This policy explains when and why we and companies in our Group collect personal information about individuals who are customers, prospective future customers, previous customers and other individuals who may be connected to them, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.
This policy may change from time to time so please check this page occasionally to ensure that you’re aware of any changes. This policy was last updated on the 24th of May 2018.
1) WHO WE ARE
Student Castle Limited is a company registered in England and Wales (registration number 07119911), whose registered office is at 70 High Street, Fareham, Hampshire PO16 7BB. This policy also applies to the following Group Companies; SC Walmgate Management Limited (company registered number 08220322), SC Mitchams Corner Management Limited (company registered number 08444935), SC Pulteney Road Management Limited (company registered number 09053826), SC Causewayside Limited (company registered number 10416197), SC Claypath Management Limited (company registered number 08882637). We respect your right to privacy and will only process personal information you provide to us in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy and/or data protection laws.
If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us by any of the following means:
o Post: Third Floor, 16 D'Arblay St, London W1F 8EA
o Email: email@example.com
2) HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information from you in the following ways: Personal information you give to us: This is information about you that you give to us by, for example:
• Visiting our Website (www.studentcastle.co.uk)
• Using our Web or mobile applications
• Viewing or following our channels on any social media platforms;
• Corresponding with us by phone, email or otherwise;
• Attending one of our organised events;
• Showing interest at a University accommodation fair or event which is provided by you voluntarily. This includes all information given to us at the time of registering on our website, making a booking or enquiry, requesting additional information, completing requested research surveys and managing your personal details (including engaging in correspondence with us by phone or email and accessing documents). The information you supply will include your name, address, email address and phone number(s), date of birth, enquiry details, course/year of study and where you heard about us.
3) PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect the following information, either by request or automatically:
your contact details, geographic and demographic information, preferences and other data such as visits to our website and app and any resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server, the Internet Protocol (IP) address used to connect your computer or device to the Internet and browser type.
Personal information we may receive from other sources: We may also obtain certain personal information about you from external sources or other third party companies where you have previously provided your consent to personal information being shared, in accordance with those third parties’ own privacy policies. These include educational establishments and booking agents. This information collected typically includes your contact details, demographic information, and any previous preferences you have stated.
4) TYPE OF PERSONAL INFORMATION WE PROCESS ABOUT YOU
We may process a range of personal information about you.
- Correspondence information contained in our correspondence or other communications with you about our products, services or business
- Biographical such as your academic background and course(s) of study
- Contact information which can be used to address, send or otherwise communicate a message to you
- Identification information contained in a formal identification document such as your passport
- Banking/Billing information used to collect payments from you or return money owed to you. Check your application for credit worthiness and information relating to the provision of credit to you
- Fraud information relating to the occurrence, investigation or prevention of fraud
- Legal information relating to legal claims made by you or against you
- Behavioural such as your activities, actions and behaviours
- Correspondence information, date of birth and identification information about your guarantor
5) HOW WE USE YOUR PERSONAL INFORMATION
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below. Where there is a Legal Requirement We will use your personal information to comply with our legal obligations, such as: (i) to assist any public authority, industry regulator or criminal investigation body; (ii) to correctly identify you when you contact us and/or to verify the accuracy of data we hold about you. Where it is required to complete or comply with a Contract We may use and process your personal information where we have sold you a product or products, supplied you (or continue to supply you) with any services, where we have arranged for the supply of another party’s products or services to you as their appointed agent, or where you are in detailed discussions with us about the sale or purchase of a product or service. We will use this information in connection with ensuring that the terms of the relevant contract(s) are carried out or entered into. This may include circumstances in which we are not a party to the contract ourselves, however we have been appointed to administer or provide services relating to that contract. For the purpose of this description, a ‘contract’ will typically mean a sale and purchase agreement, lease or management services agreement. Please refer to ‘Type of personal information we process’ about you above for details of the types of personal information we process for these purposes. Where we have assessed there is a Legitimate Interest We may use and process your personal information where we have deemed it is necessary for us to pursue either our legitimate interests as a business, your legitimate interests as a resident or prospective resident, or the Legitimate Interests of a Group company, for the following purposes:
• to correspond or communicate with you generally, for example with company or relevant location news;
• for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services or share your details with third parties to do the same, as explained below);
• for analysis to inform our future marketing strategy, and/or to enhance or personalise your customer experience (such as improving the quality or relevance of information we provide to you in future);
• to verify the accuracy of data that we hold about you and create a better understanding of you as a customer or potential customer;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• for prevention of fraud and other criminal activities;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• to review facts, assess and improve our service to customers through recordings of any calls with our offices;
• for the management of any queries, complaints, or claims you bring; and for the establishment and defence of our legal rights.
Where you have provided Consent We may use and process your personal information on the basis that you have consented for us to do so, for the following purposes:
• To contact you via email or social media with marketing information about our goods and services, predominantly being accommodation and accommodation services.
• To share your data with certain Group companies in order for them to contact you with marketing information about similar products and services.
• We will never share or sell your data with unconnected third parties for commercial gain without your knowledge and consent. You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
6) OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
We may share your information with other Group companies, who may use your personal information in the ways set out in the section How We Use Your Personal Information above, in connection with various ancillary or complementary products and/or services, for example products and services which only they can provide for regulatory reasons, or products and services which are similar to those We offer but may be under the name of a different brand. Some of our Group companies may also be service providers to us, as explained in the section below. Please see the start of this policy for a description of what we mean by Group companies with whom we may share your personal information in this way.
Our Suppliers and Service Providers
We may disclose your information to certain selected third-party service providers, agents, subcontractors and other organisations where necessary for the purposes of them providing services to us or directly to you on our behalf. Such third parties may include information technology providers (such as hosting and software service providers), digital and marketing agencies and administrative services providers. When we use third party service providers in this way, we only disclose to them any personal information that is necessary for them to provide their service and we have an agreement in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions for the purposes intended and set out in this Policy.
Other Ways We May Share Your Personal Information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, for example to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of other data subjects. If we do so, we shall take steps to ensure that your privacy rights continue to be protected and your rights are upheld.
Credit/Debit Card Payment Processors
When you purchase certain products or services via our websites, over the phone or at one of our residences or premises, a credit or debit card payment may be processed with your instruction by a third party payment processing agent who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please ask us at the time of making the payment or contact us using the details at the end of this policy. We do not store or keep a record of your credit card details on our own websites or within our own systems.
7) HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
When we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than we consider necessary. The length of time we retain your personal data may also vary depending on the legal basis we are using. Where your personal data is required to complete or comply with a Contract We may need your personal information to comply with our own legal and accounting responsibilities, and/or to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How We Use Your Personal Information above. Where we are only required to retain some of your information for these purposes, we will use our reasonable endeavours to ‘minimise’ that data and not to retain any information which we do not need to hold for 7 years. The only exceptions to this are where:
• the law requires us to hold your personal information for a longer period, or to delete it sooner;
• you exercise your right to have the information erased (where applicable) and we do not need to hold it in connection with any of the reasons permitted or required under the law. See Your Rights section below.
8) DATA SECURITY
We are committed to ensuring that your information is held securely. In order to prevent unauthorised access or disclosure we put in place suitable procedures to safeguard the information we collect from you. Where possible we only store information in structured systems (databases) which can only be accessed with secure passwords. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the internet to us. Where we collect and process any sensitive personal information, for example your bank details, we will apply additional security controls to protect that data. Where we have given (or where you have chosen) a password which enables you to access certain information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to tell us as soon as possible if you think your password may have been stolen, exposed or compromised in any way.
We may collect your personal data and any information about your preferences in order for you to receive marketing information directly from us by email, and text with services and information we think may interest you. This has been done in the following ways:
• If you complete a contact form on our website
• If you receive and act upon a marketing campaign
• If you make a reservation enquiry by telephone or email to one of our sites
• If you attend one of our social events
• If you enter a competition we have organised
• If you engage with any of our social media content
• If you download our app to one of your devices
• If you purchase a product or service from us
In any of these cases listed above we may contact you with further marketing information. We may contact you with marketing information by email or via our social media platforms.
We will not disclose any personal information to any third party for marketing purposes unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.
11) YOUR RIGHTS
You have the following rights:
- You have the right to ask us to provide you with copies of personal information that we hold about you at any time. We will provide this to you within 30 days of the request free of charge
- You have the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge
- You have the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal info with your consent) may send to you
- You have the right to request us to delete or destroy any information we hold about you after you have completed your contract with us, providing we are not required by law to keep these details for compliance, accounting or auditing purposes
- You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website www.ico.org.uk for further details.
If you wish to exercise any of the above rights, please write to us (either by post or by email) at the address specified above.
CHANGES TO THIS POLICY
Please direct any queries about this policy or about the way we process your personal information using the contact details below. If you wish to write to us, please write to Student Castle Ltd, Head Office, Third Floor, 16 D’Arblay Street, London, W1F 8EA. Our email address for data protection queries is firstname.lastname@example.org. If you would prefer to speak to us by phone, please call 020 7183 7764.