This privacy policy (“Policy”) relates to www.resooma.com, any subdomain or any
such related website and/or mobile application for such site (together the
“Website”).
You should read this Policy carefully as it contains important information about
how we will use your Information (as defined below in clause 4.1). You will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit Information to or through the Website.
If you do not consent to such processing you should not submit any Information to or
through the Website. For further information about consent see clause 7 below.
We may update this Policy from time to time in accordance with clause 18 below.
This Policy was last updated on 1st November 2017.
About us
The terms “Resooma” or “us” or
“we” refer to Future Residential Limited, the owner of the Website.
We are a company registered in England and Wales under company number 09326175 whose
registered office is at Portland House, 113-116 Bute Street, Cardiff Bay, Cardiff,
CF10 5EQ and whose trading name and branding is ‘Resooma’. The term
“you” refers to the individual accessing and submitting Information
to the Website.
Our Data Protection Officer is Lyndsay Broughton, Managing Director.
Data Protection
References in this Policy to:
“Privacy and Data Protection Requirements” means: the Data
Protection Act 1998 (until repealed) (“DPA”), the Data
Protection Directive (95/46/EC) (until repealed) and, from 25 May 2018, the
General Data Protection Regulation 2016/679 (“GDPR”) or any
equivalent provision which may replace the GDPR following the formal political
separation of the United Kingdom from the European Union; the Regulation of
Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice)
(Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic
Communications Data Protection Directive (2002/58/EC); the Privacy and
Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and
all applicable laws and regulations which may be in force from time to time
relating to the processing of Personal Data and privacy, including where
applicable the guidance and codes of practice issued by the Information
Commissioner or any other supervisory authority, and the equivalent of any of
the foregoing in any relevant jurisdiction; and
“Personal Data”, “Data Controller” and “Data Processor” and “processing” shall
have the meanings given to them in the DPA or, from 25 May 2018, the GDPR.
For the purposes of applicable Privacy and Data Protection Requirements, we
(Resooma Limited) are a Data Controller and therefore we are responsible for, and
control the processing of, your Personal Data in accordance with applicable Privacy
and Data Protection Requirements. “Personal Data” has a legal definition but, in
brief, it refers to information from which a living person can be identified. Such
information must be protected in accordance with applicable Privacy and Data
Protection Requirements.
Information we may collect about you
When you use the Website and/or when you otherwise deal with us we may collect the
following information about you (“Information”):
personal information including first and last name, date of birth, photograph
and/or likeness;
contact information including current residential address, primary email
address and/or primary phone number;
technical information including IP address, operating system, browser type and
related information regarding the device you used to visit the Website, the
length of your visit and your interactions with the Website;
information obtained through our correspondence and monitoring in accordance
with clause 12 below; and
details of any property enquiries made by you through the Website, together
with details relating to subsequent correspondence (if applicable).
education information including, graduation year, resooma attended, and course
of study.
We may monitor your use of the Website through ‘cookies’ and similar tracking
technologies. We may also monitor traffic, location and other data and information
about users of the Website. Such data and information, to the extent that you are
individually identifiable from it, shall constitute Information as defined above.
However, some of this data will be aggregated or statistical, which means that we
will not be able to identify you individually. See clause 17 below for further
information on our use of cookies.
Occasionally we may receive information about you from other sources, for example
any property agents and/or landlords you connect with through the Website, or from
any third party websites and applications that integrate or communicate with the
Website in relation to you. If so, we will add this information to the Information
we already hold about you in order to help us carry out the activities listed below.
How long we keep your Information
Subject to clause 5.2, we will keep your Information only for as long as we need
to hold it for the purposes set out in clause 8 below.
If required, we will be entitled to hold Information for longer periods in order
to comply with our legal or regulatory obligations.
Legal basis for processing your information
From 25 May 2018, under applicable Privacy and Data Protection Requirements we may
only process your Information if we have a “legal basis” (i.e. a legally permitted
reason) for doing so. For the purposes of this Policy, our legal basis for
processing your Information is:
your consent (for which see clause 7 below); or
subject to your rights set out in clause 15 below, the legitimate interest of
providing services to our users through the Website, which requires the
processing of your Information to enable us to provide these services.
Your consent to processing
As noted above, you will be required to give consent to the processing of your
Information as set out in this Policy. We will seek this consent from you when you
first submit Information to or through the Website.
If you do not consent to such processing you should not submit any Information to
or through the Website.
If you have previously given consent you may freely withdraw such consent at any
time. You can do this through your account on the Website or by notifying us in
writing (see clause 22 below).
If you withdraw your consent, and if we do not have another legal basis for
processing your information (see clause 6 above), then we will stop processing your
Information. If we do have another legal basis for processing your information then
we may continue to do so subject to your legal rights (for which see clause 15
below).
Please note that if we need to process your Information in order to operate the
Website and/or provide our services, and you object or do not consent to us
processing your Information, the Website and/or those services may not be available
to you.
How we use your Information
We
may process Information held about you for the following purposes:
to provide the Website and process any property enquiries you make through the
website, including by passing your Information to Agents (for which see 10 clause
below);
to investigate and address any comments, queries or complaints made by you or
other users of the Website;
to ensure that content from the Website is presented in the most effective manner
for you and for your device;
to conduct research, statistical analysis and behavioural analysis (including
anonymizing data for these purposes);
to provide insights based on aggregated, anonymous data collected through the
research and analysis referred to at 8.4 above;
for administration, maintenance and improvements of the Website and/or our
services;
to allow you to participate in interactive features of the Website, including
inputting information and providing feedback;
to contact you for marketing purposes (see 'Marketing and opting out' in clause 9
below);
to disclose your information to selected third parties as permitted by this Policy
(see clause 10 below);
to notify you about changes to the Website; and
to comply with our legal obligations, including obligations relating to the
protection of Personal Data.
Marketing and opting out
If you have given permission, we may contact you by telephone and email about our
products, services, promotions and special offers that may be of interest to you. We
will inform you (before collecting your data) and seek your permission if we intend
to use your data for such purposes. If you prefer not to receive any direct
marketing communications from us, or you no longer wish to receive them, you can opt
out at any time (see below).
If you have given permission, we may contact you by telephone and email to provide
information about products, services, promotions, special offers and other
information we think may be of interest to you from carefully selected third
parties. We will inform you (before collecting your data) if we intend to use your
data for such purposes. If you would rather not receive such third party marketing
information from us, or you no longer wish to receive it, you can opt out at any
time (see below).
If you have given permission, we may share your personal data with carefully
selected third party organisations and business partners and they may contact you
directly (unless you have asked them not to do so) by telephone and email about
products, services, promotions and special offers that may be of interest to you. We
will inform you (before collecting your data) and seek your permission if we intend
to disclose your data to third parties for such purposes. If you prefer not to
receive direct marketing communications from our business partners, or you no longer
wish to receive them, you can opt out at any time (see below).
You have the right at any time to ask us, or any third party, to stop processing
your information for direct marketing purposes. If you wish to exercise this right,
you should contact us by sending an email to [email protected] or contact the
relevant third party using their given contact details, giving us or them enough
information to identify you and deal with your request. Alternatively you can follow
the unsubscribe instructions in emails you receive from us or them.
Disclosure of your information
We may disclose your Information (including Personal Data):
to other companies within our group of companies (which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in
section 1159 of the UK Companies Act 2006);
to our business partners, service providers or third-party contractors to
enable them to undertake services for us and/or on our behalf (and we will
ensure they have appropriate measures in place to protect your Information);
to property agents and/or landlords (together “Agents”) who have listed
properties on the Website if you have made an enquiry about a property listed by
that Agent, following which the Agent will contact you directly about your
enquiry;
to any prospective buyer or seller (and their represenatives) in the event
that we sell or buy any business or assets;
if we are under a duty to disclose or share Personal Data in order to comply
with any legal obligation, including (but not limited to) any request or order
from law enforcement agencies and/or HMRC in connection with any investigation
to help prevent unlawful activity; and
to other third parties if you have specifically consented to us doing so.
We may disclose aggregated, anonymous information (i.e. information from which you
cannot be personally identified), or insights based on such anonymous information,
to selected third parties, including (without limitation) analytics and search
engine providers to assist us in the improvement and optimisation of the Website. In
such circumstances we do not disclose any information which can identify you
personally.
If our whole business is sold or integrated with another business your Information
may be disclosed to our advisers and any prospective purchasers and their advisers
and will be passed on to the new owners of the business.
Keeping your Information secure
We will use technical and organisational measures in accordance with good industry
practice to safeguard your Information, including the use of data encryption.
While we will use all reasonable efforts to safeguard your Information, you
acknowledge that the use of the internet is not entirely secure and for this reason
we cannot guarantee the security or integrity of any Information that is transferred
from you or to you via the internet.
Monitoring
We may monitor and
record communications with you (such as telephone conversations and emails) for the
purposes of provision of services, quality assurance, training, fraud prevention and
compliance purposes. Any information that we receive through such monitoring and
communication will be added to the information we already hold about you and may also be
used for the purposes listed in clause 8 above.
Overseas transfers
From time to time we may need to transfer your Information to countries outside
the European Economic Area, which comprises the EU member states plus Norway,
Iceland and Liechtenstein (“EEA”).
Such countries may not have similar protections in place regarding protection and
use of your data as those set out in this Policy. Therefore, if we do transfer your
Information to countries outside the EEA we will take reasonable
steps in accordance with applicable Privacy and Data Protection Requirements to
ensure adequate protections are in place to ensure the security of your Information,
including:
use of approved contractual clauses; and
ensuring that we only transfer your Information to persons or entities that
are appropriately authorised and/or accredited to process Personal Data in
compliance with applicable Privacy and Data Protection Requirements.
By submitting your Information to us in accordance with this Policy you consent to
these transfers for the purposes specified in this Policy.
Information about other individuals
If
you give us information on behalf of a third party, you confirm that the third party has
appointed you to act on his/her/their behalf and has agreed that you can: give consent
on his/her/their behalf to the processing of his/her/their Information; receive on
his/her/their behalf any data protection notices; and give consent to the transfer of
his/her/their Information abroad (if applicable).
Your rights
If you are an
individual, this section sets out your legal rights in respect of any of your Personal
Data that we are holding and/or processing. If you wish to exercise any of your legal
rights you should put your request in writing to us (using our contact details in clause
22 below) giving us enough information to identify you and respond to your request.
You have the right (subject to the payment of a small fee) to request information
about Personal Data that we may hold and/or process about you, including: whether or
not we are holding and/or processing your Personal Data; the extent of the Personal
Data we are holding; and the purposes and extent of the processing.
You have the right to have any inaccurate information we hold about you be
corrected and/or updated. If any of the Information that you have provided changes,
or if you become aware of any inaccuracies in such Information, please let us know
in writing giving us enough information deal with the change or correction.
You have the right in certain circumstances to request that we delete all Personal
Data we hold about you (the ‘right of erasure’). Please note that this right of
erasure is not available in all circumstances, for example where we need to retain
the Personal Data for legal compliance purposes. If this is the case we will let you
know.
You have the right in certain circumstances to request that we restrict the
processing of your Personal Data, for example where the Personal Data is inaccurate
or where you have objected to the processing (see clause 15.6 below).
You have the right to request a copy of the Personal Data we hold about you and to
have it provided in a structured format suitable for you to be able to transfer it
to a different data controller (the ‘right to data portability’). Please note that
the right to data portability is only available in some circumstances, for example
where the processing is carried out by automated means. If you request the right to
data portability and it is not available to you we will let you know.
You have the right in certain circumstances to object to such processing. If so,
we shall stop processing your Personal Data unless we can demonstrate sufficient and
compelling legitimate grounds for continuing the processing which override your own
interests.
You have the right in certain circumstances not to be subject to a decision based
solely on automated processing, for example where a computer algorithm (rather than
a person) makes decisions which affect your contractual rights. Please note that
this right is not available in all circumstances. If you request this right and it
is not available to you we will let you know.
You have the right to object to direct marketing, for which see clause 9.4
above.
Complaints
If you have any
concerns about how we collect or process your Information then you have the right to
lodge a complaint with a supervisory authority, which for the UK is the UK Information
Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO
helpline by calling 0303 123 1113. Further information about reporting concerns to
the ICO is available at https://ico.org.uk/concerns/.
‘Cookies’ and related software
Our software may issue ‘cookies’ (small text files) to your device when you access
and use the Website and you will be asked to consent to this at the time (e.g. when
you first visit our website). Cookies do not affect your privacy and security since
a cookie cannot read data off your system or read cookie files created by other
sites.
Our Website uses cookies and other tracking and monitoring software to:
distinguish our users from one another; collect standard Internet log information;
and to collect visitor behaviour information. The information is used to track user
interactions with the Website and allows us to provide you with a good experience
when you access the Website, helps us to improve our Website, and allows us to
compile statistical reports on Website visitors and Website activity.
You can set your system not to accept cookies if you wish (for example by changing
your browser settings so cookies are not accepted), however please note that some of
our Website features may not function if you remove cookies from your system. For
further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.
Changes to this Policy
We keep this Policy under regular review and may change it from time to time. If
we change this Policy we will post the changes on this page, and place notices on
other pages of the Website as applicable, so that you may be aware of the
Information we collect and how we use it at all times. You are responsible for
ensuring that you are aware of the most recent version this Policy as it will apply
each time you access the Website.
This Policy was last updated on 1st November 2017.
Accessibility
This Policy aims
to provide you with all relevant details about how we process your Information in a
concise, transparent, intelligible and easily accessible form, using clear and plain
language. If you have any difficulty in reading or understanding this Policy, or if you
would like this Policy in another format (for example audio, large print or braille),
please get in touch with us.
Contact Us
We welcome your
feedback and questions on this Policy. If you wish to contact us, please email us at [email protected].