Privacy Policy

PRIVACY POLICY

This privacy policy sets out how we collect, use and store your personal data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

We respect your privacy and we are committed to protecting your personal data. When you visit our website (“https://www.folkcoliving.com”), contact us, purchase products or services from us, visit one of our properties, enter into a tenancy or make a reservation with us, we collect information about you, some of which is personal data for the purposes of the applicable data protection laws.

1. WHO WE ARE

www.folkcoliving.com, and The Palm House, Sunday Mills and Florence Dock developments (the “Developments”), are managed and operated by Urbanbubble Ltd of Sevendale House, 7 Dale Street, Manchester M1 1JA (“urbanbubble”) acting as agent for the leaseholders of the Developments who are:

Development	Leaseholders	Address
The Palm House	DTZI COLIV I HRW LEASE LP DTZI COLIV I HRW OPCO LTD	1 Bartholomew Lane, London, United Kingdom, EC2N 2AX
Sunday Mills	DTZI COLIV I ERL LEASE LP DTZI COLIV I ERL OPCO LTD
Florence Dock	DTZI COLIV I BAT LEASE LP DTZI COLIV I BAT OPCO LTD

As such, references to “we”, “our” and “us” in this notice, are to urbanbubble, acting on behalf of the leaseholders.

2. CONTACTING US

If you have any questions about this privacy policy, including any requests to exercise any of your legal rights, please contact the urbanbubble data protection officer on [email protected].

We hope to resolve any complaint brought to our attention, however if you would like to make a complaint, the data protection supervisory authority in the UK is the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns/ or by telephone on 0303 123 1113.

3. THE DATA WE COLLECT ABOUT YOU

Personal data is “any information relating to an identified or identifiable natural person”. We may collect, use, store and transfer different kinds of personal data about you, including:

Identity Data: your name, username or similar identifier, marital status, title, date of birth and gender. We may also collect passport details from you if you are a non-UK citizen;

Contact Data: your email address, postal address, billing address and telephone numbers;

Financial Data: bank account and payment card details and information which allows us to check against our eligibility criteria, including employment history, address history, household information, and payment performance;

Technical Data: 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 our Website;

Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. The RentCafe portal section of our Website is provided by a third party service provider, Yardi Systems Inc., and is subject to additional terms of use, which are available for you to access at https://resources.yardi.com/legal/rentcafe-agreement-for-property-owners-and-managers/;

Usage Data: information about how you use our Website, products, services and amenities;

Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences;

CCTV surveillance data: Our CCTV system monitors parts of our properties. Our CCTV system may record images of you and your presence and movements at one of our properties. CCTV is used to monitor our properties and to ensure the safety and security of our residents, guests and staff.

We do not collect any special category personal data about you (i.e. personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (where used for identification purposes), data concerning your health, data concerning your sex life and/or data concerning your sexual orientation).

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect your personal data. We primarily collect your personal data from you, either directly (for example, when you register with us, contact us, or send us feedback) or indirectly (for example, when you browse our Website or use our amenities).

We may also obtain personal data about you from third parties, including:

our referencing agency (namely, UK Tenant Data), which provides us with credit reports about you which we use in order to determine property affordability and your eligibility;
our inventory company (namely, Veri-Smart), which provides us with inventory reports; and
a utility company (namely, Wondrwall), which provides information to us regarding your energy consumption.

5. HOW WE USE YOUR PERSONAL DATA

We will use your personal data in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into with you;
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; or
where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although, where we propose sending direct marketing communications to you via email or text message, we will seek your consent before doing so, unless you have stayed with us or purchased goods or services from us previously and have not opted out of receiving marketing communications.

You have the right to withdraw consent to marketing at any time by contacting us on [email protected]

6. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where relevant.

We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your personal data.

Purpose/Activity

Type of data

Lawful basis

To provide accommodation services to you, including:

(a) managing your tenancy;

(b) managing your short-stay booking;

(d) collecting payments; and

(e) use of amenity space and events onsite.

· Identity Data

· Contact Data

· Financial Data

· Marketing and Communications Data

· Performance of a contract with you

· Legitimate interests

To inform our co-working provider, ARC Club, that you are entitled to full access to their facilities, so that they can provide for your access and unlock benefits of the co-working provision.

· Identity Data

· Contact Data

· Performance of a contract with you

· Legitimate interests

To help us quickly and efficiently respond to inquiries and requests;

· Identity Data

· Contact Data

· Performance of a contract with you

· Legitimate interests

To manage our relationship with you, including:

(a) Notifying you about changes to our terms or privacy policy;

(b) Asking you to leave a review or take a survey.

· Identity Data

· Contact Data

· Marketing and Communications Data

· Performance of a contract with you

· Legitimate interests

To enable you to partake in a competition, complete a survey or notify you of events at one or more of our properties.

· Identity Data

· Contact Data

· Marketing and Communications Data

· Performance of a contract with you

· Legitimate interests

To provide you with the information, products and services relating to the property and services that we are contracted to carry out.

· Identity Data

· Contact Data

· Marketing and Communications Data

· Performance of a contract with you

· Legitimate interests

To communicate with you regarding our properties and/or services, so as to send you financial documents, updates on maintenance issues, news, surveys and to assist you with operational requests, such as password reset requests.

· Identity Data

· Contact Data

· Technical Data

· Usage Data

· Marketing and Communications Data

· Performance of a contract with you

· Legitimate interests

To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

· Identity Data

· Contact Data

· Technical Data

· Usage Data

· Necessary to comply with a legal obligation

· Legitimate interests

Sometimes we are required to collect certain information by law, including date of birth, nationality, place of residence, date of arrival and profession

· Identity Data

· Contact Data

· Financial Data

· Necessary to comply with a legal obligation

7. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the persons set out below for the purposes detailed in the table above:

the relevant leaseholder of the Development and other companies who have a business interest in the Development, such as the freehold owner, or asset manager;
our third party service providers who perform services in connection with our Website or a property. For example, our third party service providers that process credit card transactions or other payment methods, and provide customer assistance with certain maintenance requests;
our investors (whose privacy policy can be accessed here);
other third parties where we are instructed to transfer a service to another provider, or to enable us to perform our contract with you; and
law enforcement bodies, or other supervisory or regulatory authorities.

In addition, we and our respective service providers may disclose and otherwise use your personal and other information where disclosure is needed to:

satisfy any applicable law, regulation, legal process or governmental request;
enforce applicable terms of use;
detect, prevent, or address illegal or suspected illegal activities (including payment fraud), security or technical issues; or
provide disclosures in connection with the acquisition, merger or sale of our business; or
protect against harm to the rights, property or safety of urbanbubble, its users or the public as required or permitted by law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

On the Website there may be outbound links to other websites owned and operated by a third party. We are not responsible for these third party websites or their use of your personal data. Each third party website has its own privacy policy, and you should review their privacy policy at the relevant time, as only the third party operating that website is responsible for use and security of the data that you provide to them.

8. INTERNATIONAL TRANSFERS

We do not transfer any of your personal data to any third parties which are located outside the United Kingdom.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

10. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it.

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 or other requirements.

If we are no longer providing services to you, we will generally delete or anonymise your personal data after seven years.

11. YOUR LEGAL RIGHTS

In certain circumstances, you have rights under data protection laws in relation to your personal data:

Right	What does it mean?
To access your personal data	You may obtain access to your information (if we’re processing it) (commonly known as a "data subject access request"), so that you can check that we’re using your personal data in accordance with the applicable data protection laws.
To rectify your personal data	You may be entitled to have your personal data corrected if the information we hold about you is inaccurate or incomplete.
To request erasure of your personal data	Also known as ‘the right to be forgotten’ and, in simple terms, this right enables you, in certain circumstances, to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
To restrict processing of your personal data	You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
Data portability	You may request that your personal data is transferred to you or another person or organisation.
To object to processing	You may have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).
To withdraw consent	Where we are relying on your consent to process your personal data, you may withdraw that consent at any time.

If you no longer want to receive certain communications (such as news or updates) from us via email or text, then you can: (1) unsubscribe from such communications by clicking the “unsubscribe” button in any email we send to you; (2) email us at [email protected] and we will remove you from the list; or (3) manage your preferences in the RentCafe portal section of the Website.

If you would like to exercise any of your legal rights set out above, or you want to ask a question about this privacy policy or how we collect and use your personal data, please email us at [email protected], providing us with enough information to identify you and verify your identity and informing us of the information to which your request relates.

We will try to respond to legitimate requests within one month from when we receive your request, but it may take a bit longer if your have made a number of requests, or your request is particularly complex. If it will take us longer to respond, we will notify you.

We usually act on requests and provide information free of charge, but we may refuse to provide, or charge a reasonable fee to cover our administrative costs of providing, your personal data or acting on your request if your request is manifestly unfounded, or you submit multiple, repetitive or excessive requests.

12. GENERAL

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review. This privacy policy will be updated from time to time in order to comply with legal, regulatory or operational requirements. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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