Privacy Policy
PARAGON PROPERTY UK GROUP LTD
Privacy policy
Introduction and Purpose
Paragon Property UK Group Ltd (company number 12597964) (we or us) and our group of companies are committed to protecting and respecting the privacy and security of personal information. This policy describes how we collect and use personal information about you.
Paragon Property UK Group Ltd of 60 Oxford Street, Manchester, M1 5EE is a “data controller”. This means that we are responsible for deciding how we hold and use personal information. We are required under data protection laws to notify you of the information contained in this policy and we adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679 which is applicable from 25 May 2018, together with any domestic laws subsequently enacted.
This notice applies to current and former tenants and leaseholders, current and former investors, subscribers, those third parties intending to become tenants and investors, visitors to our websites, and those who have used or registered for any of our products and services.
By registering, applying for, or investing in any of our products and services, or by visiting any of our websites (Site) including mapartments.co.uk, paragonproperty.co.uk and any of our Site landing pages, you are accepting and consenting to the practices described in this policy.
You may also be asked to accept the terms of this privacy policy before applying for any of our products or services, completing an online booking or submitting an online query on our Site.
This policy does not form part of any contract that you may have with the Company. It is for information purposes only.
Information we collect from you
We will collect and process the following data about you:
Information you give us
This is information about you that you give us from your application for accommodation, from your application for investment, by filling in forms on our Site (including online booking and online query forms), by completing a paper-based application form (which we enter into our computer system), completing an application or enquiry form on our touch screen systems, corresponding with us by phone, e-mail, post, WhatsApp, Live Chat, website, Facebook adverts and other social media platforms or otherwise, or if you provide information to us through a third party.
It includes information you provide when you register to use any of our services, including any services on our Site, ask a question on our Site, participate in discussion boards or other social media functions on our Site, enter a competition, promotion, or survey and when you report a problem with our Site.
We will also collect information from you as part of the tenancy application, lease application and investment application process.
The information you give us may include:
- Tenants: Tenant name, address (including residential status and previous addresses), e-mail address, phone number, date of birth, marital status, national insurance number, nationality, next of kin, name of university or college where you are studying (if applicable), personal identification (including passport, driving licence, visa/immigration document and proof of address); Property address: term, rent, deposit, utility and service responsibilities; Guarantor name, address (including residential status and any previous addresses), e-mail address, phone number, date of birth, marital status, national insurance number, nationality, next of kin (if applicable), identification; The employment status and income information of tenants and/or guarantors, address, contact details (including email, phone) of the employer/accountant, payroll numbers, length of employment salary information and any other income received; Bank account details of the tenant and/or guarantor, including branch name, address, name of account holder, account number and sort code, and other financial information including credit history. Should you take up accommodation with us we may also hold data that you provide to us, or that we learn of, during your tenancy.
- Investors: Investor name, address, e-mail address, phone number, citizenship, date of birth, bank account details including branch name, address, name of account holder, account number, sort code, international bank identifier number, personal identification (including passport, driving licence, visa/immigration document and proof of address); and financial and lease information relating to the investment product or service. Should you invest or take up a lease with us, we may also hold data that you provide to us, or that we learn of, during the term of your investment or lease.
- technical information, which may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our help team number.
- to carry out our obligations arising from any contracts entered into between you and us and/or any of our group companies (including any tenancy agreement, lease or investment products and services) and to provide you with the information, products, and services that you request from us
- to enable us to supply you with the services and information which you have requested
- to help manage your tenancy, lease, or investment product
- to carry out due diligence on any prospective tenant, leaseholder, or investor, including whether there are any money judgements against them or any history of bankruptcy or insolvency
- to analyse the information we collect so that we can administer, support, and improve and develop our business and the services we offer
- to contact you in order to send you details of any changes to our services or supplies which affect you
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know when you submit the relevant data (which could be on our online booking form, comment/query form or any other form on which you submit information to us on the Site);
- to ensure that content from our Site is presented in the most effective manner for you and for your device
- for all other purposes consistent with the proper performance of our operations and business.
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your device;
- to allow you to participate in interactive features of our service (when these are available from time to time) when you choose to do so;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
- We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- Any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, or any of our associated companies.
- Selected third parties including: business partners, suppliers, and sub-contractors for the performance of any contract we enter into with you; analytics and search engine providers that assist us in the improvement and optimisation of our Site; credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you (which may be as part of a tenancy application).
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Paragon Property UK Group Ltd or any of its associated companies, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our online booking terms and other agreements; or to protect the rights, property, or safety of Manchester Apartments Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- To carry out due diligence on you as a prospective tenant/guarantor, including but not limited to the carrying out of affordability checks, due diligence checks and the obtaining of references from relevant third parties, whose data you have provided.
- If you request so, your information shall be disclosed in order to determine if there are any money judgements against you, as the prospective tenant/guarantor, or to determine if they have a history of bankruptcy or insolvency.
- If you are unable to make payments under your tenancy, your information may be disclosed to any relevant party assisting in the recovery of this debt or the tracing of you as a tenant/guarantor and
- In the creation, renewal or termination of the tenancy, your information may be disclosed to any relevant local authority, tenancy deposit scheme administrator, service/utility provider, factor, facilities manager or any other relevant person or organisation in connection with this.
Personal data is kept in files or within the Company’s IT systems.
We do not collect, store and use any ‘special categories’ of more sensitive personal information about you.
Information we collect about you. With regard to each of your visits to our Site we will automatically collect the following information:
Images are being recorded on some of our premises for crime prevention and the safety of both the public and our property by means of CCTV.
If you contact us using the telephone numbers listed on our Site, we may record calls for training and monitoring purposes as well as ensuring our marketing is delivered and attributed effectively.
Information we receive from other sources
This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Site. We will also have told you for what purpose we will share and combine your data. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Cookies
Our Site may use cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you use our Site and also allows us to improve our Site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or other device if you agree. Cookies contain information that is transferred to your device's hard drive.
We may use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our Site and include, for example, cookies that enable you to log into secure areas of our Site.
Analytical/performance cookies. They allow us to recognise and count the number of users of our Site and to see how users move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you and remember your preferences.
Remarketing Cookies: We may use these cookies to tailor specific advertisements to you after you leave our website that will be shown on third party websites to enable us to provide you the latest offers and information.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site or access the services we may provide to you through it.
Google Analytics cookies will expire after the following time frames: new visitor information (2 years), average length of time on website (30 minutes) and referral information (6 months).
Uses made of the information
We will only use personal information when the law allows us to. The law says that we must identify a lawful basis for each use of personal data. We rely on a number of lawful bases, including:
1. Where we have obtained freely given, specific, informed, and unambiguous consent from you to use your personal information in certain ways, for example in marketing communications.
2. Where we need to perform a contract that we have entered into.
3. Where we need to comply with a legal obligation.
4. Where we need to use personal information to pursue our legitimate interests (or those of a third party) and we believe that using personal information in that way is not overridden by the interests or fundamental rights of the person to whom the information relates.
We use information held about you in the following ways:
Information you give to us. We will use this information:
· to provide relevant marketing communications to you via email, text, post, online or telephone.
· to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them
· to communicate with you on third party social media platforms
· to monitor the effectiveness of our marketing communications and your responses to it
· if you contact us via a phone number listed on our Site, to record these for training and monitoring purposes and to identify the digital source for attribution and improvements in our digital marketing delivery
Information we collect about you. We will use this information:
Information we receive from other sources
Communication & marketing
If you are an existing contact, joined our mailing list or submitted an enquiry we may occasionally update you on our latest services, news and special offers via e-mail and telephone. You have the right to withdraw this consent or amend your marketing preferences at any time by contacting dataprotection@paragonproperty.co.uk.
Disclosure of your information
You agree that we have the right to share your personal information with:
We will disclose your personal information to third parties:
All third parties are required to take appropriate security measures to protect your personal information in line with our policies.
For tenancy and leaseholder applications/agreements:
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to me/us without your consent
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Where information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice.
For information processed through any of our Sites (include online bookings), this may be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of any of our services online booking, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
If we have given you (or where you have chosen) a password that 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How we keep your data secure
We have put in place appropriate security measures to protect your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those people who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information) or as set out in any relevant contract we have with you.
We will hold your data for up to 7 years after the expiry of the tenancy agreement, lease, or investment product.
For failed applications, we will hold your data for up to one year.
For enquiries, we will hold your data for up to two years from the date on which the enquiry is sent.
For CCTV images, we will hold recorded images for up to one month from the date of recording and downloaded images for up to two years from the date of download.
For call recordings, we will hold these for up to three months from the date of the recording.
Changes to your data
It is important that the personal information is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us. If your personal information changes, please let us know by emailing dataprotection@paragonproperty.co.uk.
Your rights
You have the right at any time to:
· Ask for a copy of the information about you held by us in our records
· Require us to correct any inaccuracies in your information
· Make a request to us to delete what personal data of yours we hold
· Ask us not to process your personal data for marketing purposes.
We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at dataprotection@paragonproperty.co.uk.
If you wish to unsubscribe from any of our emails, please let us know.
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to:
Data Controller, Paragon Property UK Group Ltd, 60 Oxford Street, Manchester, M1 5EE
Email: dataprotection@paragonproperty.co.uk.
If you have any concerns about the use of your information, we would ask that you contact us to resolve the matter in the first instance at dataprotection@paragonproperty.co.uk.
If you think your data rights have been breached, you also have the right to complain to the Information Commissioner’s Office (ICO). You can contact the ICO at:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
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