Privacy Policy

1 What is this Notice?

1.1 We take our privacy and data protection responsibilities seriously. This privacy notice (Notice) sets out how we will gather, use and share personal information. If you would like to receive this information in an alternative format such as in hard copy large print or braille, please let us know.

1.2 In this Notice, reference to “you” or “your” means you as:

(a) a tenant, prospective tenant or former tenant of one of the properties in the Anaconda Cut development;
(b) a visitor or user of our website and online facilities at www.anaconda-cut.com (Website); or
(c) a supplier or business contact of ours.

2 Who are we?

2.1 We are Greengate Opco Limited and we are classified as the “controller” of the personal data that we collect and use about you in our role as the management company for the Anaconda Cut development and as the owner of the Website. We may share information with Greengate Sarl, who are the landlord of the properties in the Anaconda Cut development, and with our wider corporate group.

2.2 If you have any queries about this Notice or how we use your data, or to exercise any of your data rights, you can contact us by:

• Letter: Anaconda Cut, 100 Greengate, Manchester, M3 7NG
• Phone: +44 (0)161 511 0342
• Email: info@anaconda-cut.com

3 What kinds of personal data do we use?

3.1 We use personal data that you provide to us as part of any enquiry or tenancy application, such as:

(a) personal and/or professional contact details such as name, title, addresses, telephone numbers, and personal email addresses;
(b) passport details and date of birth;
(c) gender;
(d) marital status, number and age of dependants;
(e) next of kin and emergency contact information;
(f) bank account details, financial history, credit history, CCJs against you;
(g) salary, National Insurance number;
(h) employment status, visa or other proof of right to reside in the UK, and employer reference;
(i) location of employment or workplace;
(j) previous tenancy details and landlord reference; and
(k) educational details if you are a student and student card.

3.2 When you use the Website, we may also collect:

(a) technical data, such as IP addresses, login data (where you have an online residents account), 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 our Website;
(b) profile data, including information generated from your online residents account (if applicable to you); and
(c) information about your preferences in receiving marketing or similar communications from us.
Some of this information will be collected from the use of cookies on our Website. Please see paragraph 12 below for further information about how we use cookies.

3.3 We may also need to conduct credit checks against you to assess whether or not you can afford to rent one of our properties. This may involve us processing personal data about you that is provided to us by credit reference agencies (CRAs). More information about this is set out in paragraph 10 below.

3.4 We also have CCTV installed in the common areas of the Anaconda Cut development, which you may be captured on. There are signs throughout the development where CCTV is used. In addition, where you use a key fob to enter and exit the development, we will keep an electronic record of this.

3.5 We may 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.

4 How do we use your personal data?

4.1 We may use your personal information for the following purposes:

(a) to assess your suitability and decide about your tenancy application;
(b) to determine the terms on which you rent from us;
(c) to check you are legally entitled to reside in the UK to comply with UK legislation;
(d) to allow us to run checks for identification and creditworthiness, whether via CRAs or checking the Electoral Register and other databases which contain publicly available information about County Court Judgements, bankruptcy and repossessions;
(e) receiving your rent and deposit;
(f) administering the contract we have entered into with you;
(g) business management and planning, including accounting and auditing;
(h) making decisions about you continuing as a tenant when your tenancy expires;
(i) making arrangements for the termination of your tenancy;
(j) dealing with legal disputes involving you;
(k) to allow us to ask for your feedback, assess your satisfaction and to improve our overall operations;
(l) to allow us to detect fraud and crime;
(m) to ensure the security of the Anaconda Cut development;
(n) to validate your information to check that the data we hold is accurate, consistent and up to date;
(o) to comply with any legal or regulatory obligations to which we are subject; and
(p) to conduct data analytics studies to review and better understand tenancy retention and attrition rates.

4.2 When you visit our Website, we use your information to:

(a) provide you with services via your online residents account (if applicable to you);
(b) administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and
(c) use data analytics to improve our Website, services, marketing, and user experiences.

4.3 If you are a supplier or business contact, then we use your personal information as necessary in the performance of our contract with you or your employer and to maintain our professional relationship with you or your employer.

5 What is our legal basis for using your personal data?

5.1 We will only use your personal data where it is permitted by law and where:

(a) we need to use your personal data to perform a contract with you (such as your tenancy agreement);
(b) we need to use your personal data to comply with our legal or regulatory obligations (such as our obligation to verify your identity before contracting with you);
(c) you have given us consent to use your personal data. If consent is needed we will ask for this from your separately; and
(d) it is in our legitimate business interests or the legitimate business interests of a third party we work with to use your personal data for specified purpose, and there is no disadvantage to you or risk to your personal data.

5.2 If you do not provide us with the personal data we request from you, or if you do not allow us to process your personal data that we may obtain from other sources (such as CRAs), we may not be able to offer you a tenancy, service your property, or continue to administer the tenancy that you have with us.

6 Who do we share your personal information with?

6.1 As part of using our services, we will share your personal information with:

(a) other members of our corporate group, for example your information may be held on a central database which is accessible by other members of our corporate group;
(b) our service providers who process and store data on our behalf (such as our IT service providers);
(c) our professional advisers;
(d) our insurers;
(e) any guarantor to your agreement with us;
(f) CRAs;
(g) crime and fraud prevention agencies;
(h) law enforcement, taxation and legal authorities (which may include the police, HMRC and the Financial Conduct Authority);
(i) claims handling agencies; and
(j) debt recovery agencies.

6.2 We may also share your personal information with third parties in the event that:

(a) our business or substantially all of its assets are acquired by a third party;
(b) if we are under a duty to disclosure or share your personal information;
(c) in order to comply with any legal or regulatory obligation;
(d) in order to enforce or apply any contract with you (or the business you represent); or
(e) to protect our rights, property, or the safety of our employees, customers or others.

7 How long will we keep your personal data for?

7.1 We keep your personal data for as long as we need to for the purposes we have set out above. Usually, we will retain your data for seven (7) years after the termination of our contract with us as may be required by law, unless there is an exceptional business purpose in which this time period needs to be extended. If you would like to see a copy of our retention policy, please contact us.

7.2 CCTV footage and data access records generated from use of key fobs will only be retained for a period of 90 days.

7.3 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.

8 How will we keep your personal data secure?

We will treat all of your personal data as confidential and we will take all reasonable steps to keep your personal data secure once it has been inputted or transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information. Please note that we cannot guarantee the security of any data you disclose to us online. There are inherent security risks of providing information and dealing online, which, while we do our best to prevent these risks arising, we cannot 100% ensure the security of your information. If you would like more information about the security measures we use to protect your data, please contact us.

9 Will we transfer your personal information outside of the UK?

9.1 In certain limited situations, we may transfer your personal information outside of the UK. For example, our parent company and other companies in our corporate group are based outside of the UK, and information may be shared with them. Information may also be shared internationally in the event of a sale of the development to a third party based overseas.

9.2 Where we do transfer personal data overseas, we take appropriate steps to ensure that any transfer is subject to adequate measures to ensure the protection of your data. Please contact us if you would like further information about this.

10 What do credit reference and fraud prevention agencies do with your personal information?

10.1 When you make a tenancy application, in order to process your application we will perform credit and identity checks on you with one or more CRAs. We may also make periodic searches at CRAs to manage your tenancy with us.

10.2 To do this, we will supply your personal data to CRAs and they will give us information about you. This will include information from your application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

10.3 We will use this information to:

(a) assess your creditworthiness and whether you can afford the tenancy;
(b) verify the accuracy of the data you have provided to us;
(c) prevent criminal activity, fraud and money laundering;
(d) manage your tenancy;
(e) trace and recover debts; and
(f) ensure any offers provided to you are appropriate to your circumstances.

10.4 We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your payment history with us. If you are not able to meet your regular rent payment to us, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

10.5 When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

10.6 If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

10.7 The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at http://www.experian.co.uk/crain/index.html.

11 What are your privacy rights?

11.1 Data protection laws give you a number of rights as set out below. If you would like is exercise any of your rights, please contact us in writing.

• Access: you may request access to a copy of your personal information.
• Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
• Rectification: you may ask us to rectify any inaccurate information we hold about you.
• Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
• Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
• Object: you may object to our processing of your personal information.
• Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

11.2 If you are not happy with the way in which we process your personal data, or the way in which we handle any request by you to exercise your privacy rights, you may make a compliant to the ICO by visiting their website at https://ico.org.uk/concerns/ or on 0303 123 1113.

12 Cookies on our Website

12.1 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 Website.

12.2 A cookies is a small file of letters and number 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.

12.3 We use the following types of cookies:

(a) 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.
(b) 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 help us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies: These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
(d) 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.

12.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including Strictly Necessary cookies) you may not be able to access all or parts of our Website.

13 Changes to this Notice

We may modify this Notice from time to time, so please review it regularly. We will let you know if we make any material changes to this Notice by means of a notice on our website homepage or, if appropriate, by contacting you directly.