PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Kooky collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or request information in relation to any of our properties and/or services. This privacy notice also sets out how we use your personal data when it has been provided to a third party in relation to one of our properties.
We do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
This privacy notice is issued on behalf of Kooky so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data. For further information on the companies in the Group that your personal data is shared with please contact our privacy manager.
Kooky Ltd is responsible for operating this website on behalf of the Group.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the privacy manager using the details set out below.
Full name of legal entity: Kooky Ltd
Email address: firstname.lastname@example.org
Postal address: 44 Great Marlborough St., London, W1F 7JL
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
THE PERSONAL INFORMATION WE COLLECT AND USE
Information collected by us
In the course of your use of the website we collect the following personal information when you provide it to us:
- Identity Data including first name, last name, username or similar identifier;
- Contact Data including email address and telephone numbers;
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Information collected from other sources
We also obtain personal information from other sources as follows:
We receive identity and contact from third party estate agencies and property websites (such as Rightmove and Zoopla) when you register an interest in one of our properties with such third parties.
We receive identity, contact and usage data from any social media platforms you have used to access our website from.
How we use your personal information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- to register you as a new customer;
- to provide you with further information on the property you have expressed an interest in and our other properties in the same or similar developments;
- to add you to our mailing list and provide you with our newsletter; and
- To track the volume of traffic to the various sections of our website.
We rely on the following legal bases when processing your personal data:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are;
- suppressions and managing opting out of communications,
- risk assessment and due diligence;
- profiling monitoring, communications and marketing;
- development and enhancement of products and services; and
- information, system, network and cyber security.
- where it is necessary to comply with a legal obligation; and
- in some circumstances, with your consent.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Where we rely upon consent as a legal basis for processing your personal data, in relation to sending direct marketing communications to you via email or placing marketing cookies on your device, you have the right to withdraw consent to marketing at any time by contacting us.
Who we share your personal information with
Where necessary we will share your personal data with the following third parties;
- Our third party customer relationship management software providers – for the purposes of storing the information you provide us with and managing our relationship with you;
- Our third party marketing services providers – for the purposes of sending our marketing communications to you. We only provide our third party marketing services providers with your name and e-mail address;
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party. Please contact us if you require contact details of the third parties we have shared your information with.
How long we will keep your personal information for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Such anonymised data does not constitute personal data.
TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We will not transfer your personal data outside of the United Kingdom or European Economic Area (EEA).
Under the General Data Protection Regulation you have a number of important rights which may be exercised (save for in certain circumstances). In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please contact our data privacy manager. You will not have to pay a fee to access your personal data unless we feel your request is clearly unfounded or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights)
If you would like to unsubscribe from our email newsletter you can click on the ‘unsubscribe’ button at the bottom of the email or reply “unsubscribe” to the email. It may take up to 10 days for this to take place.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
EXPERIAN RENTAL EXCHANGE
If you choose to opt-in to the service, not only will we be able to work with you more closely to manage your tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:
• assess and manage any new tenancy agreements you may enter into;
• assess your financial standing to provide you with suitable products and services;
• manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
• contact you in relation to any accounts you may have and recovering debts that you may owe;
• verifying your identity, age and address, to help other organisations make decisions about the services they offer;
• help to prevent crime, fraud and money laundering;
• screen marketing offers to make sure they are appropriate to your circumstances;
• for Experian to undertake statistical analysis, analytics and profiling,
• and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).
We will continue to exchange information about you with Experian while you have a relationship with us and inform Experian when your tenancy has ended. Experian will hold your rental data for the time limits explained in CRAIN (section 7). Rental data falls into the Identifiers (e.g. your name, address, date of birth) and financial account categories (i.e. tenancy account, rental payment information).
We and Experian will ensure that your information is treated in accordance with UK data protection law, so you can have peace of mind that it will be kept secure and confidential and your information will not be used for prospect marketing purposes.
CHANGES TO THIS PRIVACY NOTICE
We may change this privacy notice from time to time.