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General

This is the privacy policy of the following organisations:

  • QSix LLP
  • QSix Real Estate Finance LLP 
  • QSix Residential Limited
  • QSix PSE2C Limited
  • QSix Shared Equity Limited
  • QSix Commercial Limited
  • QSix Co-Investment Limited
  • QSix Deutschland GmbH
  • QSix UK Residential LLP
  • QSix UK Management LLP

Collectively known as QSix 

The organisations listed above are asset management advisers and arrangers that originate and arrange real estate and real estate debt investment on behalf of leading institutional investors. This includes the following activities:

  • Providing property advisory services to Phoenix Spree Deutschland Limited, a Berlin-focused German residential property fund.
  • Providing advisory and arranging services to funds, which acquire portfolios of assets or financial interests in shared equity or equity release mortgages.
  • Acting as investment adviser to a real estate finance lender to support the acquisition or refinancing of commercial property.

QSix is committed to safeguarding the privacy of all your information, to ensure it is secure at all times and treated in the strictest of confidence. Please note any information that is transmitted over the internet is not 100% secure, and any information transmitted via the internet is at the individual’s own risk.   Any personal information you give to the QSix will always be processed in accordance with applicable laws.

The term “your information” means any information we hold about you, both online and offline which you or third parties provide to us which is required in order to provide the services to you that we do. An example of where data is collected could be when you contact us, via phone, email or letter.

What personal data does QSix process?

QSix may processes some or all of the following information in respect of their role as advisers to corporate funds. These funds hold a range of assets includes ones that involve private individuals and as such personal data is collected and processed.

Individual details – name, address (and proof of address), alternative address, date of birth, date of death, other contact details (e.g. telephone and email details), gender, marital status and family details.

Identification details – identification numbers issued by government bodies or agencies (e.g. depending on the country you are in, social security or national insurance number, passport number, ID number, driver’s license number or tax identification number.)

Financial information – Income and expenditure and other financial information such as details of financial history including bankruptcies and credit scores.

Tenant information – information about tenants of buildings owned by Phoenix Spree Deutschland including employment information.

Shared equity information – Information about shared equity mortgages and second charge deeds that they have in place.

Equity Release information – Property details, lease details and sale price of property.

Credit and anti-fraud data – credit history, information about IVA’s and bankruptcies, allegations of crimes and sanctions details received from various anti-fraud and sanctions databases or regulators and law enforcement agencies.

What are the sources of this personal data?

QSix may collect and receive Personal Data from various sources, but in most cases not from individuals directly. These sources may include:

  • Where a member of QSix provides asset management services to funds, personal data is provided by the funds directly, the servicing providers or their professional advisers who are contracted by the funds to provide administration activities.
  • Information provided by the facility agent, lender or the lender’s advisers on commercial real estate loans.
  • Information provided by commercial real estate borrowers, their owners, subsidiaries and related parties.
  • Tenant information provided by Phoenix Spree Deutschland or its agents to allow property management services to be conducted.
  • Anti-fraud databases and other third-party databases, including sanctions lists.

The collection of this data does depend on the country the borrower is in.

How does QSix use your personal data and who does QSix transfer it to?

In this section we lay out the purpose for which we use this personal data, outline how we share this information and the legal basis that we use to rely on the processing of your data.

Please refer the table entitled Legal basis for processing data below to view how we process the data, what data we process and the legal grounds for this processing.

The personal data can also be disclosed to the following parties, this can vary on the type of activities that are being conducted as shown in the legal basis for processing data table:

  • Proposed purchaser of the shared equity mortgages or other mortgage products.
  • The lenders under the shared equity mortgage.
  • The Lenders of the commercial real estate loan.
  • The commercial real estate lenders professional advisers.
  • Professional advisors of that proposed purchaser.
  • Professional advisers of the lenders.
  • Regulators.
  • The facility agent.
  • Auditors.
  • Police or courts.
  • Banks.
  • Government or law enforcement agencies.
  • Shareholders.

Please note the QSix does not sell or rent any of your personal data nor do they use it for marketing purposes. In addition, no data is transferred outside of the EEA.

The legal basis for processing

Please view this table to view how we process the data, the data we process and the legal ground for this processing.

How long will we hold your data for?

We will not ask for more information than we need for the purposes we are collecting it and will securely dispose of the information when it is no longer needed for the given purpose.

In respect of shared equity mortgages, Personal Data will be held for either the period dictated by our clients under our contractual obligations or 12 years after the shared equity mortgage has redeemed. The reason being that shared equity mortgage contracts are deeds, and this is the time period in which a breach of obligation claim could be brought under a deed.

For commercial real estate loans and tenant information, Personal Data will be held for either the period required under our contractual obligations or for six years, which is the applicable statutory limitation period regarding contractual claims.

What rights do you have with respect to your personal data that we collect directly from you as an individual?

Under data protection legislation, you have the following rights:

(I) ACCESS TO YOUR INFORMATION

You have a right to request a copy of the information that we hold about you. If you would like a copy of the information we hold about you, please write to Head of Compliance, QSix LLP, Royal Trust House, 54 Jermyn Street, London, SW1Y 6LX or via info@qsix.com You may be asked to verify your identity before a request can be processed. The information will be provided to you within one month of the receipt of the request, however, if they are complex or there is more than one, QSix reserves its right to extend this time period by a further two months (being three months in total).

We reserve the right to charge £15 for each further requests of the same data or where the requests are excessive or repetitive.

(II) CORRECTION OF YOUR DATA

QSix wants to make sure your personal data is accurate and up to date. We will update our records if you inform us that your details have changed or are incorrect and we will regularly review and assess the quality of our information. Please write to Head of Compliance, QSix LLP, Royal Trust House, 54 Jermyn Street, London, SW1Y 6LX or via info@qsix.com   to update any incorrect information and this will be actioned within one month.   Please note there may be scenarios where QSix can refuse a request for rectification.

(III) RIGHT TO HAVE YOUR DATA ERASED

You have the right to have your personal data erased and this request can be made verbally or in writing. Please note this right only applies in certain circumstances. For example, this right does not apply to non-personal data. In addition, if you request your data to be deleted and there are legitimate reasons why it should, QSix may not be able to perform all the services to you as a borrower. QSix will write to you within one month in response to this a request.

(IV) RIGHT TO RESTRICT THE PROCESSING OF YOUR DATA

You have the right to request the restriction or suppression of your personal data that is held and used by QSix. This request can be made verbally or in writing and while QSix is permitted to hold the data it cannot use it. Please note that this right only applies in certain circumstances as outlined below:
• The data is inaccurate
• The processing is unlawful, or;
• If QSix no longer needs the personal data for the purposes it is held.

QSix will write to you within one month in response to this a request.

(V) RIGHT TO PORTABILITY

It is possible that you have a right to port your data to another provider if the basis for collecting and processing this data was consent (other basis’s outlines in this privacy notice, do no confer the right to portability). If this applies please contact us for further information.

(VI) WITHDRAWING CONSENT AND THE RIGHT TO OBJECT

Where you have given consent to the processing of your personal data, you have the right to withdraw this consent. In addition, you have a right to object to processing where the legal basis is HMS’s legitimate interests. For both scenarios please write to Head of Compliance, QSix LLP, Royal Trust House, 54 Jermyn Street, London, SW1Y 6LX or via  info@qsix.com to withdraw this consent or object.

(VII) IF YOU HAVE A COMPLAINT REGARDING HOW YOUR DATA IS HELD OR PROCESSED

Head of Compliance,
QSix LLP
Royal Trust House,
54 Jermyn Street,
London,
SW1Y 6LX
or via info@qsix.com 

In addition, you have the right to complain directly to the Information Commissioners Office (ICO) anytime, their details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
www.ico.org.uk