Last updated – 21/12/2017

Pure Student Living Limited (“PSL”, “we”, “us” and “our”) are committed to protecting and respecting your privacy and we process your personal data in accordance with this Privacy and Cookies Policy (the “Policy”) as a data controller for the purpose of the Data Protection Act 1998 (the “Act”).

This Policy sets out the basis on which we process personal data about you, either when you use our website: www.purestudentliving.com (the “Website”) or which is obtained directly from you or from third parties, including CRM Students Limited (which also processes your personal data as a data controller, in accordance with their own privacy policy: http://www.crm-students.com/privacy/), in connection with your tenancy or enquiry into any tenancy. In addition to CRM Students Limited, your personal data may also be shared with our group company, which will process your personal data as a data controller, in accordance with its own privacy policy.

PERSONAL DATA WE MAY COLLECT

We may collect or otherwise process the following personal data:

  • name and contact details (including postal and e-mail address and telephone number);
  • financial and credit card information;
  • personal description and photograph;
  • the personal data of any guarantor or emergency contact (including their name and contact details and you should show them a copy of this Policy and tell them that you have given their details to us);
  • the educational institution you attend and the course(s) studied by you;
  • nationality and immigration status;
  • IP addresses or other online identifiers when using the Website;
  • any information required under applicable law or by a relevant planning authority or local counsel; 
  • any other information that you may provide to us, either directly or through other members of our group or CRM Students Limited when communicating with us via the Website, by telephone, email or other means. 

We may also (where necessary and as lawful to do so) process some sensitive personal data about you, including in relation to your health, which is necessary for us to accommodate student needs.

USES MADE OF THE PERSONAL DATA

We may use the personal data described above for the following purposes:

  • to carry out our obligations arising from any contracts entered into between you and us (or which you enter into with our contracting partner, CRM Students Limited) and to provide you with the information, products and services that you request from us or CRM Students Limited, including to manage the letting services provided to you;
  • to receive payment or provide refunds;
  • for tax, risk management and other internal record keeping purposes;
  • to respond to question/requests for information from you to us;
  • to respond to any questions or other matters raised by you in relation to us, the Website, CRM Students Limited or any of our products and services;
  • where necessary as part of any restructuring or sale of our business or assets;
  • for compliance with legal, regulatory, planning, local counsel and good governance obligations;
  • for internal operations, including data analysis, research, statistical and survey purposes (in anonymised form where appropriate, see below);
  • for property maintenance, as necessary;
  • for sharing with universities for pastoral purposes or as part of our contractual obligations with universities;
  • to check whether a student has the right to reside in the United Kingdom;
  • for rent collection purposes (including to pursue any missed payments from you or your guarantor);
  • to maintain and improve the functionality of the Website;
  • to understand your use of the Website, or keep a record of your product or service preferences;
  • to provide you with information regarding our products and services, where you have consented to be contacted for such purposes or it is otherwise lawful for us to do so (as set out below); and
  • for other purposes as may be relevant to the management of your legal or other relationship with us.

AGGREGATED INFORMATION

We may also convert your personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve our products and services and for the statistical purposes mentioned above.

Anonymised aggregated personal information does not personally identify you or any other individual and is therefore not personal data for the purposes of the Act.

SECURING YOUR PERSONAL DATA

We are required to keep your personal data secure in accordance with the Act. Please note, however, that the transmission of information via either: (i) the internet (which happens before your personal data reaches our own systems); or (ii)  telephone communication (either telephone calls that you make to us or that you may answer from us), may not be  completely secure. We cannot guarantee the security of your data transmitted via the internet, including when you contact PSL or CRM Students Limited  via email, or via the telephone when you make telephone calls to us).Accordingly, any transmission via the internet or the telephone is at your own risk.

DISCLOSURE OF YOUR PERSONAL DATA

For the purposes described in this Policy, your personal data may need to be disclosed to (or otherwise processed by) third parties acting on our behalf (including members of our group and service providers outside our group).

We may share your information with Business partners (including CRM Students Limited), Landlords, suppliers, universities and sub-contractors for the performance of any contract which we have with you, or which we have with any of these other organisations.

In the event of a sale of our business or assets, we may also disclose your personal data to the prospective buyer of such business or assets and their advisors.

We will also disclose your personal data when we are under a duty to disclose or share your personal data in order to comply with any legal obligation. We may share it with others for our own good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of our customers or other persons with whom we have a business relationship, or to purchasers or prospective purchasers in relation to a disposal of our business or assets. We may also share your personal data with the relevant local council and/or regulatory planning authorities, as necessary.

WILL YOUR PERSONAL DATA BE TRANSFERRED ABROAD?

The data that we collect from you may be transferred to and processed by us (and/or our suppliers and affiliates) in jurisdictions outside the European Economic Area (“EEA”). They may not have data protection laws equivalent to those within the EEA.

HOW DO WE CONDUCT DIRECT MARKETING?

We would like to provide you with information about products, services, promotions and offers from us, which may be of interest to you. This communication may occur by e-mail, postal mail, telephone or text message.   

We will provide you with the opportunity to choose whether we can contact you in this way and for this purpose, where we are required to do so in accordance with the Act and certain other applicable laws.

Any direct marketing that you receive from us in electronic form will also provide a simple means for you to opt-out of receiving further marketing communications.  For example, in e-mails we may provide you with an e-mail address to which you can send an opt-out request.

We will take steps to stop any marketing to which you object or in respect of which you withdraw your consent within a reasonable period, but please allow sufficient time for the change to be administered. Please note, we are not responsible for any direct marketing sent to you by any third party in respect of which you have given your consent. In such instances, you should refer to the privacy policy of that third party. If you wish to unsubscribe you will need to contact them directly.

COOKIES

We use “cookies” on certain areas of our Website.  Cookies are small data files stored on your device by a website. Cookies help us monitor and improve the functionality and usage of our Website and your experience of the Website.

We use cookies to see which areas and features are popular and to count visits to the Website, to recognise you as a returning visitor and/or to tailor your experience of the Website according to your preferences. We also use cookies to enable us to remember who you are across each of the pages you visit within the Website. Where appropriate, we use cookies to remember what information you may have entered on a previous page.   

The cookies used on our Website may be categorised, as follows:

  • Cookies which are “strictly necessary” for functionality of the Website’s platforms. These cookies are essential in order to enable users to move around the Website and use its features;
  • Functionality” cookies which allow the Website to remember choices you make and your preferences, for example where you register/sign-up for events, products and/or services; or
  • Performance/Analytical” cookies, which collect information about how users navigate the Website; for example, which pages users access most frequently. They identify how users interact with our Website, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Website works and understand what interests our Website’s users.

We also use Google Analytics, which sets a cookie(s), to collect anonymous visitor activity on the Website to enable us to improve and enhance the Website our visitors and customers. They keep track of where the visitor came from, what search engine was used, what link was clicked, what keyword was used, and where in the world the Website was accessed from. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion or an Ecommerce Transaction. We also use other services from Google such as Google Tag Manager, AdWords, YouTube and others.

In addition, we may use a number of social media tools to enhance visitor interaction on our site. If you already use these platforms their own cookies may be set through the Website. Data may then be collected by these companies that enables them to serve up adverts on other sites that they think are relevant to your interests.  These platforms (and their providers) are responsible for what they do with cookies including on other websites such as our own.  Please refer to the cookie and privacy policies on all social media sites that you visit and check these policies carefully. We do not control what cookies these platforms use or what they say about them in their own policies.

Using our online chat functionality may also mean that we collect information on your country and IP address. This information will not be used for any purpose other than to enhance the functionality and performance of the website.

Our provider of virtual tours TourDash may use cookies as well for performance or analytical purposes to enhance your experience.

A summary of the cookies which we use on our Website are set out below (these are a combination of first party cookies and third party cookies and this means some are set by and on our own domain name, whereas others are set by (and on) a domain name that is not our own):

Domain

Cookies

doubleclick.net

DSID: Advertising - these cookies are set by Google, and are used to tailor advertising to a user, and help match activity of users across devices.

IDE: Advertising

google.co.uk

1P_JAR: This suite of cookies is used by Google to keep track of user conversions, store preferences and use those preferences to serve (or not serve) advertising around the web, based on user interests and engagement.

APISID: Advertising, Analytics and Personalisation. 

CONSENT:  Advertising, Analytics and Personalisation.   

HSID: Advertising, Analytics, User Security and Personalisation – Google uses this cookie to keep track of Google user activity on individual websites to assist with security monitoring of logged in Google Account users. This cookie is also used for content and advertising personalisation.

NID: Personalisation – this cookie is set by Google tracks your preferences, such as preferred language and location.

SID: Advertising, Analytics, User Security and Personalisation – Google uses this cookie to keep track of Google user activity on individual websites to assist with security monitoring of logged in Google Account users. This cookie is also used for content and advert personalisation.

SAPISID: Advertising, Analytics and Personalisation – this suite of cookies is used by Google to keep a track of user conversions, store preferences and use those preferences to serve (or not serve) advertising around the web, based on user interests and engagement.

SIDCC: Advertising, Analytics and Personalisation.

SSID: Advertising, Analytics and Personalisation.

www.google.co.uk

AdsUserLocale, GoogleAccountsLocale session, UULE, _ga

google.com

1P_JAR: Advertising – this suite of cookies is used by Google to keep a track of user conversions, store preferences and use those preferences to serve (or not serve) advertising around the web, based on user interests and engagement.

APISID: Advertising, Analytics and Personalisation. 

CONSENT: Advertising, Analytics and Personalisation.  

HSID: Advertising, Analytics, User Security and Personalisation – Google uses this cookie to keep track of Google user activity on individual websites to assist with security monitoring of logged in Google Account users. This cookie is also used for content and advertising personalisation.   

NID: Personalisation – this cookie is set by Google tracks your preferences, such as preferred language and location.  

SID: Advertising, Analytics, User Security and Personalisation – Google uses this cookie to keep track of Google user activity on individual websites to assist with security monitoring of logged in Google Account users. This cookie is also used for content and advertising personalisation.

SAPISID: Advertising, Analytics and Personalisation – this suite of cookies is used by Google to keep track of user conversions, store preferences and use those preferences to serve (or not serve) advertising around the web, based on user interests and engagement.

SIDCC: Advertising, Analytics and Personalisation.

SSID: Advertising, Analytics and Personalisation.

OTZ: Analytics – this cookie is used by Google for site analytics tracking.

providesupport.com

CFDUID: set by the CloudFlare service to identify trusted web traffic.

VSID: third party cookie.

purestudentliving.com

RequestVerificationToken, _ds_gtm_UA-29525880-1, _ga, _gat, _gid, hide_cookie_message

tourdash.com

_GAT: Used to throttle request rate.

_GA: Cookie belongs to Google Analytics and it is used to recognise users. This cookie does not include personal information.

_GID: Cookie is used only to realise statistical analysis (through Google Analytics service).

live.tourdash.com

AWSELB, session

youtube.com

APISID, CONSENT, HSID, LOGIN_INFO, PREF, SAPISID, SIDCC, SSID, VISITOR_INFO1_LIVE, YSC: These cookies from YouTube allow us to monitor video usage on the Website and allow Google to monitor performance of videos, analytics, preferences and usage, as well as to serve personalised advertising.

Web browsers allow control of most cookies through the browser settings.  Please be aware that you can use your web browser to:

  • delete all cookies;
  • block all cookies;
  • allow all cookies;
  • block third-party cookies;
  • clear all cookies when you close the browser;
  • open a 'private browsing' / 'incognito' session, which allows you to browse the internet without storing local data; and
  • install add-ons and plug-ins to extend browser functionality.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

YOUR RIGHTS

You have the right to request access to or receive copies of the personal data that we hold about you. If you would like to exercise this right, please contact us via notices@crm-students.com. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

If you believe that any information we have about you is incorrect or incomplete, please write to or e-mail us as soon as possible.  We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate.

You also have the right, in certain circumstances, to request that your personal data is no longer processed or that it is deleted, in accordance with the Act. You can contact us for more details.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be made available on the Website. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT

Questions, comments and requests regarding this Policy should be sent to notices@crm-students.com.  In this way CRM Students Limited will take in your questions, comments and requests on behalf of Pure Student Living Limited, and it may deal with them on our behalf.