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Privacy Notice

1. Important Information And Who We Are

Privacy Notice
This privacy policy sets out how The Pollen Estate uses and protects your personal data when you sign up for and use the Beneficiary data room (website) for the purposes of viewing documents relating to and managing your interest in The Pollen Estate.

The website is not intended for children and we do not knowingly collect data relating to children.

If you are signing up to the website on behalf of a Beneficiary, you must have their consent to share their data and that they are aware of the provisions contained within this policy.

Controller

The Pollen Estate is the controller and responsible for your personal data (collectively referred to as “TPE”, “we”, “us” or “our” in this privacy policy).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name and last name.
  • Contact Data includes address, email address and telephone numbers.
  • Profile Data includes your username and password.
  • Usage Data includes information about how you interact with and use the website and information contained therein.
  • Financial Data includes information about your percentage interest held in TPE.
3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You give us your personal data by filling in the online registration form to grant you access to the website.
4. How we use your personal data
Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and grant you access to documentation relating to your interest in TPE. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.
Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

To register you as a user on the Beneficiary data room so that you can access documentation relating to your interest in The Pollen Estate.

Type of Data

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Financial

Legal Basis

Legitimate Interests for us to grant Beneficiaries access to documents relevant to their interest in The Pollen Estate.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above:

  • Specific third parties including HighQ (provider of the website) and Charles Russell Speechlys LLP (legal advisor).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. In some circumstances you can ask us to delete your data.

9. Your legal rights

You have rights under data protection laws in relation to your personal data. These include:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data in certain circumstances.
  • Object to processing based on legitimate interests.
  • Request the transfer of your data to a third party.
  • Withdraw consent at any time where we are relying on consent.
  • Request restriction of processing of your personal data.

If you wish to exercise any of these rights, please contact us (see Contact details).

No fee usually required

You will not have to pay a fee to access your personal data unless your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information to confirm your identity and ensure your right to access your personal data.

Time limit to respond

We try to respond to all legitimate requests within one month. It may take longer if the request is particularly complex.

Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us:

  • Email address: info@thepollenestate.com
  • Postal address: 6th Floor, 25 Farringdon Street, London, EC4A 4AB
11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues www.ico.org.uk.

We would appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 25/04/2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.