The FutureLets Ltd ("FutureLets", "we" or "us") is committed to ensuring that your privacy is protected in accordance with the law, and all personal data shall be held and used in accordance with the UK laws relating to data protection and privacy ("Data Protection Law") further details of which are available from the Information Commissioner's Office website www.ico.org.uk.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements the other notices and is not intended to override them.
For the purposes of Data Protection Law, FutureLets is the data controller and is responsible for your personal data. FutureLets is registered as a data controller with the Information Commissioner's Office, under registration number ZA118788
The personal data we collect
FutureLets may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, university ID number.
- Contact Data includes address (home, postal or other physical address), email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
Personal data does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).
FutureLets also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Please note that where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to process your application for accommodation or to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services that you request). In this case, we may have to cancel a service you have requested but we will notify you if this is the case at the time.
How we collect and use personal data
When you enquire or register for services provided by FutureLets you will provide us with certain personal data. This information may be provided online through our website, by telephone, by electronic communications, via a hard copy application form or via direct contact with our employees. Your personal data will be stored on our computer systems and in our manual records.
There are various reasons that we need to collect and process your personal data. We may collect and process the personal data about you for the following purposes:
- Applications for accommodation - we will process personal data including Identity and Contact Data provided in an application for accommodation so that we can process that application in accordance with our legitimate interests and in order to take steps prior to entering into a tenancy agreement.
- Administration of accommodation - we will process personal data including Identity, Contact and Financial Data for the purpose of providing you with accommodation in accordance with our tenancy agreement including processing of your payments for rent.
- References - we may also receive personal data about you from letting agents where we require a reference, or from your referees where you have provided us with their contact details for the purpose of obtaining a reference.
- Contact Us - We will use your Identity and Contact Data to respond to you regarding the reason you contacted us.
- Advertising, marketing and public relations - we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you and in doing so we will only send you information that is deemed relevant to your use of our services.
- Website administration - As you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve the content of the website and to customise the content or layout of the website for you, in accordance with our legitimate interests. We collect this information in a way which does not identify you and we do not make any attempt to find out the identities of those visiting our website.
- Fault reporting - If you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
- Recruitment - Personal data including Identity and Contact Data provided for an employment opportunity with FutureLets will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
We may also use personal data which you provide to us, where the law allows us to do so, as follows:
- To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get 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, we will notify you and we will explain the legal basis which allows us to do so.
Disclosure of Personal Data to Third Parties
Your personal data will only be disclosed to relevant FutureLets employees that have a need for such access for the purpose for which it was collected and will not be disclosed to any other individuals or other entities. However, we may need to share your personal data with third parties in the following circumstances:
- We are required by law to place your deposit in a tenancy deposit protection scheme and in doing so we will need to share relevant personal data with our scheme provider, The Deposit Protection Service (see depositprotection.com).
- On occasions, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, namely to utility companies (for our legitimate interest in ensuring that utility charges are directed to those responsible), contractors associated with the application, management and performance of your tenancy agreement and as otherwise set out in your tenancy agreement. Other guidance on how a tenant's information may or may not be used is published on the ICO website at page: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/consent/when-is-consent-appropriate/.
- Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any agreements which may be entered into between us.
- Where it is in our legitimate interests to share your personal information with credit agencies to ascertain the financial status of you and/or your guarantor.
- Where we are under a legal duty to do so in order to comply with any legal obligation.
- In order to protect the rights, property or safety of FutureLets, our employees, tenants and others.
We will get your express opt-in consent before we share your personal data with any company outside of FutureLets for marketing purposes, or before we send you relevant third party information on behalf of any third party.
We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect. In addition, the access to and use of the personal data that we collect is restricted to our employees who need the personal data to perform a specific job role or activity. Where personal data is shared with third parties (e.g. The Deposit Protection Service) in line with this policy responsible measures are used to protect your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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 website; any transmission 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. We urge you to take every precaution to protect your personal data when you are on the internet.
Your personal data will be held and processed on computers and in hard copy within the UK and we will not transfer any of your personal data outside of European Economic Area.
We will retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements
Details of retention periods for different aspects of your personal data are available by contacting firstname.lastname@example.org
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Other Websites and Links
The FutureLets website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third party websites and are not responsible for their privacy statements or for the content, accuracy or opinions express in such websites.
FutureLets does not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by FutureLets of the linked website.
If you decide to leave this website and access these third party websites, plug-ins and/or applications you do so at your own risk. We encourage you to read the privacy notice of every website you visit.
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, though 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 personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on 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 process your personal data which override your rights and freedoms.
- 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which 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 Paragraph to go in
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 and in particular we may not be able to process your application for accommodation. We will advise you if this is the case at the time you withdraw your consent. You can ask us or third parties to stop sending you marketing messages at any time by logging into your website account and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the "unsubscribe" (or similar) links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions
If you wish to exercise any of your above rights, please send a written request to us at the address listed at the end of this privacy notice.
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
About this Notice
This privacy notice was last updated on 25 May 2018 and historic versions can be obtained by contacting us.
Questions, comments or requests about your personal data can be sent to:
Data Protection Officer
Information Protection Unit
Coventry University Group
1st Floor, Portal House
163 New Union Street
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.