Privacy Policy 2018

Rynew Privacy Notice

Who are we?

We are Rynew Property Management of 60 Cannon Street, London, EC4N 6NP.

What do we do?

We have been appointed on behalf of our landlord, Resident Management Company or Right to Manage Company to manage the common areas of your development.

What is our role under the General Data Protection Regulation (GDPR)?

We consider ourselves to be the data controllers acting on behalf of landlord, Resident Management Company or Right to Manage Company.

This Privacy Notice tells you what personal information we collect, and why we need it, how we use it and what protections are in place to keep your personal information secure.

This Privacy Notice applies to:
• Visitors to our website www.Rynew.co.uk
• Staff members, contractors, suppliers, partners, tenants, landlords and leaseholders

The type of personal information we collect about you – and the personal information we obtain from third parties – depends to some extent on your circumstances, your role within a contractor or supplier and our legal obligation.

What is personal information?

Your ‘personal information’ means information about you, and any information from which you can be identified – either by reference to an identifier (for example your name, location data or online identifier such as IP address) or from factors specific to your physical, cultural or social identity.

Who do we collect personal information from?
We may collect personal information:
• From you, where you visit our website, complete one of our online forms or contact us;
• From landlords; and
• From suppliers and contractors and staff who work with Rynew.

How do we collect personal information?

Information provided to us by you:
• When you enter information into our website or online forms; and
• When you contact us by email, telephone or post.
Information is collected by us automatically, when you visit our website.

Personal information is provided to us by third parties such as Landlords, contractors and partners:
• By email;
• Hard copy documents;
• By telephone; and
• In person
• Electronic documents

What personal information do we collect and process?

Personal information provided to us by you may include, as applicable:
• Information that you give us by entering information into our website and online forms, e.g your name and contact details given; and
• Information that you give us when corresponding with us by email, by telephone, or by post, e.g your name and contact details.
• We hold details including: Name, address, telephone, email, interested parties, key holder names, key holder email, key holder phone, tenant names, tenant email,tenant phone, other general contact information, payment comment, general notes, email, transaction details, bank details.

Information collected automatically by us when you visit our website may include:
• Technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms; and
• Information about your visit, including the URL (the full Uniform Resource Locators) clickstream to, through and from our website including date and time, what you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Personal information provided to us by third parties such as customers and suppliers, partners, may include:
• your name and contact details;
• your employment details; and
• your CV.

What do we use your personal data for?

We will use your personal information for the following purposes:

• To provide you with any information or assistance requested by you.
• Administering the services as per your lease
• To send you marketing emails regarding the Rynew Services, Rynew News, Staff updates, Rynew
Awards, Training opportunities

In these circumstances, the legal basis for processing the data is your consent. Please note that you have the right to withdraw your consent to this processing at any time by contacting us using the details set out in the Introduction section above. If you choose to withdraw your consent, this will not affect the lawfulness of the processing that occurred prior to the withdrawal.

Information collected automatically by us;
We will use this information:
• To administer our website and for internal operations, including troubleshooting, data analysis,
testing, research, statistical and survey purposes;
• To improve our website to ensure that content is presented in the most effective manner for you and
your computer;
• To allow you to participate in interactive features of our website, when you choose to do so; and
• As part of our efforts to keep our website safe and secure.

In these circumstances, the legal basis for processing the data is (our legitimate interest in administering and improving our website and its features, and keeping our website secure)

Information provided to us by third parties
We will use this information:
• For the purposes of administration in relation to Rynew clients; and
• For the purpose on contracts entered into between Rynew and suppliers, contractors and partners.

In these circumstances, the legal basis for processing the data (may be the legitimate interest of Rynew, its members and third-party suppliers to conduct business operations.

Who do we share your personal data with?

We may share your personal information with the following third parties, where relevant:
• Contractors
• Suppliers
• Partners
• Staff – to enable us to deliver the core business of professional development.
• Third party contractors that provide services to us (such as Mailchimp, SurveyMonkey, Blockman
Fixflo); and
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also share your information with third parties such as regulatory authorities, or where we are under a legal obligation to disclose your information (for example where we are required to share information in accordance with legislation, to prevent fraud and other criminal offences, or because of a court order). We may disclose your information in order to enforce our legal rights or to protect the legal rights of our customers or others.

How do we keep your personal information safe?

We have security measures in place to restrict access to personal information, to guard against unauthorised or unlawful processing of personal information a and against damage to, accidental loss or destruction of, your personal information.

The security measures applied include:
• hard copy records and manual files are kept to a minimum but those kept are in locked filing
cabinets and
• electronic records are kept in an electronic filing system with access restricted to Rynew staff only.
• Database system called Blockman, which is operated on Amazon Web Services located in EU. Data stored and transferred is encrypted. Access is only granted to administrators associated with our office

Third parties
In terms of our contracts with third party contractors include obligations on them in relation to what personal information they can process and what they can do with that information. Our third-party contractors include:

Partners
Contractors
Blockman www.blockman.co.uk
Fixflo www.fixflo.co.uk
Survey Monkey www.surveymonkey.co.uk
SOTech www.SOTech.co.uk

How long do we keep your personal information?

Your information will be maintained by us as long as our appointment exists or for as long as required by Statute or for as long as Lawfulness of Processing can be established without consent.

Where is this data stored?

This data is stored in a database called Blockman which is operated on Amazon Web Services located in the EU. Data stored and transferred is encrypted. Access is only granted to administrators associated with our office.

Changes to this Notice

This Policy may be subject to change and we will notify you of any changes.

What if you sell the property?

Where the Lessor is a Company, there is still an obligation on the Data Controller to main adequate accounting records, and a list of past and present members. However, if you sell the property only your name, address and transaction details are necessary to satisfy this requirement. All other contact details are erased.

Your rights

• You have a right to be informed.
• You may request a copy of your data stored.
• You may request correction to any erroneous data.
• You may request deletion of data, if not in violation of statutory or contractual requirements.
• You may request a restriction on processing.
• You may lodge a complaint to the controller or object to processing.
• You may lodge a complaint to the Supervisory Authority.
• You may withdraw consent if processing originally required consent.

What happens in the event of a Data Breach?

In the case of a data breach, Rynew Services, the Data Controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Supervisory Authority and Data Subject, if the personal data breach is likely to result in a risk to the rights and freedoms of natural persons.