1. Who we are and what this notice covers

This Website Privacy Notice (the “Notice”) explains how Essential Living Management Limited (“we”, “us”, “our”) collects and uses personal data when you use our websites at www.essentialliving.co.uk and www.homequarters.co.uk, or otherwise interact with us in connection with the Essential Living and HomeQuarters brands (together, the “websites”). Both brands are operated by the same company, and Essential Living Management Limited is the data controller for the personal data described in this Notice for the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018, as amended, including by the Data (Use and Access) Act 2025).

This Notice should be read together with the Terms of Use and the Cookie Policy published on each website. If you enter into a tenancy agreement with us or a company in our group, the processing of your data as a resident is described in our separate Resident Privacy Notice, which we will provide to you and which is available on our websites.

Because Essential Living and HomeQuarters are operated by the same company, information you provide through either website may be held in shared systems (including our customer relationship management (CRM) platform) and used across both brands for the purposes described in this Notice. Your marketing preferences are always respected on a per-brand basis, as explained in section 5.

2. How to contact us

Questions, comments and requests regarding this Notice, and any requests to exercise your rights, should be addressed to our Data Protection Lead:

• By email: [email protected]
• By post: Data Protection Lead, Essential Living Management Limited, 11th Floor, 33 Cavendish Square, London, W1G 0PW

3. Information we collect about you

3.1 Information you give us

This is information you give us directly when you interact with us: when you fill in forms on our websites, request a viewing, submit an enquiry, book an apartment, start a live chat, correspond with us by phone, email or otherwise, or report a problem with a website. It may include:

• your name
• postal address
• email address and phone number
• details of the properties you are interested in, viewings requested or booked, and your property requirements
• details provided in correspondence with us (by phone, email, live chat or otherwise)
• if you apply to rent a home and proceed to referencing: nationality, immigration/visa status, and financial information such as income and employment details (see section 6)
• employment details, if you send us a CV or other career information in connection with a job vacancy or a general enquiry about working with us

3.2 Information we collect automatically

Each time you visit one of our websites we automatically collect technical information and information about your visit, subject to your cookie choices where consent is required. This includes: the Internet protocol (IP) address used to connect your device to the internet; browser type and version; time zone setting; browser plug-in types and versions; operating system and platform; the full Uniform Resource Locators (URL) and clickstream to, through and from our site (including date and time); properties you viewed or searched for; page response times and 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 or social media handle used to contact our customer service team.

3.3 Location data

With your consent (given through the cookie banner on the relevant website), we collect information about your approximate location, for example the coordinates of your location, a look-up of your country by reference to your IP address, or a device advertising identifier (such as Apple’s IFA or the Android ID). We use this to deliver content, advertising or other services that depend on knowing where you are, and to recognise your browser or device when you return to a website. You can withdraw your consent at any time through the cookie settings on the relevant website. More information is available in each website’s Cookie Policy.

3.4 Information we receive from other sources

We may receive information about you from other sources, including:

• the other websites, apps or services we operate under either brand — information you provide through one brand may be combined with information collected through the other, as described in section 1
• tenant referencing, right to rent and fraud prevention providers, if you apply to rent a home (see section 6)
• business partners, sub-contractors, payment providers, advertising networks, analytics providers and search information providers (such as Google), and our marketing and CRM platform provider (HubSpot)

3.5 If you visit our buildings

If you attend a viewing or otherwise visit one of our residential buildings, please note that internal and external CCTV operates at each building for the safety and security of residents, staff and visitors, the protection of property, and the prevention and detection of crime. Footage is retained for up to 31 days unless preserved in connection with an incident or legal matter. Visitors and contractors may also be asked to sign in or show identification. Signage is displayed at building entrances, and full details are set out in our Resident Privacy Notice, available on our websites.

4. How we use your information and our lawful bases

UK data protection law requires us to have a lawful basis for each use of your personal data. The table below sets out the purposes for which we use your data and the lawful basis we rely on for each. Where we rely on legitimate interests, we have carried out a balancing assessment to satisfy ourselves that our interests are not overridden by your interests, rights and freedoms; you can contact us for more information about these assessments, and you have the right to object as described in section 13.

Without certain information we may not be able to provide the services you have requested — for example, we cannot arrange a viewing without contact details, and we cannot progress a tenancy application without the information needed for referencing and right to rent checks.

5. Marketing communications

We will send you marketing emails about our developments and services in one of two situations:

• where you have given us your consent (for example, by ticking a box when submitting an enquiry); or
• where you have made an enquiry about, or taken, our services, we may send you marketing about our own similar services under the “soft opt-in” rules, provided you were given a clear opportunity to opt out when we collected your details and in every message since.

Essential Living and HomeQuarters are separate brands operated by the same company. We treat your marketing preferences separately for each brand: opting in to (or out of) one brand’s communications does not change your preferences for the other. Our developments are owned by Essential Living group companies, and our communications may include information about those buildings; the communications will always be sent by us.

You can opt out of marketing at any time by using the “unsubscribe” link in any marketing email or by contacting us using the details in section 2, without any detriment to you. If you opt out of marketing, we may still send you service communications connected with your requests or your account.

6. Tenant referencing, right to rent and fraud prevention

If you apply to rent a home with us, we work with specialist providers to process your application, verify your identity, carry out right to rent checks required by law, assess affordability and rental history, and detect and prevent fraud.

We may update the providers we work with from time to time; an up-to-date list can be provided upon request. Some of these providers act as our processor, acting only on our instructions. Others — in particular referencing and fraud prevention providers — act as independent controllers of your personal data for parts of their work, such as maintaining fraud prevention records, and their own privacy notices (available on their websites) explain how they use your data.

Referencing may involve checks against fraud prevention databases and information from credit reference sources. Where a referencing provider uses automated processing to help assess an application, a decision to decline an application will not be made solely by automated means without human review, unless we tell you otherwise at the time and provide you with the safeguards required by law, including the right to obtain human intervention, to express your point of view and to contest the decision.

7. Our use of artificial intelligence

Like many businesses, our staff use enterprise-grade artificial intelligence (AI) tools to support everyday work such as drafting documents and correspondence, summarising information and answering general questions. We only permit the use of AI tools with which we hold enterprise agreements, under contracts that prohibit the provider from using our data to train their models. Our internal policies restrict what may be entered into these tools, and personal data may only be processed in them incidentally and under the same safeguards that apply to our other IT systems.

We do not use AI to make decisions that produce legal or similarly significant effects about you, such as whether to accept a tenancy application. If that ever changes, we will update this Notice first and provide the information and safeguards required by law.

8. Who we share your information with

We share your personal data with:

• members of our corporate group (our subsidiaries, our ultimate holding company and its subsidiaries) who support our processing of personal data under this Notice, including the group companies that own our developments;
• service providers who process personal data on our behalf and on our instructions, including website and data hosting providers, our CRM and marketing platform (HubSpot), providers who help distribute our communications and manage marketing lists, live chat providers, feedback and survey providers, and IT support providers;
• tenant referencing, right to rent and fraud prevention providers, as described in section 6;
• analytics providers (such as Google) that help us improve and optimise our websites, subject to your cookie choices;
• advertising networks and partners, including through pseudonymised audience matching, subject to your cookie choices — these partners may set their own cookies as described in each website’s Cookie Policy;
• payment processing providers, who provide secure payment processing services (your full payment card details are not shared with us by the provider);
• prospective sellers or buyers of any business or assets, if we sell or buy any business or assets, or if Essential Living Management Limited or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets, subject to the terms of this Notice; and
• courts, regulators, law enforcement and other third parties where we are under a duty to disclose or share your personal data to comply with a legal obligation, to enforce or apply our terms and other agreements, 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 fraud protection, credit risk reduction and the prevention of cybercrime.

9. Where we store your information and international transfers

Your personal data is stored on secure servers operated by us or our service providers. Some of our service providers (for example, our CRM/marketing platform and analytics providers) are based in, or store data in, countries outside the UK, including the United States.

Where your personal data is transferred outside the UK, we ensure it is protected by appropriate safeguards recognised under UK data protection law. Depending on the provider, this is one or more of: a UK adequacy decision (including the UK–US Data Bridge for certified US organisations); the UK International Data Transfer Agreement (IDTA); or the UK Addendum to the EU Standard Contractual Clauses, together with any additional measures needed. You can contact us using the details in section 2 for more information about the safeguards that apply to a particular transfer.

10. How long we keep your information

We keep personal data only for as long as we need it for the purposes described in this Notice, and then delete or anonymise it. Our standard retention periods are:

We may retain data for longer where the law requires or permits it, or where it is needed to establish, exercise or defend legal claims. We may also retain aggregated, anonymised information (from which you cannot be identified) for research and service improvement purposes.

11. How we protect your information

We apply technical and organisational measures designed to protect your personal data, informed by recognised standards including guidance from the National Cyber Security Centre. These include encryption of data in transit (payment transactions are encrypted using TLS/SSL technology), access controls, and strict procedures and security features designed to prevent unauthorised access. Where we have given you (or you have chosen) a password that enables you to access parts of a website, you are responsible for keeping that password confidential and should not share it with anyone.

The transmission of information via the internet is never completely secure, and while we work hard to protect your personal data, we cannot guarantee the security of data transmitted to our websites. Our websites may contain links to external sites; we are not responsible for the privacy practices or content of those sites, and we encourage you to read their privacy notices.

12. Children

Our websites and services are intended for use only by persons aged 18 or over, and we do not knowingly collect personal data from anyone under 18 through them. If you believe a person under 18 has provided us with personal data, please contact us using the details in section 2 and we will delete it.

13. Your rights

Under UK data protection law you have the right, in certain circumstances, to:

• be informed about how we use your data (which is the purpose of this Notice)
• access a copy of the personal data we hold about you
• have inaccurate personal data rectified, and incomplete data completed
• have your personal data erased
• restrict the processing of your personal data (for example, while we verify or investigate a concern you have raised)
• object to processing based on legitimate interests, and to object at any time to the use of your data for direct marketing, in which case we will stop
• receive the personal data you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller (data portability)
• not be subject to a decision based solely on automated processing which produces legal or similarly significant effects on you, except where the law allows and appropriate safeguards apply (see section 6)
• withdraw your consent at any time and without detriment, where our processing is based on consent

To exercise any of these rights, contact us using the details in section 2. We will respond within the timescales required by law and will not charge a fee unless the law allows it. If you have a concern or complaint about how we handle your personal data, please raise it with us first and we will investigate and respond. If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority, at ico.org.uk or on 0303 123 1113.

14. Cookies and similar technologies

Each website has its own Cookie Policy explaining the cookies and similar technologies used on that site, including analytics and advertising cookies and how to manage your choices. You can change your cookie preferences at any time through the cookie settings tool on the relevant website.

15. Changes to this Notice

Any changes we make to this Notice will be posted on this page on both websites. Where we make substantive changes — including any change to how we combine or use data across the Essential Living and HomeQuarters brands — we will notify you by email where we hold a current email address for you, before the change takes effect where practicable.

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