PRIVACY NOTICE
Of 3rd Floor, 7-9 Swallow Street, London W1B 4DE, including company brand Fresh, is committed to protecting and respecting your privacy. Fresh is committed to the protection of the Personal Data that we Process about you in line with the data protection principles set out in applicable data protection and privacy legislation in force from time to time in the UK including the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 ("GDPR"); the Data Protection Act 2018. As a property managing agent, Fresh is the data controller for the purposes of the GDPR in instances where you make an enquiry with us, and the joint data controller, along with the landlord of the property, when you live in one of the properties we manage.
Information you give us
You may give us information about you by filling in forms on our websites thisisfresh.com, freshstudentliving.co.uk, thisisfreshrenting.com or freshpg.com (our sites) or by corresponding with us by phone, e-mail or otherwise.
This includes information you provide when you register to use our site, subscribe to a service, search for a product or service, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
DATA RECEIVED IN THE COURSE OF AN ENQUIRY ABOUT OUR ACCOMMODATION
The information you give us includes:
*For student accommodation only
We use your name, address, email address and contact details to contact you about the enquiry you have made. We need to know your date of birth, course information and University to ensure that you are eligible to enter into a Tenancy Agreement and for our student properties to find the most convenient property for your place of study. We use your gender information to ensure that any preferences in this regard are catered for in shared accommodation. We use your language and home country information as we can in some cases provide services in your own
language and we need to know this to check your right to reside.
DATA RECEIVED FROM CUSTOMERS WHO MAKE A BOOKING
Once you have a signed Tenancy Agreement, we require the below information so that we can both fulfil our contractual obligations to each other including details of any disabilities that you may have.
We also collect the following information about you to comply with statutory requirements to make sure you have the right to stay in our accommodation including the right to reside and council tax exemptions for students.
In case of emergency and we need to contact someone close to you we keep a record of next of kin information – name, address, telephone, email.
*Student Accommodation only
**Non-Student Accommodation only
Information we collect about you
We will store cookies on your device should you consent to us doing so.
To ensure the safety of all of our residents, visitors and staff we capture and record CCTV images at different locations around our buildings.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. We collect Cookies under the following circumstances:
You will be asked to consent to cookies being stored on your device when you first visit our
website. You will also have an option to block cookies being used at this stage.
You can also set your browser not to accept cookies and the below websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
For further information visit
www.aboutcookies.org or
www.allaboutcookies.org.
Information we receive from other sources
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks like Zoopla and Rightmove, analytics providers and search information providers like Google, credit reference agencies) and may receive information about you from them.
We use information held about you in the following ways:
Information you give us.
We will process this information on the following legal bases under Article 6 of the General Data Protection Regulation (GDPR):
DATA RECEIVED AS A RESULT OF AN ENQUIRY ABOUT OUR ACCOMMODATION
We log the data provided in the course of an enquiry electronically and contact you if there are properties available. We also record details of conversations between us about your enquiry so that the relevant members of the team at Fresh understand your enquiry..
This will include the scheme about which you initially expressed an interest and others in the same area. We may continue to contact you for the duration of the period about which you enquired whenever something suitable becomes available and for one year afterwards. We will also use your information to give you the opportunity to re-book your property at the end of your tenancy.
Fresh has a legitimate interest in processing this information for purposes of marketing the property where the enquirer is looking for accommodation.
We will seek your formal consent if we wish to retain personal data for marketing purposes beyond the current and next academic year for student properties and for one year for non-student residential properties. We would also like to send you information about products and services of ours and other companies in our group, which may be of interest to you. We will gain your consent to do so, and you may opt out at any time.
If you no longer wish to be contacted for marketing purposes, please email us.
DATA RECEIVED FROM CUSTOMERS WHO MAKE A BOOKING
If you make a booking, we record the information on our tenant database. This information is used to contact you about the services that we provide to you as a tenant.
Our staff have access to this data to make sure that all parts of the Tenancy Agreement are fulfilled including the provision of services and the payments for these services. We may also share this information with third parties including contents insurance providers and our security partners. The legal basis for processing this information is for the performance of contract.
We will use your data for internal reporting, analysis and financial reconciliation purposes to ensure that we can manage the buildings effectively. We have a legitimate interest to do so in our role as property managers.
We may share your information with selected third parties including:
We may also share your information with the following third parties for performance of our contract with you:
For our own legitimate business interests we may share your information with the following categories of 3rd parties:
WHERE WE STORE YOUR PERSONAL DATA
We have an accounting operation in India, which we use to process financial information and to
prepare accounts. India is not a country in respect of which there is a European
Commission decision of adequacy. Therefore, we protect your privacy and your rights through the use of the European Commission’s Standard Contract Clauses, which are
recognised by the UK.
More information about these is available here:
/eur-lex.europa.eu/legal-content/en/ TXT/?uri=CELEX:32010D0087
All information you provide to us is stored on secure UK-based servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. For legitimate business purposes we may need to access your account you create on our systems.
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 our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
YOUR RIGHTS
The GDPR provides you with certain rights in relation to the processing of your personal data, including to:
These rights are not absolute and are subject to various conditions under:
If at any time you decide that you do not want to be contacted for any purpose, including marketing, or if you would like to exercise any of your rights as set out above, you can contact us by email.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data
We will retain your information for the following periods:
DATA RECEIVED IN THE COURSE OF AN ENQUIRY ABOUT OUR ACCOMMODATION
All information will be retained until the end of the booking period about which you enquired and for one year thereafter, unless you ask us not to contact you anymore. Consent will then be sought and refreshed annually.
DATA RECEIVED FROM CUSTOMERS WHO MAKE A BOOKING
Customer information has the following retention periods:
CCTV IMAGES
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. This version was updated on 26/03/2021.
Our website contains links to other websites. This privacy notice only applies to this website so when you proceed to other websites you should read their own privacy policies.
Questions, comments and requests regarding this privacy notice are welcomed:
• by email.
• or write to us as, Fresh Property Group, 7-9 Swallow Street, London W1B 4DE