Introduction

This Privacy Policy explains what information we collect about you, how we may use it, and the steps we take to ensure that it is kept secure. It also explains your rights and how to contact us. When we say “Castle Residential”, “we”, “us” or “our”, we are referring to the one of our group businesses that is responsible for processing your data – the controller. The controller is Castle Residential Scotland Limited, a company registered in Scotland, under company registration number SC348025.

The words we use in this Privacy Policy have the same meaning as in the Castle Residential Terms & Conditions.

We collect and process personal data for the purposes of the following Castle Residential Services:

• Property Management Services
• Landlord Registration
• Tenancy Management

Unless otherwise indicated, this Privacy Policy applies to each of these Castle Residential Services.

 

What information do we collect?

We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Contact Data includes postcode, address, previous addresses, email address and telephone numbers.
• Customer Service Contact Data includes records of your contact with our staff members, including, telephone conversations, emails and contacts through any other customer contact channels.
• Financial Data includes bank account details.
• Identity Data these can include first name, last name, date of birth, gender or similar identifier, marital status, profession, salary, payroll, adverse credit, additional income, NI number, occupants of home, smoker, dependants, pets, next of kin.
• Marketing and Communications Data includes your preferences for receiving marketing from us and your communication preferences.

 

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Sign an agreement with Castle Residential;
  • Use a Castle Residential Service;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Technical and Usage Data from the following parties:
    • Analytics providers such as Google;

 

How do we use your personal data, and what is our legal basis for doing so?

These are the legal bases we have for holding and processing your personal data:

• Contract: To enter into or perform a contract with you
• Legitimate Interest: For our (or third parties’) legitimate interests, as long as they aren’t overridden by your interests and rights
• Consent: Your consent
• Obligation: To comply with our legal obligations

And here is how we use your personal data, and our relevant legal basis (Our basis) for doing so:

When you register as a client with us, we obtain your Identity and Contact Data. That Identity and Contact Data may be supplemented over time with other information, such as Transaction Data, and additional or updated Identity and Contact Data. We use this information to maintain your registration with Castle Residential and administer our relationship with you. Our basis: Contract.

We will also use Identity and Contact Data, Payment Data and Transaction Data to monitor purchases with the objective of helping to prevent fraud. Our basis: Legitimate Interest (fraud-prevention).

From time to time, you may participate in a survey or provide us with feedback or otherwise engage with us in ways that, in combination with other data we hold, may be included in your Profile Data. In using the Castle Residential (and other) websites, we and our service providers will also collect Technical and Profile Data. We use and combine Identity, Contact, Profile, Transactional, Financial, Technical and Usage Data to make our products and services, including the Castle Residential site, and the offers you receive, better and more relevant to you, and to enable us to create content that is more suited to you and send you more relevant communications. Our basis: Legitimate Interest (making our products and services and their marketing more specific to you).

Where you opt to receive marketing communications from us, we will use your relevant Marketing and Communications Data to communicate that marketing to you. Our basis: Consent.

We retain records of our financial transactions and contracts with you in order to maintain adequate accounting records and meet legal requirements. Our basis: Obligation.

We will use your Marketing and Communications Data and Identity and Contact Data to keep you informed of important changes to our relationship with you, such as by notifying you of changes to this Privacy Policy. Our basis: Contract, Obligation and Legitimate Interest (in maintaining a compliant relationship with you).

We use Customer Service Contact Data, and your Identity and Contact Data, to deal with and investigate issues you raise with us, to communicate with you about them and to improve Castle Residential Services. Our basis: Contract; Legitimate Interest (improving Castle Residential Services).

At the outset of tenancy for example, it may be necessary for us to forward your contact information to a referencing company, utility suppliers, your local council. Our basis: Contract

During your tenancy, it may be necessary for us to forward your contact information to a maintenance contractor for example. Our basis: Contract; Obligation.

We will only use your personal data for the above purposes, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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. We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

How long will we keep your personal data for?

We keep your personal data for as long as is necessary:

• for Our basis as specified in this Privacy Policy, and
• to address relevant legal, tax or accounting requirements, including potential claims by and against us.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of that data, the purposes for which we process it, whether we can achieve those purposes through other means, as well as legal, taxation and accounting requirements.

When the need to keep your personal data ends, we either delete or anonymise it.

 

Whom will we share your personal data with?

We will share your personal data with members of our group of companies that provide services to group members, and to various third parties, but in each case always for the uses referred to above. These third parties businesses are:

• Payment and transactional service providers
• Service providers providing:
  • Web-hosting services
  • Web site optimisation services
  • Web site usage services
  • Email service provision
  • Data management platform provision
  • Customer relationship management services
  • Messaging services
  • Social media platforms
  • Online and offline marketing services
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances

We may also share your personal data with others where to do so is mandated by applicable law.

Your Marketing and Communications Data will only be shared with a third party for the purpose of them directly marketing to you where you have consented to that marketing.

If we sell our business or assets, your personal data may be provided to the prospective purchaser’s advisers with appropriate legal protections and will be passed to the new owners of the business.

 

How do we keep your data secure?

We have put in place appropriate security measures intended 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

 

Your legal rights

Under the law, 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 information unlawfully or where we are required to erase your personal data to comply with local law. 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 information 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 where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by email at info@castle-residential.co.uk. You will not have to pay a fee to exercise any of your legal rights as specified above. 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 may need to request specific information from you to help us confirm your identity and ensure your right to access the relevant your personal data (or to exercise any of your other legal rights). This is a security measure we take to help avoid your personal data being disclosed to a person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to help speed up our response.

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.

 

Password Security

Although not yet set up, moving forward we are intent on bringing our clients a members are where they can access their own account. Once implemented, access to your Account is password-protected for your privacy and security. While we do our best to protect your personal information you also must protect yourself. What does this mean?

• Keep your password or other access information secret.
• Ensure no-one else uses Castle Residential while your machine is "signed in" to the Castle Residential site.
• Make sure you sign out from your Account when not using it.

 

Editing your Account and mailing settings

We like to keep in touch with our clients so – where you have opted to receive marketing communications from us – we will use your relevant Marketing and Communications Data to communicate that marketing to you.

Of course we know lots of emails can be annoying so we try to keep ours to a minimum. However, if you feel you're getting too many or would like more you can change the settings in your Account at any time. We have a one click unsubscribe policy, and each communication gives you the opportunity to opt-out of receiving similar future communications using a link at the bottom of the email. Once underway, you will also be able to review, change or correct your identity and email address information by signing into your Account and going to the settings tab.

Please note there are some (non-marketing) communications that are an integral part of the Castle Residential Service and cannot be opted-out of. These communications cover, amongst other things, changes to the Castle Residential Service and your actual record of statements/rents. They can be brought to an end by de-registering and therefore ceasing to become a client as per our standard terms & conditions.

 

Relationship with the Castle Residential Terms & Conditions

Words we use in this Privacy Policy have the same meaning as in the Castle Residential Terms & Conditions or in your lease agreements.

This Privacy Policy is correct as of 25th May 2018

 

Contacting us

We have appointed an Information Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our Information Officer using the details set out below.

Email address of Information Officer: info@castle-reisidential.co.uk

Postal address of Information Officer: The Information Officer, Castle Residential, 63 Causeyside St, Paisley, PA1 1YT.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s 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 would request that you contact us in the first instance.