1. Introduction & Statutory Context
Lanternpickor Asset Management Ltd. (hereinafter referred to as "Lanternpickor", "we", "us", or "our") is dedicated to upholding the highest standards of data protection, client confidentiality, and fiduciary discretion. This Privacy Policy sets out the strict basis upon which any personal data collected from property owners, institutional clients, prospective tenants, contractors, and visitors to lanternpickor.yachts is processed, stored, and protected.
We comply comprehensively with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018 ("UK GDPR"), the Swiss Federal Act on Data Protection (FADP), and relevant international privacy statutes.
2. Data Controller Information
The designated Data Controller responsible for your personal information is:
Lanternpickor Asset Management Ltd.
Company Registration No: 09482173
Registered Office: 48 Berkeley Square, Mayfair, London W1J 5AW, United Kingdom
Data Protection Officer (DPO) Contact: [email protected]
3. Categories of Data Collected
Depending on your relationship with Lanternpickor, we may collect and process the following categories of data:
- Principal & Client Data: Full legal names, residential addresses, passports/national identity documents, proof of wealth, tax residency certifications, and corporate ownership registers (for SPVs and trusts).
- Tenancy Applicant Data: Employment histories, diplomatic accreditation records, bank statements, credit history references, right-to-rent verification documents, and guarantor undertakings.
- Property & Technical Telemetry: Asset floor plans, utility meter serial numbers, IoT environmental sensor logs (temperature, humidity, water pressure), and maintenance access logs.
- Digital & Browsing Metadata: IP addresses, browser specifications, operating system versions, and anonymized user journey paths captured via essential cookies.
4. Lawful Bases for Processing
We process personal data strictly under established legal bases pursuant to Article 6 of the GDPR:
- Contractual Necessity (Art. 6(1)(b)): Executing property management mandates, negotiating tenancy agreements, managing escrow accounts, and dispatching authorized repair technicians.
- Legal & Regulatory Obligations (Art. 6(1)(c)): Fulfilling anti-money laundering (AML), Know-Your-Customer (KYC), and statutory tax authority reporting requirements across the UK, France, Switzerland, and Italy.
- Legitimate Fiduciary Interests (Art. 6(1)(f)): Maintaining the physical security of high-value real estate, preventing fraud, and optimizing digital platform performance.
- Explicit Consent (Art. 6(1)(a)): For non-essential digital communications and customized market research newsletters where explicitly opted in.
5. Data Retention & Secure Storage
Lanternpickor retains personal records only for the minimum period necessary to fulfill fiduciary, contractual, and statutory accounting purposes. Standard tenancy contracts and financial records are retained for seven (7) years following contract termination to comply with statutory taxation audits. All electronic records are stored within ISO/IEC 27001 certified European cloud data centers with AES-256 bit encryption at rest and in transit.
6. International Data Transfers
Where data must be transferred between our UK, French, and Swiss operational desks, transfers are conducted under the UK International Data Transfer Agreement (IDTA) or European Commission Standard Contractual Clauses (SCCs), ensuring equivalent levels of protection across all jurisdictions.
7. Your Statutory Rights
Under GDPR and applicable data protection legislation, you possess enforceable rights:
- Right of Access: Request a full copy of all personal records maintained by Lanternpickor.
- Right to Rectification: Demand immediate correction of inaccurate or incomplete records.
- Right to Erasure ("Right to be Forgotten"): Request data destruction where statutory retention mandates have expired.
- Right to Restriction & Objection: Restrict certain processing actions or object to legitimate interest processing.
- Right to Lodge a Complaint: You have the right to lodge a formal complaint with the UK Information Commissioner’s Office (ICO) or your local European Data Protection Authority.
8. Inquiries & DPO Contact
To exercise any statutory privacy rights or submit inquiries regarding our cryptographic data storage practices, please address our Data Protection Officer at: [email protected].