Privacy Policy

 

Summary

We respect your right to privacy and treat any information you give to us with care. This Privacy Policy describes how we collect, use, share, store or otherwise process the information we hold about you. We are committed to ensuring the personal data you provide is used for the purpose it was collected and is kept secure.

 

Your personal information allows us to deliver the Rainbow Quay’s management services and comply with our obligations set out in the terms of our leases, as well as enabling us to improve the services we provide by understanding your needs, interests and preferences.  By understanding what you need, like (and what you don’t) we are able to provide more appropriate services to you and other residents and lessees at Rainbow Quay.

 

Who we are

Rainbow Quay Residents Company Limited (“we”, “our”, “us”) is the data controller when you provide information to us.

 

What information do we collect?

When you interact with us or our appointed managing agent, for example when browsing our website, emailing our directors or raising an issue with our agent, we may collect or receive information about you and that particular interaction. Generally, this may include your personal data which means personal details from which you can be identified or are identifiable, for example:

 

• Contact information, and preferences;
• Information about your ownership or residential status at Rainbow Quay;
• Images of you in areas of Rainbow Quay covered by CCTV (such as the garage);
• Conversations you have when you call our managing agent and their customer service teams;
• Information about anyone residing in your property (such as tenants), if that information is provided to us;
• Information about the devices you use to interact with us (e.g. if you access our website via a mobile device);
• Certain types of personal information which are more sensitive: such as health or disability requirements (e.g. if you need a guide dog, or support animal in your property). We only collect this type of information about lessees and residents to the extent that there is a clear reason for us to do so.

 

Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.

 

When and how we collect your information

We and our managing agent may collect information you provide to us directly and indirectly when interacting with our services and those of our managing agent. This may include when you:

• Contact us online, over email or on the phone;
• Create, use or manage an online account;
• Visit our website or those of our managing agent;
• Use social media login functionality;
• Interact with us in online forums, by email, text, telephone, or on social media;
• Complete our market research/lessee/resident surveys.

 

Legal basis for using your information

All organisations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.

 

With your consent

There are some activities where we process personal information with your consent, for example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time by clicking on the unsubscribe link on the email or updating your account preferences. We will indicate in the Policy where we rely on consent.

 

To fulfil a contract and/or the terms of your lease

We also process your personal information in order to fulfil the terms of your lease for Rainbow Quay (we are a party to your lease along with the freeholder).  For example, we and our managing agent(s) will process your information to administer the collection of service charge, water utility recharges and perform our other property management activities

 

Vital interests

We have a basis to use your personal information where it is necessary for us to protect life or health.   For instance if there were to be an emergency impacting individuals at the development, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.

 

For a legitimate interest

We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).  We consider our legitimate interests to include all of the day-to-day activities carried out with personal information for the purposes of the running of a lessee owned residential management company.  For example, we might use your information to analyse demographics, maintenance condition, lease compliance, development and car park occupancy rates and other information about the development.

 

We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.

 

When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).

 

You can object to us relying on our legitimate interest to use your personal data in these ways at any time by getting in touch with us using the contact details below.  Please note, an individual must give specific reasons why they are objecting to the processing of their data which should be based upon their particular situation.  We may be able to continue processing, for example, if there are legitimate grounds for this.

 

To comply with legal obligations

There may be situations where we need to use your information to comply with legal obligations. For example, we may have to issue notices and correspondence to you in connection with matters relating to the management of the development and your lease.

 

How we use your personal information

The reason we use your information will often be obvious from the way you interact with us. For example, if you report a maintenance issue to us or our agent (such as a water leak), we would use that information in response to that issue.  However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:

 

Use of personal information	Legal basis for processing (where there is more than one, the exact grounds will depend on the activity – see the section above for an explanation of each)
Provide you with the products and services you have requested, including administering any maintenance requests, responding to any enquiries, complaints or requests you may have	Consent, Legitimate Interest, Contract/Lease
To manage our relationship with you	Consent, Legitimate Interest, Contract/Lease
Send you market research surveys	Consent, Legitimate Interest
Tailor our service to your preferences, where you tell us about them	Consent, Legitimate Interest, Contract/Lease
Make decisions about what direct marketing to show you based on how you have interacted with us	Legitimate Interest
Improve our management services online and offline, including our websites and apps	Legitimate Interest
Allow you to interact with us online and offline, in forums, on social media and elsewhere	Consent, Legitimate Interest, Contract/Lease
Monitor the use of our services and content	Legitimate Interest, Legal Obligation
Verify your identity	Legitimate Interest, Contract/Lease
Conduct analysis, system testing and statistical research	Legitimate Interest, Legal Obligation
Comply with legal obligations on us	Legitimate Interest, Legal Obligation
Detect ad blockers and other technologies that affect the services we provide	Consent, Legitimate Interest, Contract
Manage Rainbow Quay efficiency, including regulating the provision of amenetires, use of utilities and lighting based on occupancy	Legitimate Interest
Send you product or service related communications, service messages	Legal Obligation, Consent, Legitimate Interest, Contract/Lease
Send you direct marketing, where you have consented	Consent, Legitimate Interest
Allow social sharing functionality	Consent, Legitimate Interest, Contract/Lease
Keep residents safe and ensure the security of our development	Legal Obligation, Legitimate Interest
Conduct data matching and audience insight activities	Legitimate Interest
Detect ad blockers	Legitimate Interest
Ensure the acceptable use of our services	Legitimate Interest, Legal Obligation
Facilitate payments and credit checks	Legal Obligation, Consent, Legitimate Interest, Contract
Facilitate the restructuring or sale of all or part of a fFlat (including shares in the Company)	Legal Obligation, Consent, Legitimate Interest, Contract/Lease
Investigate and respond to disputes	Consent, Legitimate Interest, Contract/Lease
Provide you with help and support where it may be required. For example, we contact you to provide assistance if experience technical difficulties with any of our (or our agent’s) systems, where we have your contact details	Legitimate Interest, Contract/Lease

 

 

How we keep your personal data secure – Technical and organisational measures

We, and our managing agents, have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems.  Your information may be transferred to one of our reputable cloud-based service providers who may store and process this information outside the European Economic Area (EEA). We can assure you that we take all reasonable steps to ensure your data is handled securely under appropriate agreements with our suppliers.

 

How we store your personal information and how long we keep it for

We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.

 

Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.

 

Our processors

There may be situations where we share data with our suppliers and data processors – companies who act on our behalf, such as our appointed managing agent – to collect and/or process your information for us or to use the personal data we pass to them in order to provide management service. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.

 

Identity verification

If we provide a service that is dependent on age or residency we have an obligation to verify relevant information. Where relevant we may pass your information to a third party for this purpose.

 

Our websites and partner websites

We also receive information about you indirectly when you interact with us. For example, when you visit our websites or use our apps the devices you use may provide us with your general location (like which country or region you’re in). They also tell us if you are using ad-blockers and your IP address. We may also receive information from cookies and other technologies that are on your device or browser. For more information on our use of cookies, please see our cookie policy below.

 

Agents, suppliers and partners

We collect information about you when it is provided to us by third parties.  This might include our managing agents and other suppliers. This could be when you acquire your property, take a short tenancy in the development from a lessee, provide comments online via our websites or forum, or where you interact with anyone who assists us with the provision of management services at the development. You should always read the privacy policies of companies or other third parties you use, as they will use your information in accordance with their own privacy policies.

 

When you, or someone on your behalf, makes an enquiry through our appointed agent, or where you acquire a flat at the development we may receive information about you, including information about anyone else who resides at the premises under a tenancy agreement.

 

Where you interact with third parties who promote our services for us, these third parties may pass us your information.

 

When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how the development is performing.

 

We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline.

 

Sometimes we may want to improve our services by getting a better understanding about residents & lessees and their preferences. In these situations we may ask our managing agent to collect and provide information to us about you.  Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. We may receive updated information about you from organisations that provide services to you.  For example, we might be updated if your contact details change (e.g. If you are a non-resident landlord) so that we can keep our records up to date or receive updated bank details to ensure that our respective lease obligations are adhered to.

 

Further Information on how we use your information

We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.

 

Do not track signals or browser/device settings

Our websites are not designed to respond to “do not track” signals or browser/device settings.

 

Direct marketing

In addition to sending you information about the services you use (service communications), where we have your permission or where we are relying on our legitimate interest, we may send you direct marketing communications about our services, events and offers (e.g. where we have obtained a discount at a local business for residents).

 

Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as Whatsapp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our websites or use our apps. This may also include any websites and apps of our partners who are in our advertising networks.

 

We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used our services where we feel we have a legitimate interest.

 

You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.  Alternatively, you may contact our managing agent and change your marketing preferences who will pass this on to us.

 

Resident/Lessee communications and “in-life” updates

We may use your information to send you newsletters, bulletins, and other “in-life” communications (about your property and Rainbow Quay).  For example, we may send you emails or notices to update you on what’s going on in and around Rainbow Quay. You’ll be able to opt-out of these.

 

Service communications will be sent to you regarding the services you interact with. These are important messages relating to the services we (or our agents) provide to you.

 

Analysis and product development

We may use your information to improve the services we and our agents offer in order to satisfy our legal obligations to you under your lease and make Rainbow Quay a better place for residents and lesses. For example, we may look at the preferences our residents have for amenities available on site, or what they think regarding maintenance or cleaning levels at the development.

 

Detecting ad blockers

When you visit our websites we may check (by using script, code, cookies or other technical means) if you are using ad-blocker or other privacy tools. If we do detect one of these tools, we may ask you or ask your browser to ask you, if you would give us permission to ignore those settings and continue to serve adverts and/or collect your information using cookies and similar technologies.

 

Information about your device and use of ad blockers may be stored or associated with your device and used to reinsert adverts and to understand how ad blockers and other privacy tools are being used by our visitors.

 

Linked services, third party sites and content

Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.

 

Payments and credit checks

Your information may be used to take payment for products and services and may be used to verify credit details related to payments.

 

Disclosures required by law

Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.

 

Acceptable usage

If you post or send offensive or inappropriate content anywhere on or to any of our websites or apps, or otherwise engage in disruptive behaviour on any of our websites or apps, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.

 

Data Transfers

When you complete our registration forms or use our services, we may transfer your information to our processors – companies that carry out activities on our behalf, only on our instructions – outside the European Economic Area (EEA) to countries that may not have data protection rules that provide the same level of protection to your personal information as countries in the EEA. However, we will only transfer your information if we have appropriate measures in place to ensure the protection of your information in accordance with applicable data protection legislation. (For example, model contract clauses or Privacy Shield in the case of the USA)

 

When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware of the potential transfer of their information outside the EEA.

 

Training and quality

If you contact our agents by phone or on chat the conversation may be recorded and listened to for training and quality purposes.

 

Social media login

Our websites and apps provide plug-ins to social media websites, including Facebook, Twitter, Google, Yahoo and LinkedIn.

 

If you make use of, or log-in to, the social media features on our websites or apps, we may (depending on your privacy settings) access, use and store information about you, including, but not limited to: your name, e-mail address, gender, location, profile, picture, contacts, and any other information you have chosen to make available.

 

To find out more about the reasons and extent to which social media sites collect and process your data, or to change your privacy settings, please refer to your social media provider’s privacy policy.

 

How we share your personal information

Where you provide your information to us we may share it with our company directors, other residents / lessees (where required to perform our services), and affiliates, partners and Suppliers (including but not limited to our managing agents).

 

What sharing takes place will depend on the activity that your information is being used for. Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected.  We won’t sell your personal information without your consent or share it with other organisations for their own marketing purposes, unless you have consented to such sharing.

 

Sharing with advertising partners

When you visit our websites or apps we may pass information about you and any devices you are using to our advertising network partners to enable them to deliver relevant adverts and tell advertisers that adverts have been delivered and seen.

 

Sale of your property

If you sell or are looking to sell or lease your property, we (or our managing agents) may transfer your information as part of that activity, including, but not limited to responding to replies to enquiries. Where this is the case your information will be used in accordance with this Policy unless you are notified otherwise.

 

Access and Control – Updating your information

Please ensure you keep your information up to date by logging into your account via our managing agent’s online system and modifying it. Alternatively, you can call them or email them on their published customer services number.

 

Controlling direct marketing

You can change your mind about receiving direct marketing from us or our managing agent or change your preferences by logging into your account with them, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below.

 

Requesting copies of your information

You may request a copy of your personal information which we may hold about you by getting in touch with us using the contact details below. You may also ask us to correct any inaccuracies in your personal information.  This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.

 

Withdrawing consent

Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time by logging into your account, if you have one, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below. However, we may have the right to rely on an alternative legal basis for the processing activity so that we are able to provide you with the service we are required to provide and, in that case, will inform you of that.

 

Other rights

You may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

 

Complaining to the regulator

If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK. Details for the UK Information Commissioner can be found at https://ico.org.uk/

 

Changes to our Privacy Policy

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

 

Contact

If you would like to get in touch with us, please contact

• By Email: directors@rainbowquay.co.uk (copying in connect@rynew.com)
• By Post: Rainbow Quay Residents Company Limited, C/o Rynew Property Management Ltd, 60 Cannon Street, London, England, EC4N 6NP

Cookie Policy

Introduction
We use cookies to help improve our websites in a variety of different ways. Including collecting contextual information about your visit to the site to enhance functionality and user experience.

What are cookies?
Cookies are small text files placed on your devices when you visit websites via internet browsers. Our use of cookies is to primarily help enhance your user experience and improve the efficiency of our website. In order to optimise the user experience, you will need to enable cookies.

What cookies do we use?
Essential cookies – These make our websites work. They remember that you are logged in to your account. They also allow us to collect information about your use of our websites and apps, enabling us to improve the way they work.

Performance Cookies – Performance cookies also allow us to see if there are any technical issues on our websites and if you are experiencing any issues using our websites. They also allow us to look at usage statistics and performance.

Functional cookies – These cookies collect information about the language you have requested the site display content in, remembering your username so you can log-in more quickly, text size, location you are in and generally allow us to customise your experience. Nobody likes having to repeat themselves and these cookies help with that.

Tracking and advertising cookies and similar technologies – We do not currently use these Cookies, but we may do so and use these types of cookies and similar technologies to provide adverts that we think may be more relevant to your interests. This can be based on your browsing activity and is known as Online Behavioural Advertising or OBA. Cookies may be placed on your browser, which remembers what websites you’ve been to. Advertising based on what you have been viewing is then displayed.

Web beacons and tracking pixels – These technologies help us to count users on a web page, and see if a cookie has been activated. They allow us to see how popular content is and if an email has been delivered to a recipient, opened and links clicked on. We may use this information to track how successful campaigns have been.

Flash cookies – Sometimes we may use flash players to deliver special content, such as video clips. This uses Local Shared Objects or flash cookies to remember settings. Device Fingerprinting – Sometimes we may use a device’s browser information to identify that device, conduct analysis, help detect and prevent fraud and present content correctly. We also use cookies and similar technologies to:

• Allow you access to our websites;
• Permit your internet connection to our websites;
• Allow our servers to record information about your device (such as IP address, browser type, location, hardware and software information;
• Collect unique device identifier (UDID), geo-location and other transactional data to validate free trials when you use a mobile device;
• Assess content usage;
• Provide relevant content;
• Sell third party advertising and enable frequency capping;

 

Apps
By downloading apps that we may make available from time to time, we may require access to the following services on your device: UDID, MAC address, or other applicable device identifier and location. Other services may also be required in order for the apps to function. This information may be used to validate credentials and provide push notifications to your devices.

 

Managing cookies
You can change your cookie settings very easily in your browser settings. However, you need to be careful about restricting the use of cookies, as they may prevent the websites you visit from working as they were intended.

You can also control which companies set cookies on your devices by visiting the following pages. Please note that you will need to turn off any ad blockers or privacy tools to see what cookies are being set:

Internet Advertising Bureau (IAB) Your Online Choices is an industry programme that allows you to control which companies can set cookies and show you advertising. It provides you an easy way of opting out several advertising networks.

The Network Advertising Initiative control page also allows you to control OBA from the advertising networks they represent.

The Digital Advertising Alliance’s control page also allows you to control cookies too.

It is important to remember that these services use cookies to remember that you have opted-out of cookies being placed on your browsers. If you clear your cache, the opt-outs will be forgotten and you will have to opt-out again.

You can stop web beacons being set, although you cannot decline receiving them in emails. For information about managing these, please visit https://www.allaboutcookies.org/