URBAN STUDY – COMBINED UK GDPR PRIVACY POLICY

1 – Scope

This Privacy Policy is split into two sections: 
Section 1 – covers all Data Subjects including enquiries, residents and employees 
Section 2 – applies only to Residents 

A Privacy Policy Addendum is available for employees, please ask your manager.

Section 1 – applicable to All Data Subjects

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The 2018 Data Protection Act and the UK General Data Protection Regulation (UK GDPR), along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data and protect against the unlawful processing of personal data.

This Privacy Policy is for the Urban Study Group and for other the trading names, which are all listed below:

Aidan House Management Ltd ICO registration ZA635481
Melbourne Hse. Management Ltd ICO registration ZA635430
Warwick House MGMT Ltd ICO registration ZA635515

For the purposes of data protection and this Privacy Policy, all entities will be referred to as Urban Study. In the event of any differences in data processing the relevant company name will be used in full.

In conjunction with the Urban Study Privacy Policy, the Privacy Policy of CRM Students Ltd, should also be considered, as operator of the Urban Study Group. This can be found “here” . In agreeing to the Urban Study Privacy Policy, it is also considered that you are agreeing to the CRM Students Ltd Privacy Policy.

Urban Study is pleased to provide the following information:

2 – Who we are

Urban Study is a developer and operator of homes for rent in the UK. Urban Study has a contractual agreement with CRM Students Ltd to act as Operator of all Urban Study sites.

3 – Personal data

1. a) The business uses the information collected from you to provide quotations, make telephone contact and to email you information concerning your enquiry.

For those with tenancy agreements with Urban Study, additional information may need to be collected. Only that information necessary for Urban Study to fulfil its contractual obligations will be collected.

1. b) For marketing purposes, Urban Study may use the contact details provided by you to respond to your enquiries including making telephone contact and emailing information to you which we believe may be of interest to you.
2. c) When you make initial contact, including through website enquiries, you consent to Urban Study maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. At all times, the business will work hard to be fully UK GDPR compliant.
3. d) Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence, when you visit us, from phone calls and details of your visits to our website, including but not limited to personally identifiable information like Internet Protocol (IP) addresses.
4. e) The business will only collect the information needed so that it can provide you with the services it provides; Urban Study does not sell or broker your data.
5. f) Telephone calls may be recorded for training and security reasons and this will be announced at the start of the call. Where recorded, call data is retained no longer than six months unless it is required longer for legal reasons.
6. h) Further information exclusively pertaining to data protection and employees is covered in their employment contract and the Company Handbook.

4 – Legal basis for processing any personal data

To meet our contractual obligations to residents and legitimate interests when responding to enquiries concerning the services provided.

For potential and existing residents Urban Study seeks your explicit consent to the sharing of your data with certain third parties, but only where special categories of personal data are involved such as in certain circumstances medical information, which it may need to share to protect you or supply the services it is contracted to provide you. Urban Study will only share data where necessary to provide the services it is contracted to provide, to enforce our contractual rights and to protect residents from harm as part of our duty of care.

5 – Legitimate interests pursued by the business

To promote Urban Study’s building and homes for rent. Communications may include direct mail, email, newsletters, telephone calls, social media and any other channels to reach those who may be interested in renting or using the facilities provided by the business.

6 – Your agreement

Through agreeing to this Privacy Policy, you are agreeing to Urban Study processing your personal data for the purposes outlined. You can withdraw agreement at any time by using the postal or email address or telephone number provided at the end of this Privacy Policy.

7 – Disclosure

Urban Study will keep your personal information safe and secure, although our administration team will have access to your contact details so that they can manage your account. Some of the services used to support the business such as marketing, website management, legal and debt collection services are outsourced from third-party suppliers.

Urban Study will always put in place with these third-party suppliers a processing agreement and will only share personal information with them where required to meet your requirements or to support our legitimate interests or contractual obligations.

In certain circumstances the business may need to disclose your Personal Information to meet legal, regulatory or valid governmental requests.

Urban Study may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.

8 – Retention policy

Urban Study will process personal data for the duration of any business dealings and will continue to store only the personal data needed for up to eight years after any contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details and/or liabilities.

9 – Data storage

Data is predominantly processed within the UK. Certain personal data is also held within Microsoft SharePoint for Business, Alto and Google Drive.

10 – Your rights as a data subject

At any point whilst Urban Study is in possession of or processing your personal data, all data subjects have the following rights: 
• Right to information – you can ask for information about what data is being processed and the rationale for such processing. 
• Right of access – you have the right to request a copy of the information that we hold about you. 
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. 
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. 
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing. 
• Right of portability – you have the right to have the data we hold about you transferred to another organisation. 
• Right to object – you have the right to object to certain types of processing such as direct marketing. 
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Urban study refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

At your request, Urban Study can confirm what information it holds about you and how it is processed.

11 – You can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data. 
• Contact details of the data protection officer, where applicable. 
• The purpose of the processing as well as the legal basis for processing. 
• If the processing is based on the legitimate interests of Urban Study and information about these interests.  
• The categories of personal data collected, stored and processed. 
• Recipient(s) or categories of recipients that the data is/will be disclosed to. 
• How long the data will be stored. 
• Details of your rights to correct, restrict, object to processing and rights to erasure. 
• Information about your right to withdraw consent at any time. 
• How to lodge a complaint with the supervisory authority (ICO). 
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data. 
• The source of personal data if it wasn’t collected directly from you. 
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

12 – To access what personal data is held, identification will be required

Urban Study will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months.

A minimum of one piece of photographic ID listed above and a supporting document is required. If Urban Study is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to [email protected] 

13 – Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Urban Study you have the right to complain to us. If you do not get a response within 30 days you can complain to the ICO.

Section 2 – this applies only to Residents

Resident Addendum Privacy Policy

14 – Lawful basis for processing your personal data

Where possible your personal data will be processed using contractual as the applicable lawful basis for processing. In certain circumstances such as providing useful information like the newsletter, we will be relying on legitimate interests. For medical and other categories of special data Urban Study will seek your explicit consent. For expediency, Urban Study seeks your explicit consent to the sharing of your data with certain third parties as this could involve some medical information, which it may need to share to protect you or supply the services it is contracted to provide you. Urban Study will only share data where necessary to provide the services it is contracted to provide, to enforce our contractual rights and to protect you the tenant.

15 – Consent

By signing your tenancy agreement, you explicitly consent to Urban Study sharing your details where required with any relevant landlord’s agent or consultant and retain any of the personal information you provide including special categories of personal data for the purpose of administering your tenancy agreement, to protect you and to support the delivery of services in relation to the lease. It should be noted that CRM Students Ltd as operator of the Urban Study sites, will also have access to all personal data. Their privacy policy can be found here.

17 – Urban Study and external service partners

As a matter of policy, you should not be contacted by Urban Study or by any other service partner to market any products or services that do not relate to your tenancy agreement.

18 – Urban Study promotional material

When you are contacted to introduce a newsletter, survey, service provider or other promotional material relating to your tenancy, you will be given the opportunity to opt out of these if you so wish, and the same opportunity to unsubscribe from any subsequent communications.

19 – Service emails

Certain information appertaining to the contractual aspects of your tenancy agreement and building management will continue to be sent to you even if you have unsubscribed out of receiving promotional information.

20 – Mandatory information

Some services provided through CRM Students Ltd, such as access to your apartment, are a compulsory part of this lease agreement. However, you can also opt out of notifications about promotions and events offered by Urban Study’s third-party service partners.

21 – Our use of your personal information

Urban Study will need to use your personal data to provide the services Urban Study is contracted to provide you, as detailed within this tenancy agreement. A copy of the personal information that is processed and further details of your rights can be accessed via Section 1 of this privacy notice.  If you have any questions, please contact Urban Study’s data protection officer, using the contact details also at the end of Section 1.

Employees
22 – Separate Privacy Policy Addendum just for employees

A separate Privacy Policy Addendum is provided just for employees, please ask your Line Manager for a copy

Cookies

This website uses cookies for analytic purposes and to enhance your browsing experience.

When you visit our website, we use Google Analytics to gather standard internet log data and details about visitor behaviour. This helps us understand how people use our site, such as the number of visitors and the specific areas they explore.

Privacy Policy for Use of Google Analytics

Introduction

This Privacy Policy explains how we use Google Analytics to collect and analyse data about our visitors. By using our website, you agree to the collection and use of information in accordance with this policy.

What is Google Analytics?

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. It helps us understand how visitors interact with our website, enabling us to enhance the user experience.

Information We Collect

When you visit our website, Google Analytics automatically collects certain information, including:

• IP Address: To determine the approximate geographic location.
• Device Information: Such as device type, operating system, and browser type.
• User Behaviour: Pages viewed, time spent on pages, and navigation paths.
• Traffic Sources: How you arrived at our website (e.g., search engine, direct link, referral).

Use of Collected Information

We use the data collected through Google Analytics for the following purposes:

• Website Improvement: To optimize content and layout for a better user experience.
• Performance Monitoring: To understand Website performance and identify issues.
• Audience Analysis: To analyse visitor demographics and interests.
• Marketing: To evaluate the effectiveness of our marketing campaigns.

Data Sharing and Disclosure

We do not share or sell any personally identifiable information collected via Google Analytics to third parties. However, Google may use the data collected by Google Analytics in accordance with its own privacy policy.

Cookies and Tracking Technologies

Google Analytics uses cookies to collect data about your interactions with our website. These cookies help us understand how visitors engage with the website and enhance their browsing experience. You can manage your cookie preferences or disable cookies through your browser settings.

Your Rights and Choices

You have the following rights regarding your data:

• Opt-out of Google Analytics: You can install the Google Analytics Opt-out Browser Add-on to prevent Google Analytics from collecting data about your visits.
• Cookie Management: You can control and manage cookies through your browser settings.
• Data Access: Request access to the personal data we hold about you.
• Data Deletion: Request the deletion of your personal data.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the effective date. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

[email protected]