University of London Housing Platform Privacy Policy

This Privacy Policy applies to users of the Private Housing and Advice Services Housing Platform and App (“Our Housing Platform”).

The Privacy Policy in summary

  • You will provide information to us in order to create an account, search for properties, rent a property, let a property or act as a guarantor.
  • We will store this information and collect data about you as required to provide you with the requested service.
  • We will carry out reporting and other analysis using aggregated data to monitor our progress and improve our services.
  • We will use third parties to maintain Our Housing Platform and ensure our payments system is safe and secure.
  • You have a number of rights around how we manage your data.

 

The University of London Housing Services

The University of London Housing Services comes under the umbrella of CoSector, which is a wholly owned subsidiary of the University of London (UoL), a registered Data Controller. The general University of London Privacy Statement is available here.

 

1. Information you give to us

We ask for and collect the following personal information about you when you use Our Housing Platform. This information is necessary for us to provide you with the requested service and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with the requested service.

Determined by your use of Our Housing Platform (i.e. the personal information you upload to our App or Website) and whether you sign into Our Housing Platform using your social media profile (i.e. Facebook, or any other social media platform that may be available from time to time) and the corresponding log in details, we will where required collect and process the following information about you:

Where you are a student or university staff member and you register with Our Housing Platform:

  • your name, age, gender;
  • your contact details including telephone number, mobile number, email address and postal address, and any proof of address you may provide;
  • your location, GPS co-ordinates;
  • your image, where this is included on your Facebook profile or other social media platform;
  • your university name and university id and any other id you may provide;
  • your payment information such as bank account details;
  • the name of your guarantor and their details such as name, address;
  • information about your computer or mobile device, including, where available, your IP address, operating system and browser type;
  • information in relation to your living habits, search specifications;
  • any other information that you may provide to us through the website and/or App.

Where you are a guarantor and you are guaranteeing a student or staff member’s rental contract:

  • your name, age, gender;
  • relationship to student or staff member;
  • your contact details including telephone number, mobile number, email address and postal address;
  • a valid proof of identity, proof of address and any proof of income you may provide;
  • other financial information such as bank account details, sort codes;
  • information about your computer, including, where available, your IP address, operating system and browser type; and
  • any other information that you may provide to us through the Website and/or App.

Where you are a landlord (private or institutional) or agent and you register and/or work with Our Housing Platform:

  • your name or employee and/or agents name and address;
  • your photo or employee and/or agents photo;
  • where applicable, your company, agent or university name, address, legal address, director name and address;
  • financial information, such as bank account details, sort codes;
  • details of your property(ies) such as address, house type, rooms, features, amenities, amount of rent;
  • photos of the property(ies);
  • details of other tenants located at property(ies);
  • tenant requirements;
  • information about your computer or mobile device, including, where available, your IP address, operating system and browser type; and
  • any other information that you may provide to us through the website and/or App.

 

2. Information you may choose to give to us

You may choose to provide us with additional personal information in order to obtain a better user experience when using Our Housing Platform. This additional information will be processed based on your consent.

  • Additional Profile Information: You may choose to provide additional information as part of your profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your account settings is part of your public profile page, and will be publicly visible to others.
  • Address Book Contact Information: You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of Our Housing Platform, like inviting them to use Our Housing Platform.
  • Other Information: You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your account, respond to surveys, post to community forums, participate in promotions, or use other features of Our Housing Platform.

 

3. Information we automatically collect from your use of Our Housing Platform

When you use Our Housing Platform and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of Our Housing Platform and Payment Services.

  • Geo-location Information: When you use certain features of the Our Housing Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Our Housing Platform may also collect this information even when you are not using the App if this connection is enabled through your settings or device permissions.
  • Usage Information: We collect information about your interactions with Our Housing Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on Our Housing Platform.
  • Log Data and Device Information: We automatically collect log data and device information when you access and use Our Housing Platform, even if you have not created an account or logged in. That information includes, among other things: details about how you’ve used Our Housing Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using Our Housing Platform.
  • Cookies and Similar Technologies: We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on Our Housing Platform, or engage others to track your behaviour on our behalf. While you may disable the usage of cookies through your browser settings, Our Housing Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookie Policy.
  • Payment Transaction Information: Our Housing Platform collects information related to your payment transactions through the platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and our payment provider, Stripe Payments Europe Limited and to allow the provision of the Payment Services.

 

4. Information we collect from third parties

Our Housing Platform may collect information, including personal information that others provide about you when they use Our Housing Platform or obtain information from other sources and combine that with information we collect through Our Housing Platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • Third Party Services: If you link, connect, or login to your account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
  • Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off Our Housing Platform through partnerships, or about your experiences and interactions from our partner ad networks.

 

5. How do we use your information?

We may use the personal data described above for the following purposes:

General:

  • to maintain and improve the functionality of Our Housing Platform;
  • to perform any contract we may have in place with you;
  • to communicate with you including sending you notifications about your account;
  • to allow us to manage your account you hold with us;
  • to improve your user experience and to prevent abuse;
  • for tax, risk management and other internal record keeping purposes;
  • to respond to any questions or other matters raised by you in relation to us, Our Housing Platform or any of our products and services;
  • to understand your use of Our Housing Platform, or keep a record of your product or service preferences;
  • for anonymous statistical reporting for the University and its member institutions;
  • to provide you with information regarding our products and services, where you have consented to be contacted for such purposes or it is otherwise lawful for us to do so;
  • for compliance with legal, regulatory and other good governance obligations; and
  • for any other purposes related to the management of your legal relationship with us.

Where you are a student or university staff member:

  • in order for us to process and complete your property searches;
  • in order for us to assist you in managing Our Housing Platform, including the payment of rent and deposits to landlords; and
  • to allow us to contact third parties such as guarantors to verify information about you.

Where you are a guarantor:

  • to allow you to guarantee someone’s application for accommodation, which will include us contacting you to verify the applicant’s information; and
  • to allow us to contact third parties such as banks and credit agencies to verify financial information.

Where you are a landlord (private or institutional) or agent:

  • to allow us to facilitate contact with prospective tenants, including agreeing to the terms of Our Housing Platform and liaising via direct chat on the platform; and
  • in order for us to process and complete your property listings that you have placed with us.

Please note that when we obtain a photo from your mobile or computer, i.e. photos of your property or your profile photo, a copy is stored on our database which is associated with Our Housing Platform. A copy may also exist in our archived systems. We may also store the details you enter on Our Housing Platform in a database. This database, along with one or more backup copies is stored on computers based in the European Union. Please note that all information captured via Our Housing Platform shall be sent to cloud storage where an internet connection is available.

We may store and process your information on our own technology systems or on systems owned by third parties that may store and process your information on our behalf.

 

6. Aggregated information

We may also convert your personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve our housing and/or other products and services.

Anonymised aggregated personal information does not personally identify you or any other user of Our Housing Platform and is therefore not personal data.

 

7. On what legal basis do we process your personal data?

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contract if we are negotiating or have entered into a contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligations if we are legally required to hold information on you to fulfil our legal obligations.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to share your details with landlords or prospective tenants when you have given it.

 

8. Our Legitimate Business Interests

We have a number of lawful reasons that mean we can use your personal information, including your consent, where you give it. One lawful reason is something called "legitimate interests". In general terms, “Legitimate Interests” means we can process your personal information if:

  • We have a genuine and legitimate reason; and
  • We are not harming any of your rights and interests.

 

9. Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

 

10. Do we share your personal data with any third parties?

In order to process your personal data for the purposes described in this Policy, your personal data may need to be disclosed to (or otherwise processed by) third parties acting on behalf of us. Such third parties could include employees or agents who are employed to administer and provide support for your account with Our Housing Platform.

We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data, in order to comply with any legal regulations or good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of our customers or other persons with whom we have a business relationship, or to purchasers or prospective purchasers in relation to a disposal of our business or assets.

The University of London Housing Services website uses Google Analytics to collect information on how visitors use our site. This information is used to create reporting and analysis to allow us to improve the site for our users. The cookies used by Google Analytics collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. By continuing your navigation of Our Housing Platform, you are consenting to the University collecting and using your information for the purposes stated above. You can disable Google Analytics tracking on your browser by following the instructions on the Google site.

We may share your data with the third parties listed below. If you would like to review their respective privacy policies, please refer to the following links:

  • For the processing of all payments we use Stripe Payments Europe Ltd. You can access their privacy policy here.
  • For sending you e-mails from Our Housing Platform, we use Mailchimp/Mandrill. You can access their privacy policy here.
  • For analytics data, we use Google Analytics. For further information on Google Analytics please see Google’s Cookie Policy here.

You may at any time log into your account and delete your details from our system if you are no longer interested in receiving our service. However where you have entered into a tenancy, whether as a landlord or student/staff member you will be bound by that tenancy agreement and also our Terms of Service. If you would like to review our Terms of Service, please refer to the following link: https://housing.london.ac.uk/about-us/policies-terms.

 

Where you are a student or university staff member:

In order to provide you with the service, we will share your personal data with prospective landlords and agents who have property vacancies to fill. Landlords and agents will have access to your information, such as your name and details. Landlords and agents will be able to contact you where you have shown interest in their property. Landlords and agents will also be able to start live chats with you, where you permit this or initiate this. We will also share your information with your named guarantor in order to verify your information.

Where you have added other students or staff members to the same property, we will share your information with these additional students (subject to you initiating this request).

As part of your use of Our Housing Platform we may share your information with the landlord or agent, your guarantor and the third parties listed above.

 

Where you are a guarantor:

Where you provide a guarantee for a student or staff member, we will share your information with the landlord of the property you act as guarantor for and where you act as guarantor on a joint tenancy agreement, we will share your information with the other tenants and guarantors for the property.  

We will also share your data with the third parties listed above. 

 

Where you are a landlord or agency:

As part of the service, we will share your personal data with prospective tenants who are interested in your property listing(s). They will receive details of your property and your name. You will be able to liaise with tenants over direct chat and tenants will be able to contact you to raise queries and inform you where i.e. a repair is required in your property.

We will also share your data with the third parties listed above. 

 

11. Where do we store your data and what safeguards are in place to protect it?

The data that we collect from you is stored by Our Housing Platform provider, SPCE Ltd, on Amazon Web Services (AWS) servers within the European Economic Area (”EEA”). We take appropriate steps with a view to protecting the security of your personal information. We will treat all your information in strict confidence and we will endeavour to take all reasonable steps to keep your information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information.

All information you provide to us is stored on these secure servers and any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Please note that the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

 

12. How do we conduct direct marketing?

We would like to provide you with information about new products, services, promotions and offers from us, which may be of interest to you. This communication may occur by post, e-mail, SMS or telephone.

Where we need consent for this we will ask for it separately (outside of this Policy). Where we need to give you an opt-out opportunity before we send you our own marketing we will do so.  Any direct marketing that you receive from us in electronic form will also provide a simple means for you to opt-out of receiving further marketing communications.  For example, in e-mails we may provide you with an “unsubscribe” link, or an e-mail address to which you can send an opt-out request. We will take steps to stop any marketing to which you object or in respect of which you withdraw your consent within a reasonable period, but please allow sufficient time for the change to be administered.

 

13. Transfers to other countries

Your personal data may be transferred by us as data controller to countries and territories outside the UK and the European Economic Area which do not have the same level of protections for personal data as apply in the UK.  We are required by the Data Protection Law to ensure that there are adequate protections for it in those other countries and territories.

 

14. How you can change your details

You can manage your information and amend your details within Our Housing Platform by accessing your account. If you are a guarantor, you will not have a separate account, please contact us instead using the details contained in section 19.

If you stop using Our Housing Platform, your information will be retained on our servers and affiliated database for a period of time after which it shall be deleted. All data retention shall be in accordance with Data Protection Law and applicable law and regulatory requirements.

 

15. What are your rights in relation to your personal data?

The GDPR provides you with the following rights. To:

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party in certain formats, if practicable.
  • Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.
  • Access to information. You have the right to request access to or receive copies of the personal data that we hold about you. If you would like to exercise this right, please contact us at data.protection@london.ac.uk.

If you believe that any information we have about you is incorrect or incomplete and you are unable to change it yourself via your account, please contact us using the details provided above us as soon as possible.  We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate.

 

16. How do we use cookies on our Website?

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site and app. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy.

 

17. What should I do if I suspect a data breach?

Under the GDPR, CoSector University of London has a responsibility to keep the personal data it holds safe, and as part of this we must have appropriate safeguards in place to ensure that we act appropriately in the event of a data breach. If you suspect that there has been a data breach in relation to personal data that CoSector University of London has under its control then please notify us immediately using our contact details found here.

 

18. Changes to the Policy

We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Policy accordingly. We encourage you to check this Policy for changes when you revisit Our Housing Platform.

 

19. Contacting us

We hope that we have shared with you all the information you need, but in the event that we have not, or if you have any questions then please contact us.

Last Updated: July 2020