- Who are we?
Urban Splash Management Limited and some of its associated group companies are registered as data controllers under the UK Data Protection Act 2018 (“the Act”). We are committed to delivering accessible, appropriate, timely and effective services and it is important that we can properly co-ordinate what we do for your benefit. We may share your information across service providers within our group. When you provide your personal information to one company within the Urban Splash group, your details will be held on a secure central system. They key service providers within the Urban Splash Group are Urban Splash Management Limited and Urban Splash Work Limited. Any company within our group that stores, processes and makes decisions about your personal data is a registered data controller under the Act.
- How do we collect information about you?
Urban Splash is in the business of developing, selling and renting homes and commercial property. As part of this process, we will require personal and organisation information.
We collect personal data from you when you express an interest in our products and services either over the phone, via email, social media, webforms, our contact us provision, when signing up to newsletters and other communications and at events we attend or host.
If you contact our teams and offices, you may be asked for your name, company name, email address, telephone number and confirmation of security credentials.
If you rent or buy a property from us, we will require financial information for invoicing and collection purposes, this may include bank details, credit card information, invoice name, address, and a point of contact. We also need to verify your identity and address, and we will need to see documents such as a passport, driving licence, bank statement or utility bill.
If you attend an event where we are participating, you may have given additional consent to be contacted by us following the event.
If you connect with us through a social media channel, we will know your social media handle and any other information including photos you make available through our interactions and your profile.
If you use our websites or emails, we will have details about your usage of our sites through cookies and similar technologies. This information may include IP addresses and information about your visit.
If you complete surveys or enter competitions, they may require contact information such as name, phone number, email address, company name and job title.
If you complete an enquiry form on our website, we will ask for details such as name, email address, phone number, company name etc..
If you are an applicant for a role at Urban Splash, we will require information relating to your career history which could include name, address, phone number and email address along with your employment history.
If you visit our sites or offices, you may be asked to provide your name, signature, company name and car registration number. There may also be CCTV installed at some sites and images recorded may be used for the purpose of security, accident investigation and crime prevention.
- Data from your device, usage of our website and applications
When you access our website, and if you agree, we use tools such as cookies and similar technologies to collect information which may contain data about your device and your usage of our site and services. The nature of what these tools collect differs between websites, but it would fall into similar categories.
For further information regarding cookies and other similar technologies, please see our cookies policy here.
- Social Media
Our website implements social media sharing functionality and widgets. By using these features, you will be connecting to and sharing information from your browsing session with these organisations. If you are logged into your social media account, it is also possible that they will connect your activity on our site to your social media account.
This is also the case if you access our social media pages on a social media platform. The respective social media company may add your interaction to any information they may already have about you or your interests.
In all cases, in that transfer of data the social media provider is a data controller and responsible for what they do with your personal data. If you want to find out more, it is worth accessing their privacy notices.
- How do we use your information?
Information we obtain from you is used to:
— Respond to your requests for specific services
— Improve and extend our services
— Analyse user/purchaser/visitor interactions
— Market additional Urban Splash services
- Processing activities that are covered
This notice applies to the processing of personal data collected by us when you:
— Visit our website
— Visit our social media pages
— Rent or buy a residential property or commercial space with us
— Visit our offices
— Send and receive communications such as emails and phone calls
— Register for and/or attend events where we participate or host
— Are an applicant to join Urban Splash
— For sales and marketing purposes
— For the understanding, development, growth, and administration of our business
Where we use social media or external websites and where you click a social media icon or link to an external website on our website, be aware that these companies are independent from Urban Splash, they manage their own affairs, and they will be a data controller in their own right. If you have any questions pertaining to how they process your personal data, you should review their privacy notices which will be available on their websites.
- Purpose for processing and the legal bases for processing we rely on
We collect and process personal data for the following purposes and with the following legal bases:
— Where our website is concerned, we are processing your personal data with your consent if it is required and for some elements of our website, we are processing based on the legitimate interest to operate and administer the site. Where site security is concerned and the activities through our cookies enable a secure site, this is administered as a legitimate interest.
— We may ask you for personal data when dealing with enquiries. This data would be processed as a legitimate interest in being able to effectively follow up on your enquiry. This is also the case where it relates to a service enquiry or complaint, unless of course it is linked to a contractual obligation. It could include service updates and client communications, in which case it is processed as part of the fulfilment of our contract.
— Managing event registration and administration of the event is done as a legitimate interest in ensuring the efficient administration and follow up of the event. We also rely on legitimate interests to process client contact data for service surveys. If you choose to complete the survey with our partner, then this is done based on your consent.
— Managing your payments and payments relating to the services we provide. This also includes the entirety of the payment process in line with the terms and conditions of our service. We may also from time to time have to escalate this process to a third-party debt collection service. The disclosure of such data would be a legitimate interest and data would be processed as part of our contractual terms.
— The identification of opportunities both with prospects and opportunities within our existing client base is done as part of furthering the legitimate interests of the business. Any sharing of data internally with Urban Splash group companies is also a legitimate interest when it is done for similar purposes. This data may also be used to improve user experience and our understanding of both the client journey and appropriateness of products and services at different points of client lifecycle within Urban Splash.
— Personal advertising on our website is done with your consent when you select ‘Accept All Cookies’. Advertising of our products and services offline is done in the pursuit of our legitimate interest and is done with your prior consent.
— Registering your information as a visitor to one of our offices will be done as a legitimate interest to protect our building, business, and colleagues. It may also be used to administer non-disclosure and confidentiality agreements.
— If you provided a testimonial about our service, you will be doing so of your own free will and the details may be retained until you ask us to remove them.
— Setting up and managing your journey as a customer is again done as part of the performance of our contract with you. This is also the case when it comes to good administration of matters relating to your contract with us.
— Where you have applied to rent or buy a property from or with us, we will process your information in order to progress your application, contact you with updates, and assess your credit history and financial status. You will be asked for identification documents and references. This processing is done in part as a legitimate interest, in part with your consent and in part as a legal obligation. We use third party referencing agencies to perform most of these checks and share your contact details with them. You will provide some of your details to them directly. Where data is shared with these organisations, we may both be data controllers. Further data protection information regarding their activities can be gained from them.
— While you are living in a property that is managed by Urban Splash, we will process your information in order to provide ancillary services and contact you with updates. We use our own maintenance teams as well as third party contractors to carry out repairs to your property. We will generally liaise with them directly to arrange any repairs, though in some circumstances, especially in an emergency, we may share your contact details with them so that they can arrange appointments directly with you.
— We work closely with the freeholders and managing agents of our buildings and from time to time, we may need to provide your contact details and other personal details to them or their suppliers, for example if they need to communicate with you about the maintenance of common areas or the management of a car park.
— Once you have signed a tenancy agreement with us, as part of the move-in process, we will share details of your tenancy with utilities providers and the council, so that they are able to bill you for services provided.
— Where you have applied as a candidate for a role at our company, we will process your information in order to progress your application, contact you with updates, assess your qualities and capabilities against the requirements of the role and against other candidates. You will also be asked for proof of qualifications, references, and other right to work information such as identification documents. This processing is done in part as a legitimate interest, in part with your consent and in part as a legal obligation. We may also use recruitment companies from time to time, and where data is shared with these organisations, we will both be data controllers and you will have been referred to us from them or have approached us directly and we will share your details with them. Further data protection information regarding their activities can be gained from them.
— We may use personal data relating to usage products for reporting and analytical purposes. This is a legitimate interest in trying to improve our offering and further the growth of the business.
— We will send sales and marketing communications such as emails or phone calls related to our services and those services of other companies in the Urban Splash group only if we can do so in accordance with data protection legislation.
— There are legal obligations that we must comply with, which may be tax related or involve dealing with local or national government, authorities, agencies or courts and professional advisors. It may be in our legitimate interest to protect our rights and if necessary, to disclose information for the protection of those rights or to comply with court orders.
- Legal requests for information
Urban Splash may be required under law to provide personally identifiable information to government authorities, such as the Police, or local councils. Providing such government departments/agencies have legal right to access our records and such enquiries are correctly made, we will supply such authorities with the information they require.
- With whom do we share your information?
We would only share personally identifiable information with third parties not already covered by this notice if:
— You agree to us sharing this information.
— We are forced to bring legal action against a customer who has breached an agreement or contract with us.
— We sell, assign or transfer all or part of Urban Splash and the services it provides, providing your personal information is sold, assigned, or transferred only to the acquirer as part of such a transaction.
— They are providing services to Urban Splash. Such third parties are limited in their rights to use such information only for the provision of these services to Urban Splash.
- Where do we store your information?
- How long do we retain your information?
We retain your data for as long as necessary to fulfil the purpose for its collection and processing. In some instances, this may be a short period of time, for instance, as an unsuccessful job applicant we may retain your records for only 6 months once the process has concluded. In other instances, and especially where there is a legal obligation to retain your information for a certain period of time, we will do so in order to comply with the legal requirement; this is typically 6 years.
Once your data is no longer required it shall be deleted or if it is technically not possible to delete it, we shall ensure sufficient controls are in place to put it beyond future use.
- Your rights
these are set out in more detail below. If you wish to exercise any of these rights, you can do so by contacting Urban Splash at https://www.urbansplash.co.uk/contact or by emailing our Company Secretary firstname.lastname@example.org . Please note that you will need to provide Urban Splash with evidence of your identity.
Request access to your personal information: You can ask us to give you a copy of the personal information that we hold about you.
Request correction: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
Request erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Right to object: You can object to us processing 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 restriction: You can ask us to restrict our use of your personal information in the following circumstances: 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) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
Withdraw consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
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.
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.
- Contact information
If you have any queries concerning this policy, please email email@example.com or call us on 0161 839 2999. We endeavour to respond to all requests within 3 working days.
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading, or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It may not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. You can email us at firstname.lastname@example.org.
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law - www.ico.org.uk/concerns
- Policy changes