Data protection privacy notice - Third Parties

Data protection privacy notice - Third Parties

Dated 23 March 2021

This privacy notice is made on behalf of Romulus (as defined as and as set out below). It explains what personal data (information) that Romulus ( we , our or us also, for short) may hold about you, how we collect it, and how we use and may share that information. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

1. Who we are and who collects the information

Romulus Wimbledon Limited, also called Romulus is a company incorporated in England under company number 13068908 and is the controller and responsible for your personal data. Our registered office is at Sandford House, 10 Maynard Close, London, SW6 2DB.

Our contact details are:

Full Name: Romulus Wimbledon Limited

Privacy Manager: Data Protection Manager

Email Address: romulus@romulusuk.com

Postal Address: Sandford House, 10 Maynard Close, London, SW6 2DB

ICO Ref number: ZB022464

At any time, you have the right to make a complaint to the Information Commissioners office ( ICO ) whose email address is www.ico.org.uk although, we would of course always appreciate the chance to deal with your concern before an approach is made to the ICO in which case, please use the contact details above.

2. The data we collect about you

The table set out below in section 5 summarises the information we collect and hold, how and why we do so, how we use it and with whom it may be shared.

Personal data means generally any information from which a living person can be identified or is identifiable, but does not include data, where their identity has been removed (anonymised data). We may collect, use, share and store the following personal data:

• Identity Data this includes title, first and last name, marital status, date of birth and gender.
• Contact Data this includes billing and delivery address, email address and telephone numbers.
• Financial Data this includes bank account and may, in certain circumstances, include payment card details
• Transaction Data this includes details about payment to and from you and, may, in certain circumstances, include other details of products and services that you have purchased from us.
• Technical Data this includes internet protocol ( IP ) address, login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform and other technology on the device if you use to access our website.
• Profile Data may includes your username and password, purchase orders made by you, and your interest and preferences.
• Usage Data this includes information about how you use our website, properties and services.
• Marketing and Communications data which includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any sensitive personal (or special category) data ( special category data ) about you; special category data includes details of your race, ethnicity, religious or philosophical belief, sex, sexual orientation, political opinions, trade union memberships, information about your health and genetic combine metric data unless you disclose it to us or where it is necessary for us to process it, either to comply with a legal obligation imposed on us or allow us to establish, exercise or defend legal claims or otherwise where permitted by applicable law. Neither do we collect or share any information about criminal convictions and offences unless it is necessary for the prevention and/or detection of crime and we are permitted to do so under applicable law.

We seek to ensure that our information collection and processing is always proportionate. If we are required to change this privacy notice, updated versions will be available on our website and we may let you know via email with a link to the updated privacy policy and/or reasonably prominent notice on our website, together with a summary of any material changes.

3. If you fail to provide your personal data

If we need to collect personal data to be able to fulfil a contract that we have with you and you fail to provide that data when requested, we may not be able to perform that contract. In that case we may have to cancel the products or service that you have ordered but we will notify you of this at the time.

4. How we collect your personal data

We will collect your personal data in a course of entering into a contract with you (whether that is a tenancy agreement, or for the provision of goods or services), where you may apply for the purposes of seeking or enquire about a tenancy, where or undertaking seeking a reference and/or where we may carry out credit checks based on such personal data. Where we wish to carry out any financial credit checks, we will customarily seek your prior written consent before so doing, other than where we are permitted to do so under applicable law. We collect the personal information that you provide to us which may include you given us your Identity, Contact and Financial Data by filling in forms, a contract or by corresponding with us by post, phone, email or otherwise. This includes personal data that you provide when you enquire about a tenancy or service or you supply us with information regarding products or request marketing material to be sent to you;

As you interact with our website, we may automatically collect technical data about your equipment, browsing, actions and patterns. We collect this personal data by using cookies and other similar technologies of which please see our cookies policy. When you access our website you can set your website to disallow cookies.

We may also receive personal data about you from various third parties and public sources such as Companies House, HMRC, Credit Reference Agencies.

5. How we use your personal data

We will only use your personal data when the law allows us to do so which will commonly include:

• When we need to perform a contract between you and us (such as a tenancy agreement or ordering goods from you).
• Where we have a necessary legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where it may be necessary to protect your vital interests (e.g. emergency contact information and/or health and safety precautions and procedures).
• Where we need to comply with legal or regulatory obligations.
• We do not generally rely on consent as a legal basis of processing your personal data except where you are an individual and, we wish to ask for your consent for us to send email marketing and communications to you of which you will have the right to opt out from receiving such communications at any time by contacting us on the details above or by clicking on the unsubscribe link.

Purpose/Activities

Type of Data

Lawful Basis for Processing

To register you as a new tenant or supplier.

Identity

Contact

Performance of a contract with you.

To process any application for a tenancy and/or carry out credit reference checks against you, process and collect rental payments in respect of your tenancy to include managing payments, fees and charges and collecting and recovering monies owed to us.

Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of a contract with you.

Necessary for our legitimate interest (to recover debts due to us).

To manage our relationship with you which will include:

• a) Telling you about changes to our terms or privacy policy.
• b) Asking you to leave a review
• c) liaising with utilities provider before, during and after the term of a tenancy (and assisting such providers and/or their agencies with debt collection)

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you

Necessary to comply with legal obligations

Necessary for our legitimate interests (to keep our records updated and to study a pattern of our need for products/services).

Purpose to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Identity

Contact

Technical

Necessary for our legitimate interest for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business re-organisational group restructuring exercise.

Necessary to comply with legal obligations.

To deliver relevant website content and advertisements and measure or understand the

Identity

Contact

Necessary for our legitimate interest (to study how our client use our products and services, to