privacy - Hetherley

Privacy Policy

Last updated: 27/8/26

1. Who we are

This website (the “Site”) is operated by Hetherley Capital Partners Limited (“Hetherley”, “we”, “us”, “our”), a hotel real estate investment and asset management firm.

Registered/trading address:
Hetherley Capital Partners
3rd Floor, 45 Albemarle Street, London, W1S 4JL
United Kingdom

Contact email: info@hetherley.com

We are the data controller for the personal data described in this policy. This means we decide how and why your personal data is processed. If you have any questions about this policy or how we handle your personal data, please contact us using the details above.

2. What this policy covers

This policy explains how we collect, use, store and share personal data when you visit hetherley.com, contact us, or otherwise interact with us through the Site. It also explains your rights under UK data protection law (including the UK GDPR and the Data Protection Act 2018). This policy does not cover third-party websites we may link to. Please check the privacy policy of any third-party site before submitting personal data to it.

3. The personal data we collect

We collect the following categories of personal data:

a) Information you give us directly
When you use our contact/enquiry form, you may provide:
– Your name
– Email address
– Phone number (if provided)
– Company or organisation name (if provided)
– Any other information you choose to include in your message

b) Information we collect automatically
When you browse the Site, we automatically collect certain technical data via cookies and similar analytics technologies, including:
– IP address
– Browser type and version
– Device and operating system information
– Pages visited, time spent on the Site, and referring/exit pages
– Approximate location (derived from IP address)

See Section 8 (Cookies) for more detail.

We do not currently use marketing or advertising tracking cookies (such as social media pixels) on this Site.

4. How we use your personal data and our legal basis

Responding to enquiries. To respond to messages submitted via our contact form, including follow-up correspondence. Legitimate interests (responding to enquiries directed to us). Consent, where required. Understanding how the Site is used. To analyse traffic and usage patterns, identify technical issues, and improve the Site. Legitimate interests (improving our website and services). Consent for non-essential analytics cookies. Legal and regulatory compliance. To comply with legal obligations, respond to lawful requests from authorities, or protect our legal rights. Legal obligation. Legitimate interests.

We will only use your personal data for the purpose(s) for which we collected it, unless we reasonably consider we need to use it for another compatible reason.

5. Who we share your data with

We do not sell your personal data. We may share personal data with:

– Service providers who support the operation of the Site, such as our website hosting provider and analytics provider (currently Google Analytics — see Section 8), who process data on our behalf under contract.
– Professional advisers, where necessary (e.g. lawyers, auditors).
– Regulators or authorities, where we are legally required to disclose information.
– A buyer, in the event we sell or transfer all or part of our business, subject to appropriate safeguards.

All third parties are required to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes.

6. International data transfers

Some of our service providers (for example, Google, which provides our analytics tools) may process data outside the UK, including in the United States. Where this happens, we ensure appropriate safeguards are in place, such as the UK’s International Data Transfer Addendum or an adequacy decision recognised by the UK government.

7. How long we keep your data

– Enquiry form submissions: retained for 24 months from the date of your last contact with us, or longer if required to maintain a business relationship, respond to follow-up queries, or comply with legal obligations.
– Analytics data: retained in line with our analytics provider’s default retention settings of 26 months.

We will not keep your personal data for longer than necessary for the purposes we collected it for.

8. Cookies

Cookies are small text files placed on your device when you visit a website. We use the following categories of cookies:

Strictly necessary cookies – required for the Site to function correctly (e.g. remembering your cookie consent choices). These cannot be switched off.

Analytics cookies – used to understand how visitors use the Site (e.g. Google Analytics). These help us improve the Site’s content and performance. These are only set with your consent, and you can withdraw consent at any time via our cookie banner/settings.

We do not currently use advertising or social media tracking cookies (e.g. Meta Pixel, LinkedIn Insight Tag) on this Site. If this changes in future, we will update this policy and our cookie banner accordingly, and seek your consent where required.

You can control or delete cookies through your browser settings at any time. Please note that blocking some types of cookies may affect your experience of the Site.

9. Your rights

Under UK data protection law, you have the right to:

– Access the personal data we hold about you
– Rectify inaccurate or incomplete data
– Erase your data in certain circumstances
– Restrict how we use your data in certain circumstances
– Object to our use of your data where we rely on legitimate interests
– Data portability, where technically feasible
– Withdraw consent at any time, where we rely on consent (e.g. for analytics cookies)

To exercise any of these rights, contact us at info@hetherley.com. We may need to verify your identity before responding.

You also have the right to complain to the UK’s data protection regulator, the Information Commissioner’s Office (ICO), at ico.org.uk or by calling 0303 123 1113, if you believe we have not handled your personal data in accordance with the law.

10. Security

We use appropriate technical and organisational measures to protect the personal data we hold from unauthorised access, loss, misuse or alteration. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Children’s privacy

The Site is not directed at children, and we do not knowingly collect personal data from children.

12. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on this page with an updated “last updated” date.