Privacy Policy

This Privacy Notice was last changed on 25th August 2023.

1. Who we are

   We are London BTR Investments Limited (12524275) (trading as Simple Life London) and we respect your privacy. This notice describes how we, as data controller, use your personal information.

   When you use Simple Life London, 5 Compton Road, Wimbledon, London, SW19 7QA, you trust us with your information. This privacy notice sets out the way we use your information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled.

   If you have any questions or anything in this notice is unclear, please get in touch at the following email address: [email protected] or use the contact details in the Contact Us section at the end of this notice.

   We may change portions of this privacy notice from time to time, so be sure to check it on a regular basis. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites and/or e-mail and/or postal mail within a reasonable period prior to the change becoming effective.

2. Your information

   DATA COLLECTION AND USAGE

   We will collect and use your personal information to allow access to this website for the purposes set out in more detail in this section.

   Your information may be shared with members of our group and with some third parties.

   	What we collect	How we use it	Why we use it	How long we keep it
   1	Information when you communicate with us whether in person, through our website or via email, over the phone or via any other medium, including: Your contact details; The details of your communications with us; The details of our messages to you.	We use this information, including to: Answer any issues or concerns; Provide you with the information, products and services you request from us; Allow our group companies and/or designated estate agents or tenancy management partners to contact you in response to your enquiry and/or provide you with the services that you have requested; Develop new services; Improve our services; Personalise our service.	We use this information because: We require to meet legal, regulatory or other compliance obligations; We have a legitimate business interest in understanding customer feedback and in responding to customer communications in a consistent way; We have a legitimate business interest in providing and improving our services; We have a contractual obligation or a legitimate interest to respond to our customer requests.	We will keep your original enquiry for: A reasonable period of time to ensure that we fully respond to any communications with you and two years thereafter, in the event that there are any disputes arising out of the communications. Following an enquiry we may contact you regarding homes or developments that are deemed relevant to you based on legitimate interest. In accordance with GDPR you have the option to opt out at any time
   2	Information that we collect through your use of our website including: Device information such as operating system, unique device identifiers, the mobile network system; Hardware and browser settings; Date and time of requests; The requests you make; The pages you visit and search engine terms you use; IP address.	We use this information, including to: Provide our services; Develop and improve our website; Identify issues with the website and user’s experience of it; Ensure that content on our website is presented in the most effective manner for you and your computer; Monitor the way our website is used.	We use this information because: We have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it across multiple devices.	We will keep this information for: A reasonable length of time that lets us understand how people use our website and any technical issues they have.
   3	Where you are a tenant, information you provide to us relating to your tenancy (or application) or which we receive from our third party partners, such as estate agents or tenancy management partners. This information shall include: name, address, contact details, salary, age, gender, marital status, family information and occupation; financial information including bank account details and payment details; details any rent arrears and other lease and tenancy information. This information relates to tenancies in respect of properties of which we are the landlord or in respect of which we are the manager on behalf of a third party. In particular we receive information from: Kinleigh Folkard & Hayward is a data controller of information they provide to us and you should refer to their policy for details on how they collect, hold, use and share your data. This can be found at: www.kfh.co.uk/privacy-policy	We use this information, including to: Carry out credit checks (or enable our partners to carry out credit checks); Provide our services; Manage tenants and tenant applications; Conducting analysis on tenancy data, including location, rental growth, demographics, length of tenancy and other data to inform or improve our services, obtain portfolio valuations and raise finance.	We use this information because: We require to meet legal, regulatory or other compliance obligations; We have a legitimate interest in managing our tenancies and otherwise operating our business as a property rental company.	We will keep this information for a reasonable period of time, taking into account: Whether there is any ongoing contractual, legal or financial claim that relates to your relationship with us; Whether any applicable law, statute or regulation allows for a specific retention period.
   4	Information that we collect incidentally other sources or public sources, including: Information available in the media; Information collected by security systems.	We use this information, including to: Maintain market awareness; Provide security to our sites; Answer any issues or concerns.	We use this information because: We have a legitimate business interest in maintaining a public profile; We have a legitimate business interest in providing security over our business; We have a legitimate business interest in understanding customer feedback and in responding to customer communications in a consistent way.	We will keep this for: Information relating to media awareness, for as long as the information is publicly available; Information collected incidentally by security systems we will keep this for as long as reasonable in accordance with our security policy; A reasonable period of time to ensure that we fully respond to any communications with you and two years thereafter, in the event that there are any disputes arising out of the communications
   5	Information that we collect from individuals representing organisations, including: Contact details of individuals working for organisations; Other personal information regarding such individuals.	We use this information, including to: Build relationships with other organisations; Administer our relationships with organisations that we do business with.	We use this information because: We have a legitimate business interest in developing and maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them.	We will keep this information for the duration of our relationship with the relevant company/organisation and as long as we are not made aware that the individual no longer works for them.
   6	Information that we collect from individuals attending events hosted at our premises include: Photographs of our event attendees taken at our events; We may collected certain contact details of attendees at events.	We use this information, including to: Share information (including photographs and video material) of the events we host within our group of companies and with our tenants, prospective tenants and event attendees; Promote future events with assistance from select third parties.	We use this information because: We have a legitimate business interest in promoting our events and tenancy service. We have a legitimate interest in engaging with attendees at events. Where we do not otherwise have a legitimate interest to share information (including photographs and video material) under the foregoing legitimate interests, we may share such material where we have the consent of the relevant attendees or we have a legal obligation to share such information.	We will keep this information for a reasonable length of time which allows us to share information about our events and promote future events.

   DIRECT MARKETING

   We may use personal information you give us for direct marketing purposes to provide updates; newsletters; events; offers or other communications that we think may interest you. These may include details of community events, exclusive tenant vouchers and competitions. We will only do this with your consent or where we otherwise have a legitimate interest to do so and are permitted by applicable law. We may share personal information with third parties to help us with our marketing and promotional projects, or sending marketing communications.

   If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from us or our promotional partners in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:

   • Click “unsubscribe” at the bottom of an email we sent you.
   • e-mail us using [email protected] or contact us using the details set out in the Contact Us section.

   If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you or respond to your inquiries or complaints, and similar communications.

   AUTOMATED PROCESSING

   We make automated decisions regarding you in the following situations: credit checks and background checks relating to a tenancy. These may be undertaken by third parties acting on our behalf such as Kinleigh Folkard & Hayward and in turn for them, including by Home Let (https://homelet.co.uk/).

   We will conduct our credit check on you prior to a tenancy commencing. We will conduct a search against your available credit file. If our search against your credit file illustrates to us that you have an inappropriate credit rating, a decision will be taken automatically to not proceed with your application to become a tenant.

   Submitting to a credit reference check is necessary for us to offer you a tenancy. If this information is not provided we cannot agree to provide a tenancy to you.

   If you disagree with the decision you are entitled to contest this by contacting us at following email address: [email protected].

   LEGAL REQUIREMENTS

   Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

   INFORMATION WE SHARE

   There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

   • We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this privacy notice;
   • In respect of tenants we share your data with our service providers, such as Kinleigh Folkard & Hayward, who provide tenant management services for us. Kinleigh Folkard & Hayward are a data controller of your information and you should refer to their policy for details on how they collect, hold, use and share your information. This can be found at: www.kfh.co.uk.
   • Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function;
   • We may also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you or to fulfil our legitimate interests in promoting our services.

   Your personal information may also be transferred to (or collected on our behalf by) other third party organisations in the following scenarios:

   • London BTR Investments Limited and any of its subsidiaries
   • Sigma Capital Property Limited and Saturn Holding Co S.A.R.L being the shareholders of London BTR Investments Limited
   • For communication purposes we may be using 3rd party tools including Brief Your Market Email System and MailChimp Email System to communicate with you. From time to time other 3rd party agencies may be supplied with your data to send you communications on our behalf including Think EQ (digital agency), BeeGraphics Design (design agency), Design with Direction (design agency), Big Thing Limited (design agency), AKA Media (media agency), Pink Sheep Printers, Trinity McQueen (market research agency), Pastiche (event management company), Active Profile (PR agency), KTZ Communications (PR Agency), Surge Communications (communications agency) Dave Scholes Photography, Ant Clausen (photography), iView Property (photography), Dan Eden Photography, OVO Energy portal and FixFlo (maintenance reporting software), Communicorp (podcast), Yellow Productions (videography) and Zero Deposit Scheme;
   • We will also store our customer data within our management and data systems – PropCo, Veco, Qube and FixFlo.
   • If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
   • If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
     If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police, HMRC and the Information Commissioner’s Office;
   • If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

   Finally, your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

   Where your information will be held

   When we share your information, your information may be transferred outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

   • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
   • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

   Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

3. Your rights

   You have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.

   Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at [email protected] or in one of the ways provided in the Contact Us section at the end of this privacy notice.

   Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it to check that we are lawfully processing it.

   Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.

   Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

   Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

   Transfer: you may request the transfer of certain of your personal information to another party.

   Objection: where we are processing your personal information based on a legitimate interests (or those of a third party) you may challenge this. However we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

   Automated Decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

   More information regarding your legal rights in respect of personal information can be found at www.ico.org.uk/for-the-public/. You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

   COOKIES

   Cookies are small data files saved to your computer (or any other device capable of browsing the internet) as part of your interactions with a website.

   Cookies remain stored on your device until such a time that the cookie expires or is manually deleted. This allows for the information stored within the cookie to be sent back as part of any subsequent interactions you have with the issuing website. This exchange of information enables websites to remember basic information about you, such as whether you have visited the site before, whether you are “logged in” or to remember your recent searches.

   When you visit our website, we will place a secure cookie in your browser history, which will allow us to record your interactions with our website and the device, browser and IP address that you are using.

   If you do decide to make an enquiry, we will link the data information recorded from the website cookie to your personal information used in your enquiry. You can delete the cookie from your browser at any time.

   We also use HTML web storage to store information locally, such as search results and development locations, to improve our website performance. This can also be deleted by you from your browser at any time.

   HTML web storage provides two forms of storage:

   Local Storage – stores data with no expiration date

   Session Storage – stores data for a single session (data removed when the browser tab is closed)

   If you do not want us to use cookies when you visit our website, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Alternatively, you can find information about how to do this for all the commonly used internet browsers here: www.aboutcookies.org

   This website will also explain how you can delete cookies that are already stored on your device.

   Please be aware that if you set your computer to not accept cookies, there may be certain features/areas on our website that you may not be able to use.

   EVENTS & PHOTOGRAPHY/VIDEOGRAPHY

   Simple Life London may invite professional photographer(s)/videographer(s) to on site events. The photographs/video material may be used on Simple Life, Simple Life London, Sigma Capital and EQT Estates Management social media channels, websites, presentations and other brand related marketing materials, as well as those of certain third parties permitted by us, including those who have been involved with the event. We would use the photographs/video material on the grounds of our legitimate interests to share coverage from the event and to promote similar events to tenants in the future. We may share your photograph or video material featuring you with members of our group companies and/or select third parties but only in connection with the provision of services to us and/or for the operation and/or of promoting similar events.

   We may also provide copies of photographs and/or limited video material to attendees of the events, where such attendees feature in the photographs and/or video material (as applicable) and have requested a copy of the photographs/ video material. Such sharing would be undertaken on the grounds of our legitimate interests to engage with tenants and other event attendees or otherwise in response to a legal requirement to share such photographs/ video material with the relevant attendees.

   If you would prefer your photograph not to be taken or used, please do let us know either by emailing [email protected] or informing a Simple Life member of staff or the photographer at the event. We will take account of your preference where reasonable for us to do so. Please note that you are able to inform us prior, during or after an event has taken place, at any time. You should always email us even where you have advised a Simple Life staff member or photographer at an event.  Further we may require you to provide us with identifiable information (e.g. details of clothing worn on the day of the event) or photographic ID so that we can identify you in any photographs/video material.

   Rules of Attendance

   Simple Life Homes provide on-site events for entertainment purposes, for the benefit and enjoyment of our tenants.

   In order for these to be fully and safely enjoyed, we advise the below points are followed:

   • Where food or consumables are to be provided (as detailed in any event communications), we recommend tenants advise the Simple Life team ahead of time regarding any specific dietary requirements. Full ingredients can be made available on request. Where possible, allergies and intolerances will be taken into consideration
   • We advise that all under 18 attendees are accompanied by a parent or guardian at all times. Events will be held on-site, but these will include public areas including pavements. It is not guaranteed that roads will be closed for events, so please take care when attending and be aware of road and walkway users.
   • We’re delighted to sometimes have animals at our events, as an added element of fun for adults and children alike. This will always be disclosed in any event communications. Whilst they will always be managed by professional animal handlers, please do keep in mind that animals can be unpredictable. We advise small children are closely monitored so they are able to engage with the animals in a safe manner. If you have any questions or concerns, please contact the Simple Life team prior to the event.

   SECURITY

   We are committed to keeping your personal information safe. We’ve got physical, technical and administrative measures in place to prevent unauthorised access or use of your information. However, the Internet is an open system and we cannot and do not guarantee or warrant the security of any information that you transmit on or through our Website or that we otherwise maintain.

   CHANGES TO THE NOTICE

   This notice will be changed from time to time. If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

   If you would like to access previous versions of this privacy notice please contact us using the details in the Contact Us section.

   CONTACT US

   If you have any questions about this privacy notice please contact us: using [email protected] or at Simple Life London, 5 Compton Road, Wimbledon SW197QA.