Last Updated: September 2020
aparto is a Student Accommodation management company with assets in the UK and Ireland.
Our goal is to maintain your trust and confidence when handling your data. aparto promises to protect the individual’s right to privacy, and implement safeguards that prevent the misuse of private information.
aparto is committed to meeting the legislated data protection requirements in all the countries in which it operates, specifically the EU General Data Protection Regulation (GDPR)
What Information We Collect
aparto collects the following information from customers and potential customers in order to provide product services: contact details, such as name, email address, and phone number, booking data, as well as information related to the day to day running of our business, such as financial and transaction data. You have the right to access your personal data held by us, and to request its correction or deletion.
End User Personal Data
aparto collects both our residents and potential customers (“End User”) personal data for the purposes for providing them with accommodation services and services that relate to accommodation. Personal data collected from End Users varies but typically includes name, email address, phone number, gender, date of birth and identifiers such as student IDs. It can include the Users bank details and the details of guarantors, financial and academic institutions.
We are considered a Data Controller under the Data Protection Legislation. We work with third parties on our behalf (who are considered Data Processors), in accordance with our obligations under the applicable Data Protection Legislation to assist them in providing a robust approach to data protection. End User data protection issues can be raised with us, and we will cooperate with the relevant third party data processor if necessary.
Logs & Telemetry
Special Categories of Personal Data
We may also collect, store and use information about your health, including any medical conditions or disabilities to the extent required to make any reasonable adjustments to enable you to access and enjoy our facilities. We do no not collect, store or process this special category data for any other reason.
Who We Share Data With
There will be circumstances where it is necessary for aparto to share some customer data. When this data sharing takes place, this will always be relevant for the purpose the data was given. For example, if you are a resident, we may provide your Local Authority End User data for the sake of a council tax exemption notice relating to accommodation. When we share this data, we commit to doing so in a way which protects your privacy in line with the GDPR regulations.
Other ways that we may share data with include:
- Business partners, suppliers, and contractors
- With your University so they can provide support, or we have concerns regarding your health or disciplinary matters.
- If you are a tenant or applicant, we may share data with your dual occupant or guarantor.
- With your guarantor and designated emergency contact
- With the relevant utility supplier for the purpose of ensuring bills are paid
- With our debt collection services or debt collect solicitors if you fail to pay rent or fall into arrears
- Live chat service provider and use of chat bots
- Automated marketing providers
- Analytic and search engine providers to help optimisation
- With event partnership organisations for onsite events – If we do this we will let you know what we are doing with this information
- If we merge or form a new entity we may share your data with that new entity.
You are welcome to contact us at any stage to express any reasonable limitations on how your data is used, at email@example.com. We will never share sensitive personal data with third parties without the individual’s express consent.
For the purposes of providing our services, we engage cloud service providers, which provide the infrastructure for several of our systems. These organisations will host and transmit encrypted personal data, and do so under a contract with aparto that requires the same standards of protection for the subject’s data rights. In the event of a requirement to disclose data to another third party, or for a purpose which is substantially different from our existing services, you will be given the opportunity to opt-out. With these third parties, and any others, aparto remains liable for the handling of your personal data.
aparto will use your data for the purpose of direct marketing. However, we make a commitment not to share your data with any third-party agents for their direct marketing, or marketing their products. All data collected for the purpose of marketing will only be used by aparto for the purpose of marketing our accommodation.
aparto make a commitment to delete any data relating to marketing our accommodation once the specific year of study expires.
We use livechat software on our website, this is provided by livechat.com, a 3rd party software company. Information on how the data is processed and stored can be found at: https://www.livechat.com/legal/privacy-policy/
How We Use Data
We use Personal Data to provide our services, and we host End User data so that our Customers can provide services to their customers. Examples of how we may use
- To respond to inquiries and provide customer support
- To improve our existing products or develop new ones
- For audits, regulatory purposes and compliance with industry standards
- To send marketing communications
- To make the advance rent payment and rent refund payments
- To comply with local laws and taxes, and to cooperate with local law enforcement
- To execute a tenancy or licence agreement
- To process data for the purpose of completing a contract
- For Health and Safety Purposes, to record accidents and injuries.
- To recover any sums of rent owed to us or the landlord
- To improve our level of service
- To administer a guarantee (for you guarantor)
- To seek your views on our products and services
- To notify you of any changes to our services
- To confirm your identity when arriving at one of our buildings
- To administer parcels
- To notify your emergency contact in an emergency
The information that aparto collects is treated with the utmost care and security. aparto uses commercially reasonable efforts to ensure that the data is:
- Used fairly and lawfully, for limited and specifically stated purposes
- Used in a way that is adequate and relevant to the business purpose, and not excessive in nature
- Is managed to maintain its integrity
- Kept only for the period for which it is required to provide services
- Handled according to people’s data protection rights
- Kept safe and secure
- Not transferred across borders without the protection of strong encryption, secure storage, and the legal basis to do so, by arrangement with data controllers
Our Legal Basis for Using Information
There are a number of lawful reasons for us to process your personal data. As we are a business that provides an accommodation service, we will primarily use your data in order to fulfil your accommodation contract.
Other legal bases we will rely on include:
- Where we are required to comply with legal obligations
- Where it is in our legitimate interest to do so
- In order to help us provide services that you have requested
- How long we hold your data
We will hold on to your personal data for as long as is required to fulfil the purpose that we collected it for, and including and legal, accounting or reporting requirements. Generally, at the end of your tenancy we will hold onto your personal data for six years from collection, for financial reasons. We may hold this data for longer if you have not fully paid any sums due.
If you do ask us to delete your data, we may retain your basic information on a document that records your request.
Access to your Information, Correction and Deletion
To make a request for your data information, corrections or deletions, please do so in writing to: firstname.lastname@example.org
Data Protection Officer
aparto has appointed an internal data protection officer for you to contact if you have any questions or concerns about StarRez’s personal data policies or practices:
Tom Rix – Director Operations
5 Welbeck Street, London W1G 9YQ, UK
If any concerns or complaints remain unresolved after contacting the Data Protection Officer, you may raise the issue with the panel provided by the Data Protection Authority (DPA) in your country, as a free, independent resolution mechanism. Under certain circumstances it is possible for you to invoke binding arbitration as a dispute resolution mechanism.