Last updated 6 July 2018
Thank you for choosing to be part of our community at Bow Square (“company,” “we,” “us,” or “our). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
You agree that we have the right to transfer, store and process the data that we collect from you at a destination outside the European Economic Area ("EEA").
For the purpose of the General Data Protection Regulation 2018 (GDPR), the data controller is Atlas Residential Solutions Management UK Limited, whose registered office is located at 10 Queen Street Place, London, United Kingdom, EC4R 1AG.
Our Data Protection Officer for the purpose of the GDPR is Vivian Juan, Human Resources Director.
Please address any questions, comments and requests regarding our data processing practices to email@example.com.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- DO WE USE GOOGLE MAPS?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you give to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in containing information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you apply to rent our apartments, storage units or car park, such as your payment instrument number (such as a credit card number) and the security code associated with our payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your queries.
Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGIN” below.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – are collected automatically when you visit our Sites or Apps.
We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our Apps
In Short: We may collect information regarding your geo-location, mobile device, push notifications, and Facebook permissions when you use our apps.
If you use our Apps, we may also collect the following information:
- Geo-Location Information: We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permission, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s social media accounts, reminders, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
- Facebook Permission. We, by default, access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country), user identification numbers for your contacts, profile picture URL and any other information you chose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contact with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process our personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS” for further information.
- To send you marketing and promotional communications for Business Purposes. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
- To send administrative information to you for Business Purposes, Legal Reasons and/or possibly for Contractual Obligations. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To post testimonials with your Consent. We post testimonials on our Sites or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you for Business Purposes and/or with your Consent. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
- To protect our Sites for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual Obligations.
- To respond to legal requests and prevent harm for Legal Reasons. If we receive a witness summons, a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For our Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judifical proceeding, court order, or legal process, such as in response to a court order or a witness summons (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transsfer your information in connection with, or during negotations of, any merger, sale of company assets, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
5. DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites or Apps may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile pictures as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your accounts, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
With respect to personal information received or transferred, Atlas Residential is subject to the regulatory enforcement powers of the Information Commissioner’s Office. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
We have a strict Anti-Money Laundering policy which incorporates compliance with all relevant UK legislation (including but not limited to the Proceeds of Crime Act 2002, the Money Laundering Regulations 2007, the Bribery Act 2010 and the Terrorism Act 2000). As part of this policy, we are required to adequately identify all of our clients and customers whether you are landlords or tenants. We will therefore request evidence of your identity and, where appropriate, proof of ownership of a property and source or destination of funds. We will keep records of your identity for a period of not less than 5 years. Please note that your identity may be subject to an electronic identity check, which may also include a credit check. We will not be able to proceed with any work on your behalf if you do not provide us with this information.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
10. DO WE COLLECT INFORMATION FROM CHILDREN?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You have rights that allow you greater access to and control over your personal information. You may reivew, change or terminate your account at any time.
You have certain rights under the General Data Protecton Regulation 2018. You have the right to:
i. to request access and obtain a copy of your personal information;
ii. to request rectification or erasure;
iii. to restrict the processing of your personal information; and
iv. if applicable, to data portability.
You have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Pleasse note however that this will not affect the lawfulness of the processing before its withdrawal.
If you believe we are unlawfully processing your personal information, you also have the right to complain to the Information Commissioner’s Office, https://ico.org.uk/.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookes and to reject cookies. If you choose to remove or reject cookies, this could affect certain features of services of our Sites or Apps.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. However, we will still need to send you service-related emails that are necessary for the administration of your tenancy agreement and use of your account. To otherwise opt out, you may:
- Note your preferences when you register your information with our Sites or properties.
- Contact us using the contact information provided.
13. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Vivian Juan, by email at firstname.lastname@example.org, or by post to:
FAO Vivian Juan
3 Manchester Square
If you have any further queries or comments about us or our policies, email us at email@example.com or by post to:
FAO Vivian Juan
3 Manchester Square