Overview

is the Website Privacy Notice (the "Notice") for the website hosted at https://www.essentialliving.co.uk ("we", "us" and "our website"). The website is operated by or on behalf of Essential Living Management Limited. We are committed to protecting and respecting your privacy.

This Notice (together with our Terms of Use and Acceptable Use Policy and Cookie Policy and any other documents referred to in it) sets out:

• Information we collect about you on our website
• How we use your information
• Our promotional updates and communications
• Who we give your information to
• Where we store your information
• Child safety
• How we protect your information
• How long we keep your information
• Your rights
• Changes to this Notice
• How to contact us

Please read the following statement carefully to understand our views and practices regarding your personal data and how we will treat your data.

By engaging with our website, you acknowledge you have read and understood this Notice.

More information on the use of cookies and similar technologies on the site are included in our Cookie Policy.

For the purposes of the UK Data Protection Act and GDPR (the "Data Protection Law"), the data controller is Essential Living Management Limited.

Information we collect about you

We will collect and process the following personal data from you:

Information you give us

This is information about you that you give us directly when you interact with us.

This is information about you that you give when filling in forms on our website, when you request a viewing, submit an enquiry to find an apartment, or by corresponding with us by phone, e-mail, live chat or otherwise. This includes information you provide when you search for flats, book a flat, contact us through a form, start a live chat and / or report a problem with our website.

The information you give may include:

• Your name
• Address
• Email address
• Phone number
• Nationality
• Visa and financial information
• Personal description and photograph
• Details provided in correspondence (including phone, e-mail, live chat or otherwise)

Details of properties that are of interest, viewings requested / booked and property requirements.

It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.

Information we collect about you from your use of our website

We will automatically collect information from you each time you visit our website. This includes:

Technical information

The technical information we collect about includes but is not limited to:

• The Internet protocol (IP) address used to connect your computer to the Internet
• Browser type and version
• Time zone setting
• Browser plug-in types and versions
• Operating system and platform

Information about your visit

The information we collect about your visit includes but is not limited:

• 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
• Any phone number used to call our customer service number or social media handle used to connect with our customer service team.

Location data

We collect information about your location through the site. This provides an indication as to your real time location in order to activate our location services (via Google Analytics), where requested or agreed to by you, in order to deliver content, advertising or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the website.

Delivery of location services will involve reference to one or more of the following:

• The coordinates (latitude/longitude) of your location;
• Look-up of your country of location by reference to your IP address against public sources; and/or
• Your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.

See our Cookie Policy for more information on the use of cookies and similar technologies on the site.

Information we receive from other sources

This is information we receive about you:

If you use any of the other websites we operate for the other services we provide

In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.

From Third Parties we work closely with

We are working closely with third parties from whom we may receive information about you. This includes, for example, business partners, sub-contractors, payment and delivery services, advertising networks, marketing service providers (such as HubSpot), analytics providers, and search information providers (such as Google).

How we use your information

We use the information about you in the following ways:

Information you give to us

We will use this information to:

• Take steps to enter into any contract or carry out our obligations arising from any contract entered into between you and us; or take steps at your request prior to entering into a contract including to:
• Help you search for apartments.
• Help set up a viewing of an apartment.
• Draw up, provide to you and enter into any tenancy agreement (which will be handled in accordance with our Resident Privacy Notice.
• Notify you about changes to our service.

Without this information, we may not be able to perform the services you have requested from us. We will indicate on our website:

• Information on our services, which we feel may interest you and about our developments (which might be owned by our group companies), if you have indicated that you would like to receive (or if you do not object, where applicable) to receiving marketing material from us. We will always ask you your preferences at the point we collected your information.
• Our legitimate interests to:
• Present content from our site in the most effective manner for you and for your computer.
• Provide you with the information, products and services that you request from us.

Please note our legitimate interests will never be overridden by your rights. For further information see the ‘Your Rights’ section below.

Information we collect about you from your use of our website

We will use your information in our legitimate interests, where these interests are not considered to override your rights. This includes but is not limited to:

• Administering our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• Keeping our website safe and secure.
• Measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• Improving our website to ensure that content is presented in the most effective manner for you and for your computer.
• Allowing you to participate in interactive features of our service, when you choose to do so.

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights) for the purposes set out in the section entitled "Information We Collect About You From Your Use Of Our Website" above.

Our promotional updates and communications

Where, with your prior consent, or, if you have not objected (as applicable), we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our /services including information on all our developments.

You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email protected].

Our developments are owned by Essential Living group companies, subject to the above, our email communications may include information about these buildings. The communications will always be sent by us, and you would only give your information to these companies directly, if you enter into a tenancy agreement with them.

If you object to receiving marketing communications from us, we may still send you service communications in connection with your requests and/or to administer your account.

Our blogs

We host a blog on our site https://www.essentialliving.co.uk/blog/. You may be able to comment on these blogs from time to time. Any information that is disclosed in this area becomes public information and you should exercise caution when using the comment feature and avoid posting any personal information.

Who we give your information to

We may give your information to:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this Notice.
• Selected third parties which may include:
• Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. The reason for this includes supporting the services we offer through the site in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
• Advertising networks that require data to select and serve relevant adverts to you and others. We work with third parties to deliver our advertising to you. These third parties may sometimes serve their own cookies on our site, which collect information which helps deliver our adverts to you online. We also work with third parties to share pseudonymised data which also is used to deliver advertisements to you. This helps us and the third parties which we work with track the effectiveness of online campaigns and helps inform advertising networks of target audiences. Please see out cookies and custom audience section below for further information.
• Analytics providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this Notice (this will not identify you as an individual).
• Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
• Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.

We will disclose your personal information to third parties:

• In the event 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 subject to the terms of this Notice.
• If Essential Living Management Limited 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 terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Essential Living Management Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Why we store your information

We store your information where we are legally required to do so and in order to:

• Enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
• Facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

How long we keep your information

We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

We may also retain your information where we are legally required or otherwise permitted to.

How we protect your information

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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.

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 done so at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Child safety

Protecting the safety of children when they use the Internet is important to us.

The website is intended for use only by persons who are at least 18 years of age.

By using the website, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using this website or sending us personal information.

Your Rights

You have the right under certain circumstances to:

• Be provided with a copy of your personal data held by us.
• Request the rectification or erasure of your personal data held by us.
• Request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example).
• Object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our Promotional Updates and Communications' section of the policy).
• Request that your personal data be moved to a third party.

We collect location data through our use of Google Analytics. You may opt out at any time from allowing further access by us to your location data by updating your Google Analytics settings here.

Your right to withdraw consent

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent, without detriment, at any time by contacting us. You can also change your marketing preferences at any time as described in 'Our Promotional Updates and Communications' section of the policy;

You can also exercise the rights listed above at any time by contacting us at [email protected].

If your request or concern is not satisfactorily resolved by us, you may approach the Information Commissioner as the supervisory authority in the UK who can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

Change to this notice

Any changes we make to our privacy notice in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This Notice was last updated on 07/07/2023.

Contact us

Questions, comments and requests regarding this Notice are welcomed and should be addressed for the attention of:

Data Protection Lead, and issued via email, [email protected].

Or post to:

Essential Living Management Limited

11^th Floor,

33 Cavendish Square,

London,

W1G 0PW

Version Control

Revision Code

Rationale

Deployment Date

Archived Date

T2.V1

New Document

07/07/2023

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