If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
Collection of your Personal Data
We collect the following categories of Personal Data about you when you use or otherwise interact
with our Services:
- Email address
- Home/work/mobile telephone number
- Postal or other physical address
- Employment details and status
- Indications of your credit profile as made by you
- Indications of your criminal record as disclosed by you
- Whatsapp profile information (when you use Whatsapp and our community app to communicate in our groups and directly with representatives of Exclusive Rooms)
- Passport and/or photo identification
We collect and/or process your Personal Data in connection with the below activities related to our Services:
- Application process
- Setting up Whatsapp and community app groups
- Billing and collecting payments for our Services
- Newsletters and mail-merge type communications about your tenancy
- Creating legal documents relating to your tenancy
- Providing a statement of fact to other prospective landlords/agents of your choice detailing your performance during the tenancy
Processing of your Personal Data
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your tenancy with us that allows us to provide you with the Services) and our “legitimate interests” such as:
- Personalizing, improving or operating our Services and business
- Better understanding your needs and interests
- Fulfilling requests you make related to the Services
- Providing you with information and offers from us or third parties
- Complying with our legal obligations, resolving disputes with users, enforcing our agreements
- Protecting, investigating and deterring against fraudulent, harmful, unauthorised or illegal activity
- To meet contract or legal obligations
If you choose to use our referral service to tell a friend about our products, you represent that you have their consent to provide us your friend’s name and email address.. Unless we are authorized by your friend, we will only use your friend’s name, phone number and email address for the purposes of sending this one-time email and maintaining an activity log of our referral program.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain elements of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Services.
- Right to File Complaint: You have the right to lodge a complaint about Exclusive Rooms’ practices with respect to your Personal Data with the supervisory authority.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data. In the course of our usual service delivery we will retain your information throughout the tenancy, and for 5 years after your tenancy has ended to comply with money laundering regulations.
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information
about your device such as operating system and user identification information.
Sharing your Personal Data
We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We share Personal Data within Zoom and its affiliated companies, and with third party service providers such as G Suite for business for purposes of data processing or storage.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process
by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Exclusive Rooms terms of service, the tenancy agreement or as otherwise required by law.
Security of your Personal Data
Exclusive Rooms is committed to protecting the Personal Data you share with us. We utilise a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When communicate with you via email, Whatsapp and also when uploading your data to our cloud storage facility we use a Secure Sockets Layer (SSL) technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at firstname.lastname@example.org
Linked websites and third party services
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.
If you participate in a Whatsapp group, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Whatsapp, who have access to that discussion forum or chat room. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Exclusive Rooms.
Transfer and Storage of Personal Data
Your data is hosted and operated both at Exclusive Rooms headquarters in physical copy and/or via Google’s secure cloud business storage solutions. We may transfer your Personal Data to any Exclusive Rooms affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage, such as software companies, for the purpose of delivering our Services. By using any of our Services or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party.
You can also contact us by writing to this address:
Exclusive Rooms Ltd