Privacy Policy

Campus Living Villages UK Limited (‘CLV’) is a company registered in England and Wales (company number 06604874) at 6th Floor, One London Wall, London, EC2Y 5EB.

CLV respects your privacy and is committed to protecting your personal data. This Privacy Policy (together with any other documents referred to on it) explains how we collect and use your personal information, in accordance with the General Data Protection Regulation (GDPR).

It applies when you use our website, when you interact with us through social media, email, phone or in person and also when you participate in our competitions or events.

With that in mind, you should consider that this Privacy Policy applies to you if you are a:
• resident;
• prospective resident;
• guarantor;
• prospective guarantor;
• guests of a resident;
• prospective employee;
• business customer;
• supplier or contractor;
• prospective supplier or contractor; or
• website visitor.

It is important that you read this Privacy Policy, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your personal information, so that you are fully aware of how and why we are using it. This privacy notice supplements the other notices and is not intended to override them.

WHO WE ARE

This Privacy Policy applies to Campus Living Villages UK Limited, together with its subsidiaries and associated companies (referred to herein as “CLV”, “we, “us” or “our”). A list of these entities can be found at the end of this Privacy Policy.

These companies make up the “joint data controllers” and decide how your personal information is held and used.

PERSONAL INFORMATION WE HAVE ABOUT YOU AND WHAT WE WILL DO WITH IT

We may ask you to provide us with certain personal information about you. You don’t have to give us any of this information, but if you don’t you may not be able to use our services and you are unlikely to receive the customer experience we want to give you.

We use your information in a number of different ways depending on what that information is. The table below sets out what information we need, what we will do with it and the purpose in detail.

Some or all of these may be applicable to you. Where we believe we have a legitimate interest in processing data we have explained what benefit it will have to CLV.

 

INFORMATION HOW WE USE THAT INFORMATION WHY?
Your name and contact details

 

 

To allow you to register on our resident portal We need this so we can enter into a contract with you and perform our obligations under that contract
To ensure our contract with you is drawn up correctly We need this so we can enter into a contract with you
To send you service messages and information about matters that affect you or your room during your stay at the Village We’ve got to do this so we can perform our contract with you but we also want to provide you with a great service
To let you know about Village Life activities at your Village We want to give you opportunities to meet other residents but also want to give you opportunities to improve your wellbeing where we can
To send you information about our business, new products and services To keep you up to date and to help us grow and improve our business
Fraud prevention and detection To prevent and detect fraud against either CLV or you
To show you CLV adverts as you use the internet So you can see our latest offers
To find out what you, and other customers, like So we can make sure we are giving you what you want, and to stay ahead of the competition
Your date of birth Fraud prevention and detection To prevent and detect fraud against either CLV or you
To know if we need to make any adjustments for you (e.g. if you’re under 18) If you’re under 18 there are some additional things we will need to do to make sure we treat you fairly and stay inside the law, including meeting our Health and Safety obligations
Your gender To make sure we put you in the best room for you To give you the best experience with us possible
You nationality Fraud prevention and detection To prevent and detect fraud against either CLV or you
To determine whether you will be in receipt of student finance To allow us to create payment plans and decide how your rent instalments will need to be structured
Your student ID (or a suitable alternative) To confirm that you are a student You need to be a student to stay at our properties
To be able to provide evidence to your Village’s local council that you are a student We need to apply for an exemption on your behalf so that we don’t have to pay council tax we shouldn’t have to
What University you go to and what course you’re on To confirm that you are a student For commercial and security purposes including for the purpose of gaining council tax exemptions
So that we can contact your University if we need to (we will only do this where we have a legal basis for doing so) For your welfare
So we can identify who is staying in our properties We need to understand demographics so that we can adapt our marketing strategies
So we can allocate you a room We want to ensure you are in the right room
Your photograph To confirm your identity Commercial and security purposes
Information about whether you’re a care leaver or young adult carer So that we can take into account your personal circumstances and are able to point you in the direction of information that may be suitable for you (such as financial support or mental health support) We want you to have a great experience at the Village and want to be able to signpost information which can help with any challenges our residents are facing.
So we can take your personal circumstances into account if we need to recover any amounts due to us We want to treat you fairly if you are having financial difficulties as a result of commitments you have outside of university
Personal information relating to your stay with us (e.g. the date you first move in, the date you’ll be moving out, your room number etc.) So we know where and when you’ll be staying with us To perform our contract with you and for building management purposes
Administration relating to your stay with us We’ve got to do this to perform our contract with you
To know what marketing material will be appropriate for you So you can see our latest offers
Your payment information (your bank account details and payment card information) To take payments and give refunds We’ve got to do this to perform our contract with you
Fraud prevention and detection To prevent and detect fraud against CLV and you
Administration relating to your stay with us We’ve got to do this to perform our contract with you
Accounting data for commercial customers and suppliers To determine what charges are unpaid or paid To fulfil our legal obligations
Fraud prevention and detection To prevent and detect fraud against CLV
Your contact history with us (e.g. what you’ve said to us over the phone, over webchat, in writing, through the portal, via email or on social media) To provide customer service and support We need to do this so that we can perform our contract with you – we want to give the best service we can!
Administration relating to your stay with us We’ve got to do this to perform our contract with you
Fraud prevention and detection To prevent and detect fraud against either CLV or you
To handle any complaints you may have To provide you with the best service possible and to improve our business
To know what information about our new products and services may be of interest to you To keep you up to date and to help us grow our business
To train our staff So that you get the best customer service from us
Information about your phone or laptop (e.g. information you give us when you browse our website, including your IP address and, if you choose to share it with us, your location data and how you use the website) To improve our website To give you the best possible experience
To protect our website To prevent and detect fraud against CLV and you, and to meet the legal obligations we have with respect to looking after your data
Your User ID and password for our resident portal To allow you to register on and use our resident portal We need this so we can enter into a contract with you and perform our obligations under that contract.
CCTV footage of you To safeguard residents, staff and other third parties at our Villages We need to do this to perform our contract with you and as an employer
Electronic door access logs Administration relating to your stay with us We’ve got to do this to perform our contract with you
Fraud prevention and detection To prevent and detect fraud against either CLV or you
For security and to safeguard residents, staff and other third parties at our Villages We need to do this to perform our contract with you and as an employer of our staff
Your responses to surveys, competitions and promotions So we can run the survey, competition or promotion We need to do this to perform our contract with you – and it means you could win!
We use your feedback to improve our business
Health information (such as details of any disability you may have, or any health issues or conditions which we may need to take into account) So we can provide additional support to disabled individuals when required and point you in the direction of information that may be suitable to you/support networks within University We need to do this to comply with our legal obligations and provide you with a safe and comfortable environment to stay
So we can plan evacuations and evacuate disabled residents safely We need to do this to comply with our legal obligations
Welfare and behaviour information (e.g. information about your behaviour whilst residing in the Village (such as being in debt, incidents involving the police, accidents) as well as information about your wellbeing where we are, or someone else is, concerned about you) To safeguard residents, staff and other third parties at our Villages and point you in the direction of information that may be suitable to you/support networks within University We need to do this to perform our contract with you and as an employer of our staff
Personal data related to individuals applying for jobs at CLV To allow us to review and process any applications we receive We need to do this to recruit new employees
Personal data related to business customers To allow us to manage your account administration as well as our working relationship and any contract that is in place We need to do this to perform our contract with you
Personal data related to suppliers/contractors To allow us to manage your account administration as well as our working relationship and any contract that is in place We need to do this to perform our contract with you

 

Aside from information you give us directly; during your time with us, we might gather information about you as a result of our contact with you.

If we receive any sensitive information (such as information about your health) from you which we have not asked for, we will consider that you have provided your explicit consent for us to process this information.

We will only use your personal information for the purposes for which we collected it. However, we may need to use it for another reason. If that is the case and the reason is compatible with the original purpose we will use it without contacting you but, if the purpose is different, we will notify you and will explain the legal basis which allows us to use it.

 

INFORMATION YOU GIVE US ABOUT OTHER PEOPLE

We may ask you to provide information about other people. Before doing so, please make sure that you have asked their permission and that you have shown them this Privacy Policy.

INFORMATION HOW WE USE THAT INFORMATION WHY?
Information about your next of kin (their name and contact details) We will contact the next of kin in the event of an emergency – but only after the legality of this has been considered. See ‘Sharing sensitive information’ To protect your vital interests
If you’re under 18; details about your parent or guardian We will need to get their permission to contract with and communicate with you in some circumstances To comply with our legal obligations
Information about your guarantor (their name and contact details) We will contact the guarantor in the event of non-payment by the resident.

 

Please note that if you (as guarantor) do not pay all monies owed by the resident under their contract CLV may provide  your details to a debt collection agency

To ensure that all debts are paid as per the resident’s contract with us
We will contact the guarantor in the event of any other lack of compliance with the resident’s contract with us To ensure that the resident complies with all of the terms and conditions of their contract

 

INFORMATION OTHER PEOPLE GIVE US ABOUT YOU

When someone makes an application to stay with us on your behalf (such as an agent) or you apply through your university, we will use your personal data in accordance with this policy. We will also contact you to clarify what information has been sent to us and where the information came from.

 

WHO WE SHARE YOUR INFORMATION WITH

We may disclose your personal information about you (that you have given us, that someone else has given us or that we have obtained ourselves) to third parties in the following circumstances:

  • when we legally have to;
  • when we have to perform our contact or, if there is no contract, any obligations as part of our working relationship with you;
  • where we have another legitimate interest in doing so; or
  • to protect the rights, property, or safety of CLV, our customers, or others – including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

We may share information with:

THIRD PARTY WHY WE MAY SHARE YOUR PERSONAL INFORMATION
Your University Where the university requires such information for administrative or pastoral purposes, or for the purpose of safeguarding student welfare

 

Where a contract is in place between us and your university for the provision of accommodation to their students and we need to give them information under that contract
Suppliers and sub-contractors Where we rely on external suppliers in order for us to comply with the terms of your contract with us
Where you have ordered goods and services that must be delivered by someone else.
Where we use other businesses to assist us with the provision of services
To prospective buyers of sellers If we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets)
Your guarantor Where you are in breach of your contract we have the right to involve your guarantor.
Your next of kin Where we feel it is appropriate for us to contact them as a result of an emergency, for example. Please see ‘Sharing sensitive information’
Your Village’s local council Where we are under a legal obligation to disclose information about you.

 

In order to discuss council tax bills we might receive in relation to your accommodation and to seek an exemption on your behalf
Our debt collection agency We use debt collection agencies in order to recollect amounts due to us
Our insurers Where it is in our best interests to involve our insurers in relation to queries and claims
Our auditors, accountants, lawyers and other professional advisors In order to enforce or apply our terms of use and other agreements
Where we ask for support with any complaints or queries
IT service providers We may disclose your personal data to third parties including internet service providers, IT system providers, web application service providers, data back up providers, mail hosting providers, customer management systems, call recording systems, postal package tracking systems, asset tracking systems and those who provide web analytics services to us (including, for example, third parties who analyse our users’ online behaviour in order to improve the way in which we advertise and market goods and services)
Our service providers We may disclose your personal data to third parties who help us provide our services to you such as security companies or ICT infrastructure providers. In particular, we will share your personal data with StarRez Pty Ltd which hosts the online portal through which you apply for student accommodation
Statutory bodies Where we are required to provide information we will do so
Banks, card payment gateways and other financial institutions In addition to needing to process payments we may send your details to credit reference agencies and fraud prevention agencies
Emergency services Where it is appropriate for us to contact them as a result of an emergency and need to provide your personal information to ensure your wellbeing, the wellbeing of others or to protect our interests
Marketing agencies Where we outsource our marketing to you
Other entities within the CLV group and our joint venture partners Sometimes different companies within our group are responsible for different activities and our joint venture partners may require access to information

We may provide third parties with anonymised information and analytics about our customers but we will make sure that you can’t be identified.

 

SHARING SENSITIVE INFORMATION

If we are concerned about the welfare or behaviour of a resident we may share this information with third parties where it is in their vital interest, the public interest, or in accordance with other exceptions permitted under data protection law.

The third parties that we would share this information with, if we do, would usually be:

  • the University of the resident (e.g. the University welfare office);
  • the guarantor of the resident (in the event of non-compliance with their contract – including non-payment of any money due which, dependent upon the circumstances, may be considered by CLV to be a behavioural issue);
  • healthcare professionals such as a local authority mental healthcare team; and
  • the emergency services.

We may share this data without the consent of the individual it relates to, particularly if it would be in the vital interests of the resident or if it is in the public interest.

In highly exceptional circumstances CLV may contact the next of kin (whose details will have been provided by the individual) to share welfare or behavioural information.

CLV will ensure that this information is only shared with third parties after careful consideration of the individual’s rights. Such a decision will be made by a senior member of CLV staff.

 

YOUR INFORMATION AND COUNTRIES OUTSIDE EUROPE

We are an international company with offices in:

  • New Zealand;
  • United States of America; and
  • Australia

We will transfer the personal information we collect about you to these countries (outside the EU/EEA) in order to perform our contract with you.

There is an adequacy decision by the European Commission in respect of New Zealand. This means that New Zealand is deemed to provide an adequate level of protection for your personal information.

The European Commission has also determined that, in respect of the United States of America, there are adequate safeguards in place under the EU-US Privacy Shield. We will only transfer your personal information where we are legally able to do so.

There is not an adequacy decision by the European Commission in respect of Australia. This means that it is not deemed to provide an adequate level of protection for your personal information.

However, we will only ever transfer your personal information to Australia if that transfer is:

  • made with your informed consent;
  • necessary for the performance of a contract between you and CLV or for pre-contractual steps taken at your request;
  • necessary for the performance of a contract made in your interests between CLV and a third party;
  • necessary for important reasons of public interest;
  • necessary for the establishment, exercise or defence of legal claims;
  • necessary to protect your vital interests or those of other persons, where you are physically or legally incapable of giving consent; or
  • made from a register which under UK or EU law is intended to provide information to the public (and which is open to consultation by either the public in general or those able to show a legitimate interest in inspecting the register).

In addition to these transfers, we may also use suppliers or service providers who process data outside of the EU/EEA. If you have made a booking with us via an international third party we may also need to transfer personal data to that third party. In these cases we will ensure that a reasonable level of data protection is established with the recipient before transferring your personal data.

If you require further information about international transfers, you can contact us using the contact details under ‘How to contact us’.

 

YOUR INFORMATION AND COUNTRIES OUTSIDE EUROPE

We may transfer your personal information to countries that are outside the European Economic Area (including to Australia, where CLV’s server is currently located) in order to perform our contract with you or, if there is no contract, to maintain our working relationship with you.

Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection as United Kingdom, although our collection, storage and use of your personal data will continue to be in line with this Privacy Policy and data protection laws.

If any data is transferred outside of the EU to a third party we will ensure that the third party has adequate protections in place.

 

HOW LONG WE WILL KEEP YOUR INFORMATION FOR

We will only keep your information for as long as is necessary to fulfil the purposes we collected it for (including for the purposes of satisfying any legal, accounting or reporting requirements). When we decide how long we should keep it for we consider:

  • the amount, nature and sensitivity of that personal information;
  • the purposes for which we process it;
  • whether we can achieve those purposes through other means; and
  • the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice from you.

 

PROMOTIONS AND OFFERS

If you have said that we can, we may use your personal data to send you marketing communications by post, email, and social media about goods, services and offers.

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ensuring that you do not check the relevant boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the contact details under ‘How to contact us’.

 

YOUR RIGHTS

You have a lot of rights relating to your personal information:

  • The right to be informed about how your personal information is being used (like this Privacy Policy)
  • The right to access the personal information we hold about you (commonly known as a “data subject access request”). Please note that you may have to pay a fee to meet any costs we suffer to provide you with details of the information we hold about you
  • The right to ask us to correct any inaccurate personal information we hold about you
  • The right to ask us to delete your data, stop doing anything with it, or restrict our use of it in some circumstances
  • The right to stop direct marketing messages, and to object to any processing of data we are able to use because we have, or a third party has, a legitimate interest in doing so
  • The right to ask that we transfer elements of your data either to your or another service provider
  • The right to complain to the Information Commissioner’s Office

If you want to exercise your rights, please contact us using the contact details under ‘How to contact us’.

 

COOKIES

We use cookies on our website. Please see our Cookie Policy for further information.

 

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy at any time. We will provide you with a new Privacy Policy when we make any substantial changes. We may also notify you from time to time about the processing of your personal information.

This Privacy Policy has been in effect since 23rd May 2018.

 

HOW TO CONTACT US

If you have any queries about how we collect, store and use your personal information, or if you have any other privacy-related questions, please contact us by any of the following means:
Phone us: +44 (0) 161 667 9800
E-mail us: privacy@clvuk.com
Write to us: 7th Floor Digital World Centre
1 Lowry Plaza, Salford Quays
Manchester
M50 3UB

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 should however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

LIST OF CLV LEGAL ENTITIES THAT THIS PRIVACY POLICY APPLIES TO

The legal entities in the table below represent the ‘joint data controllers’ within the CLV group:

Entity name Supervisory authority and jurisdiction
Campus Living Villages UK Limited ICO
Campus Living Villages (Bedfordshire) UK Limited ICO
Campus Living Villages (Salford) UK Limited ICO
Campus Living Villages (Cranborne) UK Limited ICO
Campus Living Villages (City Portfolio) UK Limited ICO
Campus Living Villages (Sutton Bonington) UK Limited ICO
Campus Living Villages (Goldsmiths) UK Limited ICO
Arlington Student Holdings (No.3) Limited ICO
Signpost Homes Limited ICO
Salford Village Limited ICO
Campus Living Villages (RCM 2) UK LLP ICO
Campus Living Villages (Bournemouth 1) UK Limited ICO