Resicentral Limited and Resicentral Global Limited (collectively "Resicentral") respect the privacy rights of individuals and is committed to protecting their personal data. This privacy policy sets out how Resicentral looks after the personal data that it processes.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.
We are Resicentral Limited of Lien House, 120 High Street, Skelton, England, TS12 2EA.
The nature of Resicentral's business involves the provision of a smart property management platform to review, monitor and automate the control of specific aspects of the environment within a property. Resicentral provides these goods and services to its customers (who may be housing associations, private landlords, property management companies or other building/asset owners or operators) ("Customers"). Resicentral may also provide goods and services to other members of its' Group from time to time, including Host & Stay Group Limited and Host & Stay Limited ("Group Companies"). In the course of providing its goods and services, Resicentral may process personal data relating to employees and personnel of its Customers ("Customer Personnel") and certain third parties such as tenants, occupants and visitors to properties at which Resicentral's goods and services are installed and provided ("Occupants").It may also process personal data about other third parties who utilise Group Companies' goods and services such as landlords and occupants of those Group Companies ("Group Customers") and third parties who operate alongside Customers.
This privacy policy sets out how Resicentral collects and processes personal data in such circumstances, and whether it acts as a Controller or Processor for the purposes of data protection legislation in relation to such processing.
Resicentral may issue other privacy policies on specific occasions where it processes personal data in different circumstances, and this privacy policy does not apply to the processing of personal data of Resicentral's employees, or visitors to its website. This privacy policy supplements any such other notices and privacy policies and is not intended to override them. It is important that this privacy policy is read together with any other privacy policy or fair processing policy Resicentral may provide on specific occasions when it is collecting or processing personal data so that data subjects are fully aware of how and why Resicentral is using their personal data.
Resicentral has appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
Email address: dpo@resicentral.co.uk
Postal address: Lien House, 120 High Street, Skelton, England, TS12 2EA
Telephone number: 03330 341 312
Data subjects have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated on [16.07.2024]. Historic versions can be obtained by contacting us.
Accessing Resicentral's services may include links to third-party 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 these third-party websites and are not responsible for their privacy statements. When you leave our service, we encourage you to read the privacy policy of every website you visit.
When Resicentral provides goods and services to its Customers, it may process personal data of Occupants and Customer Personnel on behalf of that Customer. Resicentral may also provide goods and services to Group Customers and process personal data of Group Customers on behalf of its Group Companies. When it processes personal data in these circumstances, Resicentral acts as a Processor for the purposes of data protection legislation and the relevant Customer or Group Company will be the Controller of that personal data. Occupants, Customer Personnel and Group Customers should therefore have regard to any separate privacy policy issued by the Customer or Group Company, however key information about how Resicentral processes personal data in these circumstances is as follows:
Overview – Resicentral as Processor
Processing by Resicentral To provide goods and services which enable the Customer or Group Customer to review, monitor and automate the control of specific aspects of the environment within a property.
Duration of the processing For as long as Resicentral is engaged in the provision of goods and services to the relevant Customer or Group Customer.
Purposes of Processing To provide Resicentral's goods and services to the Customer or Group Customer.
Categories of Data Subject and Personal Data Processed Customers and Group Customers
Asset Owners
Including individual landlords, landlord personnel, corporate clients and personnel.
• Identity Data including first name, last name, username or similar identifier, title, workplace and workplace contact details.
• Contact Data including address, email address and telephone numbers.
Property Management
Including personnel and representatives from Purpose-Built Student Accommodation (PBSA), assisted living organisations, commercial hospitality and those employed in the build to rent and private rented sector.
• Identity Data including first name, last name, username or similar identifier, title, workplace and workplace contact details.
• Contact Data including address, email address and telephone numbers.
Customer Personnel
• Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, login credentials.
• Contact Data including address, email address and telephone numbers.
End Users/Occupants
• Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data including address.
• Technical Data obtained from sensors within the property occupied by an Occupant about the environment in a property such as light levels, noise levels, temperature, air quality, whether the room is occupied and energy usage. Resicentral® Air Quality Monitoring identifies if occupants are being exposed to a variety of volatile organic compounds and particulates (airborne pollutants) within the property to provide data and insights to improve overall air quality to promote health and wellbeing. This Technical Data may be linked to individual Occupants.
Third party Processors Apple
Microsoft Azure Cloud Services
Third Countries where personal data is transferred US
EU
Technical and organisational security measures and safeguards for protection of personal data Encryption, access and admin controls, training.
Multi factor authentication.
In addition to processing personal data of Occupants, Customer Personnel and Group Customers for the purposes of providing its goods and services to Customers (in its capacity as Processor) outlined at Section 2 above, Resicentral will also (i) process personal data of Customer Personnel for the purposes of managing and maintaining Resicentral's relationship with that Customer and (ii) process the personal data concerning Occupants which it obtains in the course of providing its goods and services to Customers and or Group Customers to create anonymised and aggregated data and use that anonymised and aggregated data for the purposes set out below.
When it processes such personal data in the circumstances set out in this Section 3, Resicentral acts as a Controller for the purposes of data protection legislation and will be responsible for such personal data.
(i) The personal data Resicentral collects when it acts as a Controller and the purposes for which it will use such personal data
Resicentral may collect, use, store and transfer different kinds of personal data about data subjects and we have set out below, in a table format, a description of such personal data, the ways we plan to use such personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Resicentral will only use personal data when the law allows it to. Most commonly, 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.
- Where we need to comply with a legal obligation.
See below GLOSSARY, LAWFUL BASIS to find out more about the types of lawful basis that we will rely on to process your personal data. Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using that personal data. Data subjects can contact us for details about the specific legal ground we are relying on to process their personal data where more than one ground has been set out in the table below.
(ii) Details of processing where Resicentral is a Controller
Data Subject Categories of personal data processed Purpose / Activity Lawful basis for processing including basis of legitimate interest
Occupants of properties where Resicentral's goods and/or services are provided. Identity Data including first name, maiden name, last name, marital status, title, date of birth, gender.
Contact Data including address.
Technical Data obtained from sensors within the property occupied by an Occupant about the environment in a property such as light levels, noise levels, temperature, air quality, whether the room is occupied, energy usage, whether an Occupant is smoking. This Technical Data may be linked to individual Occupants. To create Anonymised and Aggregated Data. Anonymised and Aggregated Data is the Technical Data collected in relation to Occupants, which has been (i) fully anonymised in such a way that it can no longer be identified as relating to the Customer or any specific property and such that no individuals can be identified in or from the data; and (ii) aggregated with other such Technical Data held by Resicentral in relation to its other Customers. Legitimate Interest – it is a legitimate interest of Resicentral to create Anonymised and Aggregated Data so that it can be used within our business and for the purposes of research and development, product development and to create and distribute benchmarking and analytics information to third parties (including Customers). This provides insight which improves the service provided by Resicentral for all Customers and helps us to develop our products/services and grow our business.
Group Customers Identity Data including first name, last name, title
Contact Data including address, email address and telephone numbers.
For the purposes of providing Resicentral's goods and/or services to the landlord and for maintaining the relationship with the landlord, for example corresponding with the landlord, notifying the landlord about changes to our terms or privacy policy. Legitimate Interest – it is a legitimate interest of Resicentral to communicate with relevant landlords in order to administer the contract with the Customer and facilitate and enhance the provision of Resicentral's goods and services to the Customer.
Customer/Group Customer/ Customer Personnel Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, login credentials.
Contact Data including address, email address and telephone numbers.
Financial Data (where the Customer is an individual) including bank account and payment card details.
For the purposes of providing Resicentral's goods and/or services to the Customer and maintaining and managing Resicentral's relationship with the Customer, for example corresponding with the customer, notifying the Customer about changes to our terms or privacy policy and administering the contract with the Customer and processing orders and payments. Legitimate Interest – it is a legitimate interest of Resicentral to communicate with relevant Customer Personnel in order to administer the contract with the Customer and facilitate and enhance the provision of Resicentral's goods and services to the Customer.
Performance of Contract - where the Customer is an individual who has entered a contract with Resicentral, we will process certain personnel data as necessary for the terms of that contract.
Customer/Group Customer/ Customer Personnel
Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, login credentials.
Contact Data including address, email address and telephone numbers.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Transaction Data including details about products and services you have purchased from us.
To make suggestions and recommendations to you about goods or services that may be of interest to you. Legitimate Interest – it is a legitimate interest of Resicentral to develop our products/services and grow our business.
Consent - this data is processed where the customer consents to the receipt of marketing messages.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, and Transaction Data (as defined in the table Details of processing where Resicentral is a Controller above) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or a Group Member and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, we can still send you service messages which are email and other correspondence which directly relate to the goods and services we provide such as warranty notifications and other information it is reasonable for us to provide to you as part of the service we offer.
(iii) Change of Purpose
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 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 perform the contract we have entered into or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
(iv) How do we collect personal data?
We use different methods to collect personal data including through:
· Data received from our Customers. Our Customers may provide personal data to us such as name, email address, contact telephone numbers about Occupants.
· Direct interactions. Customer Personnel and Occupants may give Resicentral their personal data by filling in forms or by corresponding with us by post, phone, email, via the Resicentral apps and platform or otherwise. This includes personal data provided when such personnel apply for our products or services, create an account, subscribe to our service or publications, request marketing to be sent to them, or give us feedback or contact us.
· Automated technologies or interactions. Resicentral will automatically collect Technical Data from sensors within the property occupied by an Occupant about the environment in a property such as light levels, noise levels, temperature, air quality (including pollutants and particulates as detailed above), whether the room is occupied, energy usage and humidity. This Technical Data may be linked to individual Occupants.
· Third parties or publicly available sources. Resicentral will receive personal data about Occupants and Customer Personnel from various third parties as set out below:
· Marketing lists purchased;
· Re-sellers and value added re-sellers;
· Group Companies; and
· Sales agents.
(v) Disclosures of your personal data
We may share your personal data with the parties and for the purposes set out in the table Details of processing where Resicentral is a Controller above.
· Our Group Companies acting as processors and who are based in the UK and provide leadership reporting.
· External Third Parties i.e. service providers acting as processors based in UK, Europe and US who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, Europe and US who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties 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.
(vi) International transfers
We will not transfer personal information outside the UK unless such transfer is compliant with the UK's General Data Protection Regulation ("UK GDPR"). This means that we cannot transfer any personal information outside the UK unless one or more of the following applies:
• the UK government has decided that another country or international organisation ensures an adequate level of protection for your personal information or the data is being transferred to a company in the US which has signed up to the UK-US data bridge;
• the transfer of personal information is subject to appropriate safeguards, which may include:
o binding corporate rules; or
o the International Data Transfer Agreement or the UK Addendum.
• one of the derogations in the UK GDPR applies (including if you explicitly consent to the proposed transfer).
We currently transfer personal information outside the UK to:
• the European Union; and
• the United States of America.
(vii) 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. 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.
(viii) Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see Legal rights of data subjects below for further information.
Anonymised and Aggregated Data can no longer be associated with individuals and so once we have anonymised and/or aggregated the data, we may use this information indefinitely without further notice to you.
(ix) Legal rights of data subjects
Under certain circumstances, data subjects have the following rights under data protection laws in relation to their personal data:
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:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 process your personal data. 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. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any 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 speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
4. Glossary
Lawful Basis
• Legitimate Interest means the interest of Resicentral in conducting and managing our business to enable us to provide the best service/product to our Customers and the best and most secure experience. We make sure we consider and balance any potential impact on data subjects (both positive and negative) and their rights before we process their personal data for our legitimate interests. We do not use personal data for activities where our interests are overridden by the impact on data subjects (unless we have the consent of the data subject or are otherwise required or permitted to by law). Data subjects can obtain further information about how we assess our legitimate interests against any potential impact on them in respect of specific activities by contacting us.
• Performance of Contract means processing the data of a data subject where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Group in relation to a company, means any subsidiary or holding company from time to time of that company, and any subsidiary from time to time of a holding company of that company. Holding company and subsidiary has the meaning given in section 1159 of the Companies Act 2006.
Lein House,
120 High Street,
Skelton,
England,
TS12 2EA
