MY SIMPLE LIFE
APP PRIVACY POLICY

Last updated: 25th August 2023

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described below.

1. Introduction

Welcome to the My Simple Life App Privacy Policy.

Your personal information is collected by ThinkEQ LTD (ThinkEQ), as the operator of the My Simple Life mobile application, on behalf of Sigma Capital Properties Limited. Sigma Capital Property Limited (trading as ‘Simple Life’) is a company registered in Scotland under company number SC219919 and having its registered address as 18 Alva Street, Edinburgh, Scotland, EH2 4QG (Simple Life, we, us, our). Sigma Capital Properties Limited is the “data controller” in relation to your personal data.

We respect your privacy and are committed to protecting your personal data. This policy (together with our end-user terms (End User Terms) and any additional terms of use incorporated by reference into the End User Terms, together our Terms of Use) applies to your use of:

• the My Simple Life mobile application software (the App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device); and
• any of the services accessible through the App (Services), unless the End User Terms state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

If you have any questions in relation to our use of your personal information or this Privacy Policy, please contact us using the contact details given at Section 13 (Contact us) below.

The App is not intended for children. We do not knowingly collect data about children. If you become aware that we may have been given data about a child, please contact us as soon as possible.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: your full name, title, username or similar identifier;
• Contact Data: your address, billing address, email address and telephone numbers;
• Financial Data: bank account and payment card details;
• Transaction Data: details and records about payments to and from you and other details of services you have purchased from us or otherwise made use of in the App, including data collected in the App when using the meter readings service;
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on your Device;
• Profile Data: this includes your username and password, your interests, preferences, feedback and survey responses;
• Usage Data: information about how you use our App and services; and
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
• Contribution Data: any messages or images that you upload to the ‘Forum’ section of the App or that you may contribute to Simple Lifestyle and any other content that you upload or contribute that includes your personal data such as your opinions or experiences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. You should not include such information in any content uploaded to the Forum or contributed to Simple Lifestyle.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms on the App or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • download the App;
  • create an account on the App;
  • make payment of sums to us using the App;
  • request marketing to be sent to you using the App;
  • enter a competition, promotion or survey on the App;
  • give us feedback or contact us through the forms available in the App;
  • upload content to the ‘Forum’ section of the App; or
  • contribute content that includes your personal data to Simple Lifestyle.
• Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
  • Identity Data, Contact Data, Technical Data, Profile Data, Usage Data from Think EQ, our digital creative agency vendor and provider of the software infrastructure and platform supporting the App;
  • Identity, Contact and Transaction Data from our managing agents, Ascend Estates LTD (Ascend) or Direct Lettings (Scotland) Limited (DL)– Ascend or DL is the 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: ascendproperties.com and www.dlscotland.com);
  • Identity, Contact and Transaction Data from our online property rental management and lettings software provider, PropCo;
  • Technical Data from the following parties:
    • analytics providers (including Google Analytics provided by Google, who are based out with the UK)
    • advertising networks; and
    • search information providers;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services (including our payment services provider, Stripe Payment Europe, Limited);
  • Identity Data, Contact Data, Technical Data, Profile Data, Usage Data from the Apple App Store and Google Play store; and
  • Identity and Contact Data from publicly available sources (such as the media and information collected by security systems).

Simple Life may supplement the information that you provide to us, or which we are given, with information that we receive or obtain from other sources, such as from our professional advisors, partners, and agents of Simple Life, third parties with whom we interact, and publicly available sources.

4. How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data using the App although we will always get your consent before sending third party direct marketing communications to you outside of the App via email or text message using personal data processed on the App. You have the right to withdraw consent to such marketing at any time by contacting us.

5. Purposes for which we use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data and which legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

6. Change of Purpose

We will only process your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Disclosure and transfer of your personal data

We may share your personal data with the third parties set out below for the purposes set out in the table at Section 4 (How do we use your personal data?) above:

• our property management agency (Ascend or DL) who will process your data in order to manage your tenancy with Simple Life;
• Ascends’ payment solutions provider (Opayo) and DL’s provider (Stripe) who will process your data on their behalf to process any payments that you make using the App
• ThinkEQ who operate the App on our behalf;
• our other vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as our property management agency, rental management and lettings software providers, IT service providers, software development and hosting providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used by us in the conducting our business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
• our professional advisors (e.g. lawyers, accountants, auditors, etc);
• third parties to whom we are required to transfer personal data by law, such as law enforcement bodies, governmental and regulatory bodies, the courts and other competent authorities that may request personal data in connection with any inquiry, court order, or other legal or regulatory procedures which we would need to comply with;
• third parties to whom we share personal data to establish or protect our legal rights, property or safety, or the rights, property or safety of others, or to defend against legal claims;
• other members of our group of companies so we can provide the best service across our group (those members of our group are bound to keep your information in accordance with this Privacy Policy);
• investors on whose behalf Sigma manages relevant Simple Life properties (including the PRS REIT Plc and PineBridge Penson Elliot); and
• any third party connected with business transfers; we may transfer your personal data to third parties, in connection with a reorganisation, restructuring, merger, acquisition, or transfer of our business or assets, provided that the receiving party agrees to treat your personal data in a manner consistent with data protection law.

8. International transfers

We will transfer the personal information we collect about you to countries outside the United Kingdom and/or European Union in order to perform our contract with you and for the legitimate interests identified above in Section 4 (How do we use your personal data?). In certain cases, there will not be an adequacy decision by the United Kingdom authorities and/or the European Commission in respect of those countries. This means that the countries to which we transfer your data may not be deemed to provide an adequate level of protection for your personal information.

However, where those countries are deemed not to provide an adequate level of protection, to ensure your personal information is properly protected in line with UK and EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation, or any equivalent clauses approved by the authorities in the United Kingdom.

We may also rely on any other international transfer mechanisms that are available to us under UK and/or EU data protection law to ensure that the transfer of your personal data outside of the United Kingdom and/or European Union will comply with applicable data protection laws.

If you would like to obtain copies of the regulator-approved Standard Contractual Clauses or further information on any other international transfer mechanism used by us please contact us at the details given in Section 13 (Contact us) below.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

10. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

In some circumstances you can ask us to delete your data (please see Section 11 (your legal rights) below for further information).

11. Your legal rights

Under data protection law, you have certain rights in relation to your personal data. Please note that many of these rights are not absolute, and we may have grounds for refusing to comply with your request to exercise them (for example, where we are (a) required or permitted by law to process your personal data in a way that is incompatible with your request, or (b) able to rely on exemptions under data protection law which entitle us to process your personal data in a way that is incompatible with your request). Where such circumstances apply, we will inform you of this at the time you make a request to exercise your rights.

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you don’t want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
• What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or access someone else’s personal data on their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Third-party links

This App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App we encourage you to read the privacy policy of every website you visit.

13. Contact us

If you have any questions in relation to this Privacy Policy, including any requests to exercise your legal rights (or someone else’s legal rights on their behalf), please contact us using the details below:

Data Protection, Simple Life Floor 3, 1 St Ann Street, Manchester, M2 7LR

Email: slmarketing@simplelifehomes.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (Tel: 0303 123 1113 or at www.ico.org.uk). Alternatively, you can also make a complaint to the supervisory authority in the Member State of the European Union in which you are resident. We would however appreciate the chance to deal with your concerns before you approach the ICO or a supervisory authority, so please contact us in the first instance.

14. Keeping your information up to date

To help Simple Life keep accurate information, you must tell us about changes to information or personal details relating to you, in particular, any changes to contact or financial details. If you know that Simple Life holds any personal details about you that are out of date or inaccurate, please let us know as soon as possible by contacting us on the details in Section 13 (Contact us) above.

15. Notification of changes

Simple Life may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. We may do this by updating this Privacy Policy on our App and on our website, or providing you with notice of the updates by email or through our App. However, the last update date is given at the start of this Privacy Policy, and we encourage you to review this Privacy Policy periodically so you remain informed of how we use your personal data.