ProperTies Privacy Notice

This notice describes how we collect, store, use and share personal information.

It applies to personal information provided to us, both by you or by others on your behalf. It also explains the rights you may have in relation to the personal information that we hold about you.

1. Who we are:

We are a 'data controller' of the personal information we process. This means that we decide why and how personal information is used.

2. What kinds of personal information can we hold about you?

We may collect and process the following:

information about you – for example name, age, gender, title, date of birth and nationality. We need this information to help us identify you, but also to allow us to contact you, for example, for regulatory or service reporting reasons.
government identifiers – for example identification document information (driving licence, passport) and National Insurance number.
contact information - for example email, address, postcode and phone number.
online information – for example cookies and IP address (your computer’s internet address), if you use our websites.
financial information –bank account details for any payments you make to us or we make to you.
audio or video recordings – for example voice recording when you contact us, or CCTV footage if you visit our offices. Calls may be monitored and recorded for regulatory purposes, such as calls relating to the reception, transmission and execution of investment orders.
contractual information – for example details about your products and benefits.
third party information – where relevant we will have information such as the executor or power of attorney connected to your investment.
written communications – for example emails and letters may be monitored and recorded for regulatory purposes and to ensure we have an accurate record of instructions.

When we collect your information, we’ll let you know if any of it is optional. If it is, we’ll explain why it would be useful to us, and you can decide whether it’s something you’re happy for us to have.

3. How we use your information

3.1. If you are/were a tenant of one of our properties:

managing our properties
ensuring our properties are properly valued, benchmarked and our accountancy requirements are met
insuring our properties
in some of our promotional marketing material

3.2. Processing activities that apply to all the people whose personal information we process:

recording phone calls if you call one of our recorded lines
communicating with you if you are the contact of one of our existing or potential suppliers
monitoring the use of our websites.

4. Where do we get your information from?

Most of the information we receive comes directly from you. We may also get personal information about you from other sources, such as:

‘Third party’ cookies - to collect information on how visitors use our website. Our cookie policy can give you more information on this.
Letting agent – we use letting agents to search for and vet potential tenants. Please refer to their privacy policy for more information.

5. What are the legal grounds for using your personal information?

Data protection gives organisations a number of different conditions to allow us to process your information lawfully.
We’ll only use your personal information when one or more of these conditions has been satisfied. Below you can see how we use your information and the legal grounds for processing this:

Uses of your personal data

Consent

Vulnerability Information

We process your personal data to be able to treat you as a vulnerable customer (if due to personal circumstances you are in a vulnerable position). You may, at your discretion provide us with this type of information on a voluntary basis and based on your consent.

Cookies

On our website we use ‘third party’ cookies that collect information about how visitors use our website. Please see our Cookie Policy or

6. Manage our properties

If you are a tenant at one of our properties, this covers:

Approving and signing tenancy agreements.
Overseeing the activities of our Managing Agent who will collect rent and service charges and appoint maintenance to provide service to you.
Liaising with valuers and accountants.

7. How long do we keep your information for?

We’ll keep your personal information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your relationship with us has ended.

8. What are my rights?

Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer at the contact details provided. We’ll provide a response within 30 days, if not sooner. There’s normally no charge for exercising any of your rights.

Accessing your personal information
You have the right to find out what personal information we hold about you, in many circumstances.

Correcting or adding to your personal information
If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.

Data portability
In some circumstances you can ask us to send an electronic copy of the personal information you have provided to us, either to you or to another organisation.

Objecting to the use of your personal information for legitimate interest
You also have the right to object to any processing done under legitimate interest. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason we may still continue to use your information.

Objecting to direct marketing
You have a specific right to object to our use of your information for direct marketing purposes, which we will always act upon.

Restricting the use of your personal information
If you are uncertain about the accuracy or our use of your information, you can ask us to stop using your information until your query is resolved. We will let you know the outcome before we take any further action in relation to this information.

Right to Erasure
You can ask us to delete your personal information in some circumstances, such as if you no longer invest with us and we do not need to keep your information for legal or regulatory reasons. If we are using consent to process your information and you withdraw it, you can ask us to erase your information.

9. Right to complain to the supervisory authority

If you are unhappy with how we’re using your information, you have the right to complain to the Information Commissioner’s Office. However, we’d encourage you to contact us first, so we can have the opportunity to deal with your concerns.

The United Kingdom’s Information Commissioner’s Office can be contacted by:
Visiting their website www.ico.org.uk
Telephone: 0303 123 1113

Write to: Information Commissioner`s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

10. Changes to the way we use your information

If we want to use your personal information for a new purpose which we haven’t previously told you about, we’ll contact you to explain the new use of your information. We’ll set out why we’re using it and our legal reasons.

11. Changes to our Privacy Policy

Making sure that we keep you up to date with privacy information is a continuous responsibility and we keep this notice under review. We’ll update our notice as changes are required.

12. Contact us about this policy

If you have any questions or comments regarding this privacy notice, or if you’re not happy with the way we use your information, please contact us using the details below.

aspire.complaints@propertiesliving.com

Overview

ProperTies Living Limited (‘we,’ ‘us,’ ‘our’) are committed to protecting the privacy and security of personal data relating to our residents (‘you,’ ‘your’).

This Resident Privacy Notice (‘Notice’) sets out how your personal data is handled by us whether you are a prospective resident, a current resident or a former resident. This Notice outlines how we manage your personal data in accordance with applicable UK data protection laws including the UK GDPR (the 'Data Protection Laws').

Personal data is any information relating to an identified or identifiable natural person (known as a ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This Notice should be read together with your Tenancy Agreement and sets out the following information:

How we collect your personal data
Personal data we collect about you
How we use your personal data
Marketing communications
Who we share your personal data with
Where we transfer and store your personal data
How long we keep your personal data
How we protect your personal data
Your legal rights
Changes to this Notice
How to contact us

Please read this Notice carefully to understand how we handle your personal data.

By Ticking the privacy notice box on our website at www.aspire.propertiesliving.com, you acknowledge that you have read and understood this Notice.

By signing our Tenancy Agreement, you acknowledge that you have read and understood this Notice.

For the purposes of the Data Protection Laws, the data controller is:

ProperTies Living Limited is the managing agent and they will manage all of your personal data. The registered company number is 14949951 and the registered address is 80 Fenchurch Street, London EC3M 4BY.

Please contact us with any queries you may have about this Notice or how we handle your personal data per the 'How to contact us' section below.

How we collect your personal data

When you enquire or register for products or services provided by us we may collect personal data about you from a variety of sources.

Most of the information we collect about you will be provided directly from yourself during your relationship with us however we may obtain information from other sources such as other third parties (e.g. Rightmove and Zoopla).

Personal data we collect about you

When you use our products and services, we will collect personal data from you such as:

your name;
your email addresses;
your telephone numbers;
your date of birth;
your postal address;
your payment details;
copies of your ID (e.g. passport, driving licence, birth certificate, utility bill);
your IP addresses;
proof of funds e.g. , banks statements etc.);
recordings of your phone calls made to our head office.

If you are unable to provide us with relevant information, we may not be able to provide you with access to our products or services.

During our relationship with you, we may ask for additional information from you which is required for us to fulfil the specified service.

How we use your personal data

We have set out below how we use your personal data and our legal basis for doing so.

Where required under Data Protection Laws, we have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interest as the legal basis on which to process your personal data in certain circumstances (as set out above). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest is not overridden by your privacy rights as an individual, and we consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests as we process your personal data only so far as is necessary for such purpose and it can be reasonably expected for us to process your personal data in this way.

Who we share your personal data with

We may share your personal data with organisations who process your personal data on our behalf. The third parties will only process your personal data following our instructions and in accordance with Data Protection Laws.

This includes support services we procure that provide services within the apartment, maisonette or house that you rent as well as in the buildings we manage (e.g. security or concierge services).

These organisations (which may include third party suppliers, agents, sub-contractors, and/or other companies in our group) will only use your personal data to the extent necessary to perform their support functions.

We have set out below a sample list of providers (the list is not exhaustive and may include other providers who aren’t on the sample list) who we may share your personal data with as follows:

Internet Providers
IT suppliers
Security and Concierge services
Maintenance contractors
Lettings agents
Property Management service providers
Ombudsman
Inventory Clerks
Marketing and communication agents
Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.

We have set out below a list of specific named third parties that we work with on a regular basis and to who we may share your personal data with:

Let Ref- Reference and right to rent checks
Tenancy Deposit Scheme (to register your deposit in accordance with the Tenancy Agreement)
FlatFair – Zero Deposit scheme.
Tenancy Deposit Scheme (TDS) Provider
PEX & RealPage to deliver Resident management services to you on our behalf
Nottingham Telecoms (NT) deliver IT and internet services to you. Our IT or third-party IT team will collect personal data including, your name, email IP / MAC address and apartment number.
Inventory Assist – Inventory Services
Elavon - Payment processing provider who provide secure payment processing services. Please note your payment card details are not shared with us by the payment processing provider
Go Cardless – Direct Debit Collection facilitator
Magpie Security – Security and concierge services
Kingsley Furniture – Furniture providers
Solicitors or lawyers to enable us to adhere to the Tenancy Agreement terms.

We may also share your personal data with other third parties:

If we sell or buy any business or assets and we need to provide your personal data to the prospective seller or buyer of such business or assets subject to the terms of this Notice.
If we are under a duty to share your personal data to comply with any legal obligation, or to enforce or apply our supply terms and other agreements with you.
If we are under a duty to protect the rights, property, or safety of Properties Living Limited and the SLR Opco limited with which you sign your Tenancy Agreement.
If we are under a duty to protect the rights, property, or safety of our residents or others.

For the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we transfer and store your personal data

The personal data that we collect from you may be transferred to and stored in countries outside the UK and European Economic Area ('EEA') that may not be subject to laws equivalent to the Data Protection Laws.

To ensure your personal data is protected we will only transfer personal data outside the UK and / or the EEA where appropriate safeguards as required by the Data Protection Laws are in place. For example, where a jurisdiction has not been deemed adequate by the UK government and/or the EU Commission we will put in place appropriate UK or EU Standard Contractual Clauses as required for the transfer.

We may transfer your personal data outside the UK and / or EEA:

To store it.
To enable us to provide services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
Where we are legally required to do so.
To provide information to the owner of the building and its 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 personal data

We will only retain your personal data for as long as is necessary for the purposes for which it was collected and to meet our obligations under The Property Ombudsman Code of Practice and rules set by HMRC. In summary, our retention periods are:

Up to 15 years for tenant complaints
7 years for personal data related to a financial transaction with us (such as a rental payment)
6 years post lease end for Tenancy Agreements and deposit protection information
6 years after the end of our relationship with you for personal data related to our obligations under Anti-Money Laundering regulations
1 year post lease end for right to rent information
6 to 8 weeks for tenant screening information
18 months for all other personal data not covered by one of the above.

How we protect your personal data

We are committed to protecting your personal data and keeping it safe and secure. We have in place appropriate technical and organisational security measures to protect your personal data against any unauthorised or unlawful processing and against any accidental loss, destruction or damage.

We store all your personal data in highly secure software systems and when we share your personal data with third parties we do so in a safe and secure manner.

Your legal rights

Under the Data Protection Laws, you have a number of rights relating to your personal data. The rights available to you depend on our reason for processing your personal data. You have the following rights:

Right to be informed - You have a right to be told how we use your personal data by way of this Notice;
Right of access (known as a 'data subject access request') - You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal data, please contact us using the details in the 'How to contact us' section below;
Right of rectification - Under certain circumstances you have the right to ask us to correct your personal data if you believe your personal data is incorrect;
Right to erasure (known as a 'right to be forgotten') - Under certain circumstances you have the right to ask us to erase your personal data;
Right to restrict processing - Under certain circumstances you have the right to ask us to suspend and/or limit the ways we use your personal data;
Right of data portability – You have the right to have the personal data we hold on you transferred to you or another organisation in a structured, commonly used, machine readable format;
Right to object - You have the right to object to the processing of your personal data where we are relying on our legitimate interest as a legal basis for processing, or where we are using your personal data for direct marketing;
Right to withdraw consent - Where you have given consent to any processing (including marketing) you have the right to withdraw that consent at any time (but this doesn’t affect processing which we have done on that basis prior to you withdrawing consent). Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If we have another legitimate basis for processing information in law, we may still process the same personal data, and we will not require your consent to do so.
Right to complain - We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy and comply with The Property Ombudsman Codes of Practice. If you wish to make a complaint about how we have handled your personal data, in the first instance, please contact us using the details set out in the 'How to contact us' section below. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority (which in the UK is the Information Commissioner's Office).

If you would like to exercise any of your rights, please contact us using the details set out in the 'How to contact us' section below. Please note that certain personal data may be exempt from such access, correction, and deletion requests following applicable data protection laws or other laws and regulations. You will not ordinarily be required to pay a fee to access your personal data (or to exercise any of the other rights), however, where your request is manifestly unfounded or excessive, we may charge a reasonable fee or alternatively, we may refuse to comply with the request.

Please also note that we may ask you for further information to confirm your identity before we provide the information requested.

Changes to this Notice

Any substantive changes we make to this Notice in future (for example, changes that significantly affect your rights or, to the extent we are permitted to do so, significantly change how or why we use personal data) will be communicated by email to Residents who have signed a Tenancy Agreement and have provided us with an email address.

Any changes to this Notice will become effective once sent to you by email.

This Notice was last updated on 6 February 2025.

How to contact us

If you have any questions, comments and/or requests relating to our use of your personal data or this Notice and if you would like to exercise any of your legal rights, please contact us by:

email at data@Propertiesliving.com; or
post addressed to: FAO: Tim Holden, Data Protection Lead, ProperTies Living Limited, 80 Fenchurch Street, London, EC3M 4BY.