1 – Scope
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The 2018 Data Protection Act and the UK General Data Protection Regulation (UK GDPR), along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data and protect against the unlawful processing of personal data.
Moda Life Management Ltd - ICO registration ZA817563
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Tower One Opco Limited – The Lexington, Liverpool - ICO registration ZA831156
Moda is pleased to provide the following information:
2 - Who we are
Moda is a developer and operator of homes for rent in the UK.
3 - Personal data
a) The business uses the information collected from you to provide quotations, make telephone contact and to email you information concerning your enquiry. For those with tenancy agreements with Moda, additional information may need to be collected. Only that information necessary for Moda to fulfil its contractual obligations will be collected.
b) For marketing purposes, Moda may use the contact details provided by you to respond to your enquiries including making telephone contact and emailing information to you which we believe may be of interest to you.
c) When you make initial contact, including through website enquiries, you consent to Moda maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. At all times, the business will work hard to be fully UK GDPR compliant
d) Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence, when you visit us, from phone calls and details of your visits to our website, including but not limited to personally identifiable information like Internet Protocol (IP) addresses.
e) The business will only collect the information needed so that it can provide you with the services it provides; Moda does not sell or broker your data.
g) Telephone calls may be recorded for training and security reasons and this will be announced at the start of the call. Where recorded, call data is retained no longer than six months unless it is required longer for legal reasons.
h) Further information exclusively pertaining to data protection and employees is covered in their employment contract and the Company Handbook.
4 - Legal basis for processing any personal data
To meet our contractual obligations to residents and legitimate interests when responding to enquiries concerning the services provided.
For potential and existing residents Moda seeks your explicit consent to the sharing of your data with certain third parties, but only where special categories of personal data are involved such as in certain circumstances medical information, which it may need to share to protect you or supply the services it is contracted to provide you. Moda will only share data where necessary to provide the services it is contracted to provide, to enforce our contractual rights and to protect residents from harm as part of our duty of care.
5 - Legitimate interests pursued by the business
To promote Moda’s building and home for rent. Communications may include direct mail, email, newsletters, telephone calls, social media and any other channels to reach those who may be interested in renting or using the facilities provided by the business.
6 – Your agreement
7 – Disclosure
Moda will keep your personal information safe and secure, although our administration team will have access to your contact details so that they can manage your account. Some of the services used to support the business such as marketing, website management, the MyCasa App, legal and debt collection services are outsourced from third-party suppliers.
Moda will always put in place with these third-party suppliers a processing agreement and will only share personal information with them where required to meet your requirements or to support our legitimate interests or contractual obligations.
In certain circumstances the business may need to disclose your Personal Information to meet legal, regulatory or valid governmental requests.
Moda may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 - Retention policy
Moda will process personal data for the duration of any business dealings and will continue to store only the personal data needed for up to eight years after any contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details and/or liabilities. For more details a copy of Moda’s Document Retention Schedule is available on request.
9 - Data storage
Data is predominantly processed within the UK and through HubSpot a US based supplier. For your protection HubSpot and Moda have signed Standard Contractual Clauses to allow overseas data transfers. Certain personal data is also held within Microsoft SharePoint for Business.
10 - Your rights as a data subject
At any point whilst Moda is in possession of or processing your personal data, all data subjects have the following rights:
• Right to information - you can ask for information about what data is being processed and the rationale for such processing.
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Moda refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, Moda can confirm what information it holds about you and how it is processed.
11 - You can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Moda and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, restrict, object to processing and rights to erasure.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 - To access what personal data is held, identification will be required
Moda will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months.
A minimum of one piece of photographic ID listed above and a supporting document is required. If Moda is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to email@example.com or by phoning 01423 560200 or writing to us at the address below:
13 - Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Moda you have the right to complain to us. If you do not get a response within 30 days you can complain to the ICO.
The details for each of these contacts are:
Casa by Moda and Moda Living
Attention: The Data Protection Administrator
Central House, Beckwith Knowle, Otley Road, HG3 1UG
Telephone: 01423 560200 or email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113 or email: https://ico.org.uk/global/contact-us/email/
For further information on Data Privacy relating to the MyCasa app, please click here.