Privacy and Cookies Policy

1. Important information and who we are

Purpose of this Privacy and Cookies Policy

This Privacy and Cookies Policy aims to give you information on how we collect and process your personal data as part of our business operations, including when we provide services to you, if you are interested in a property, through your use of this website, including any data you may provide through this website when you register your interest in our student accommodation or request any help. We may also be provided your personal data by our tenants and prospective tenants (e.g. where you agree to act as a guarantor or where you are an emergency contact).

It is important that you read this Privacy and Cookies Policy together with any other privacy policy or fair processing policy 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 and Cookies Policy supplements other notices and privacy policies and is not intended to override them.

Controller

Now Student Living Limited is a data controller, and is responsible for deciding how we hold and use personal information about you.

Separate “Operational Companies” operate different buildings for accommodation. If you are a tenant, prospective tenant (or you are connected a person such as a parent, guardian or guarantor) then the relevant Operational Company will also be a data controller in relation to your tenancy or prospective tenancy. For more information on our Operational Companies, please see section 11 below.

Contact details

If you have any questions about this Privacy and Cookies Policy or our privacy practices, you can contact us in the following ways:

Email address: hello@nowstudents.co.uk

Postal address: 1st Floor Gallery Court, 28 Arcadia Ave, London, United Kingdom, N3 2FG

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

Changes to the Privacy and Cookies Policy and your duty to inform us of changes

We keep our Privacy and Cookies Policy under regular review.

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.

Third-party links

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 policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth & age, gender, university course information, property preferences, identification documentation and Right to Reside information.
• Contact Data includes email address and telephone numbers.
• Financial Data includes payment plans, bank account and payment card details.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Accommodation Data includes the data collected in relation to when we provide accommodation to you (under a tenancy agreement or otherwise) or someone you act for (e.g. if you are a parent or guardian), such as: housing needs (including whether you have a disability), who you wish to live with, household information, change of circumstance details, details related to your contract with us, funding information (including details of any guarantor), emergency contacts, any information about complaints, credit checks and other information that you provide to us in conversation or correspondence.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• CCTV Data includes footage from CCTV cameras around our building for the purposes of preventing and detecting crime.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookies Policy.

Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We may in rare circumstances process Special Categories of personal data about you if it is necessary to do so, e.g. if you have a health condition which requires adjustments to be made to your accommodation. Where we process Special Categories of Personal Data, we will do so with your consent.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information about our accommodation).

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our publications;
• request marketing to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the section of this Privacy and Cookies Policy on cookies for further details.
• Third parties or publicly available sources. We may receive personal data about you from third parties and publicly available sources.

4. How we use your personal data

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 more than one ground has been set out in the table below.
 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a tenant or prospective tenant	(a) Identity (b) Contact	Performance of a contract with you
To process and provide you with accommodation, which will include: (a) Resolving any issues you may have (b) Managing payments, fees and charges (c) Collecting and recovering money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy and Cookies Policy (b) Asking you to leave a review or take part in a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to better understand our customers’ needs)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To ensure the physical security and safety of tenants and visitors to our offices or premises	(a) CCTV Data	Necessary for our legitimate interests (to ensure the safety of people and property)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to withdraw consent to marketing at any time by contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Accommodation Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

Now Student Living Limited and the relevant Operational Company may share your personal data for the purposes set out in this Privacy and Cookies Policy (including when one entity provides services to the other).

Additionally, your personal data may be shared with the parties set out below for the purposes set out in the ‘Purposes for which we will use your personal data’ section above.

These third parties include:

• your next-of-kin in the event of an emergency;
• companies within our corporate group;
• our suppliers, which may include IT providers, building managers, tradesmen and site security;
• providers who collect information on our behalf, including as necessary to operate features of our website, such as cloud based log aggregators, customer satisfaction surveys, as well as analytics, performance, tracking, and advertising partners;
• professional advisers including consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance accounting and other services;
• our trusted business partners who we work with;
• HM Revenue & Customs, regulators and other authorities based the UK who require reporting of processing activities in certain circumstances; and
• third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy and Cookie Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
 

Cookie Title Cookie Name	Purpose	More information
Google Analytics _ga	This is a performance cookie which enables us to distinguish users.	https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google Analytics _gid	This is a performance cookie which enables us to distinguish users.
Google Analytics _ga_#	This is a performance cookie which enables us to persist a session state.

 

You can choose which analytical, functionality and targeting cookies we can set by selecting from the options on the Cookiebot popup on our website.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

11. Operational Companies

Company name	Registered office address	Company number	Residence name
Arrow Cardiff Management Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	10723597	West Wing
Arrow Exeter Management Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	10627359	The Depot
Base Glasgow Opco Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	11008974	The Base
MREF IV Birmingham Operations Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	11410897	Toybox
MREF III Runnymede Operations Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	10409665	Hox Park
Arrow Leonardo Management Limited	C/O Alter Domus (UK) Limited, 10th floor, 30 St Mary Axe, London, EC3A 8BF	13547957	Leonardo
EG Canterbury 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	12038923	Alma Court
EG Bath 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11090717	Avon Studios
EG Sheff 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11094171	Bailey Fields
EG Oxford 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11090701	Between Towns Court
EG Aberdeen 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11090607	Caledon Court
EG Newcastle 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11090685	Market Street
EG Bournemouth 1 Student Limited	125 London Wall, 6th Floor, London, England, EC2Y 5AS	11090672	Oxford Point
Blackhall S.à r.l.	14-16, Avenue Pasteur, L-2310, Luxembourg	B264958	The P&V
Cork S.à r.l.	14-16, Avenue Pasteur, L-2310, Luxembourg	B264948	Cork Street
Fairgreen S.à r.l.	14-16, Avenue Pasteur, L-2310, Luxembourg	B264950	Galway Central