Date of last revision: 30 May 2023
Privacy Notice
Residently takes your privacy seriously and is committed to protecting and respecting it.
We want you to understand how we collect and use information about you. We also value your comments about the way we do this.
The privacy notice (“Notice”) tells you:
It also contains information on the correct people to contact in the unlikely event that you have a complaint.
Here are some key details about us:
Our name: Residently Services (UK) Limited (we will refer to ourselves using the word “we” and related words such as “us” and “our” in this Notice)
Place of incorporation: England and Wales
Company number: 10834962
Registered address: 4th Floor, 100 Fenchurch Street, London EC3M 5JD
VAT number: 279 8483 31
We are one business in a group of companies, and we are the key decision-maker on data privacy in that group. This Notice, therefore, applies to all companies in our group, and the words “we” (and similar) shall include a reference to a group company, where relevant.
Under data protection law, we are known as a “data controller”. This means we are responsible for the way in which we collect and process your personal data and must meet our legal obligations in relation to it. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisor for data protection matters.
If you would like to contact us in relation to this Notice or your personal data, you may do so by:
Data Protection Team
Residently
60 Pear Tree Street
London EC1V 3SB
We live by the following principles:
Any information that relates to an identified, or identifiable, living person is personal data.
You are identifiable if it is reasonably likely that your identity could be inferred from that data alone or from that data in combination with other information.
We collect your personal data from you in the following ways:
Directly from you
This can happen in the following circumstances:
From our third-party partners
From automated technologies
As you use the Website and App, we collect Technical Data (see definition below) about your equipment, browsing actions and patterns. We collect this by using cookies and other similar technologies, subject to receiving your consent for the setting of non-essential cookies. Much of this is not personal data in the legal sense – but, to the extent that it is, we treat it lawfully as such.
Please see our COOKIES POLICY for further details. You are able to set your cookies as required.
We are a digital business operating in the property sector. We use technology to streamline and enhance the renting process, and provide some additional elements of customer support. We provide a number of services, chief among which are the following:
It will depend on circumstances, but the types of personal data we may collect include:
Applying for a role
Note that if you apply for a post with us, and provide your CV, we will receive more detailed personal data (if you provide it), including biographical data about institutions you have attended and other posts that you have held.
Aggregated Data
We also collect Aggregated Data, which is large-scale statistical data. We use it for matters such as understanding the percentage of Website or App users that look at a particular page. Aggregated Data is not personal data, as it will not reveal your identity. However, if we combine Aggregated Data with your personal data, so that you can be identified, we will treat the combined data as personal data and use it in accordance with this Notice.
Special Categories
We do not ordinarily collect any “special categories” of personal data about you (this is the legal term describing details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences (although we do process information regarding County Court Judgments).
In certain circumstances, our partner Let Alliance will run PEP (‘politically exposed person’) and/or sanctions checks regarding applicants in order to establish a person’s status (and any requirements that arise from a person’s status), and this may bring up some of the information referred to in the paragraph above.
Note: do you have to provide personal data?
In general, no – although in some situations we may be unable to provide a service if you do not. If we need to collect personal data by law, or to perform a contract with you, and you do not provide it, we may be unable to proceed.
We use your personal data to perform contracts with you, when our legitimate interests allow us to, to comply with the law, and when you consent.
Whenever we use your personal data, we need what is known as a “lawful basis”. These are prescribed by law and are limited in number. Please see the glossary below for more about lawful bases. Sometimes we may have more than one lawful basis for the same processing activity.
A summary of our use of your personal data, and the lawful bases on which we rely, is as follows:
Activity
Commencing onboarding services for property managers and landlords
Types of personal data
Identity
Contact
Lawful basis (or bases)
Legitimate interests
Activity
Enabling you to open an account with us
Types of personal data
Identity
Contact
Lawful basis (or bases)
Performing a contract with you
Activity
Transferring your personal data to our App to enable us to perform a full onboarding service
Types of personal data
Identity
Contact
Lawful basis (or bases)
Consent
Activity
Performing a full onboarding service in relation to people who have consented to the transfer of their data to the App
Types of personal data
Identity
Contact
Financial
Biographical
Lawful basis (or bases)
Legitimate interests (in this case, performing a contract with a relevant property manager or landlord)
Activity
Provision to you of our App
Types of personal data
Identity
Contact
Financial
Transaction
Technical
Profile
Lawful basis (or bases)
Legitimate interests
Performing a contract with you
Activity
Performance of administrative services, such as maintaining lease documentation and enabling communication between property manager/landlord and tenant
Types of personal data
Identity
Contact
Financial
Transaction
Lawful basis (or bases)
Legitimate interests
Activity
Processing and/or facilitating payments and refunds
Types of personal data
Identity
Contact
Financial
Transaction
Lawful basis (or bases)
Performing a contract with you
Legitimate interests
Activity
Facilitating the provision of additional services to tenants through our Website and App
Types of personal data
Identity
Contact
Financial
Transaction
Lawful basis (or bases)
Performing a contract with you
Legitimate interests
Activity
Facilitating a credit check
Types of personal data
Identity
Contact
Financial
Lawful basis (or bases)
Legitimate interests (in relation to receipt of basic information from the property manager that identifies you)
Consent (for the transfer of more detailed information to the partner performing the check)
Activity
Communicating with you about this Notice
Types of personal data
Identity
Contact
Lawful basis (or bases)
Legal obligation
Legitimate interests
Activity
Administering your involvement in competitions and special offers
Types of personal data
Identity
Contact
Profile
Usage
Lawful basis (or bases)
Performing a contract with you
Legitimate interests
Activity
Asking and enabling you to leave a review or complete a survey
Types of personal data
Identity
Contact
Profile
Marketing
Lawful basis (or bases)
Performing a contract with you
Legitimate interests
Legal obligation
Activity
Sending e-marketing to you
Types of personal data
Identity
Contact
Lawful basis (or bases)
Consent
Activity
Responding to your questions or complaints
Types of personal data
Identity
Contact
Financial
Transaction
Profile
Lawful basis (or bases)
Performing a contract with you
Legitimate interests
Activity
Personalising your Website experience
Types of personal data
Identity
Contact
Profile
Usage
Marketing
Technical
Lawful basis (or bases)
Legitimate interests
Activity
Operating, evaluating and improving our business and the Website
Types of personal data
Technical
Usage
Lawful basis (or bases)
Legitimate interests
Activity
Protecting against fraud and other criminal activity
Types of personal data
Identity
Contact
Financial
Transaction
Technical
Profile
Usage
Lawful basis (or bases)
Legal obligation
Legitimate interests
Activity
Complying with our legal obligations (for example, to HMRC and to comply with requests not to send electronic marketing)
Types of personal data
Identity
Contact
Transaction
Marketing
Lawful basis (or bases)
Legal obligation
Legitimate interests
Activity
Participating in legal action
Types of personal data
Identity
Contact
Financial
Transaction
Profile
Usage
Marketing
Lawful basis (or bases)
Legitimate interests
Legal obligation
Activity
Evaluating your job application
Types of personal data
Identity
Contact
Profile
Lawful basis (or bases)
Legitimate interests
Legal obligation
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we fairly consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, and are lawfully entitled to do so, we will notify you and explain the new legal basis.
Consent
We will make sure we have your consent before sending direct-marketing communications to you via email, the App, or SMS.
You have the right to withdraw consent to e-marketing at any time. This will not affect the lawfulness of marketing that took place prior to the time when we action your withdrawal of consent.
As explained in our Cookies Policy, we will not set non-essential cookies unless we have your consent.
Automated decision-making: we do not make decisions solely by automated means.
At all times, our use of your personal data is guided by the key principles set out in section 3 above. With those principles in mind, we may give certain personal data to the following categories of people:
We retain your personal data for no longer than is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (and whether we can achieve those purposes through other means), and the applicable legal, regulatory, tax, accounting and other requirements.
In some instances, we are legally required to hold data for minimum periods: for example, under English tax law.
We may store your contact details, and carry out marketing profiling activities, for direct electronic marketing purposes. If you have given your consent, we may contact you about our products or services that may be of interest to you.
If, having opted in, you prefer not to receive any direct electronic marketing communications from us, you can opt out at any time. We will give you the option to opt out each time we send a marketing communication by electronic means.
Opting out will not affect our ability to use your personal data for the other purposes set out in this Notice, and it will not affect the lawfulness of electronic marketing carried out prior to the time when we actioned your opt-out request.
We may transfer your personal information to a location (for example, to a secure server) in another territory if we consider it necessary or desirable for the purposes set out in this Notice and if we are permitted by law to do so.
Where we do so, we will sure that transfers:
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our authorised employees, authorised contractors and third parties referred to in this Notice have access to your personal data.
All our employees and contractors who have access to your personal data are required to adhere to our privacy requirements, and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by us.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. You should not share a password with anyone.
We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Any transmission over the internet is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Please contact us if you would like more information about this.
You have certain rights in relation to your personal data. Please see the “Your Legal Rights” section of the glossary below for more information.
We may first need to verify your identity (and, in certain cases, verify that you have authority to make the request on another person’s behalf).
In general, we try to deal with genuine requests within one month. Occasionally it may take longer, in which case we will let you know in advance.
You do not have to pay a fee to exercise these rights. However, if your request is excessive, repetitive or unfounded, we may charge a reasonable fee or refuse to comply with your request.
Our Website and App may include links to websites, plug-ins and applications that are owned by someone other than us. Clicking on those links may allow the owner to collect or share your personal data. We have no control over other sites, are we not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.
We may change this Notice from time to time. Please check this Notice on our Website regularly to ensure you are aware of the most recent version.
In the first instance, we hope you raise any issues with us directly – in almost all situations, matters can be resolved very simply. To do this, please contact compliance@residently.com.
Should you find it necessary, you have a right to raise a concern with the UK’s information regulator, the Information Commissioner’s Office: https://ico.org.uk/.
LAWFUL BASES
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS:
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected (although we may need to verify the accuracy of the new data you provide to us).
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for legal reasons, which will be notified to you, if applicable, at the time.
Object to processing of your personal data where we are relying on a legitimate interest and where this adversely affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to continue to process your information.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies, explained as follows.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, arrange and manage bookings and make use of e-billing services.
Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your favourite choice of service).
Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We may place our cookies on your device via our Site. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.
There are two types of cookies used on our Site, namely "persistent cookies" and "session cookies".
Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access our Site.
Our Site may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.
We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on our Site or by sending you an email.
It's important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide our Site to you, and your only option is to stop accessing our Site and deactivate your account.
END OF PRIVACY NOTICE
