Privacy Notice

This Privacy Notice was last changed on 12^th September 2024.

Who we are & how to contact us

This is the privacy notice of Sigma Capital Group Limited (03942129) and the companies within our group from time to time (the “Sigma Group”), which includes the following:

Company Name

Company Number

Registered Office Address

Sigma Capital Group Limited

03942129

dataprotection@sigmacapital.co.uk

Floor 3, 1 St. Ann Street, Manchester, England, M2 7LR

Sigma Capital Property Ltd (trading as ‘Simple Life’ and as manager for London BTR Investments LP trading as “Simple Life London”) together being “Simple Life”)

SC219919

slmarketing@simplelifehomes.com

18 Alva Street, Edinburgh, Scotland, EH2 4QG

Sigma PRS Management Ltd (in its capacity as investment adviser to The PRS REIT plc)

10615738

Floor 3, 1. St. Ann Street, Manchester, England, M2 7LR

Simple Life Management Limited

15472750

Floor 3, 1 St. Ann Street, Manchester, England, M2 7LR

A list of companies within the Sigma Group is available on request. This privacy notice is issued on behalf of the Sigma Group, so when we mention “we”, “us”, or “our” in this privacy notice, we are referring to the relevant company in the Sigma Group responsible for processing your data. Where information is only relevant to one member of the Sigma Group, we will make this clear in the relevant sections below. Otherwise, the information provided in this privacy notice applies to all members of the Sigma Group.

Sigma Capital Property Ltd is responsible for www.simplelifehomes.co.uk and www.simplelifelondon.co.uk, and Sigma Capital Group Limited is responsible for www.sigmacapital.co.uk and in each case are the data controller for personal data processed through your use of the respective websites. Please refer to the respective sections within this privacy notice for further information about how we process your personal data depending on the website you are accessing.

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.

For Sigma Capital Group, this privacy notice applies to you if you are a director or shareholder of the entities within the Sigma Group, a tenant, represent one of our customers or suppliers, or accessing our website.

For Simple Life, this privacy notice applies to you if you are a tenant, or an applicant to be a tenant, using our Simple Life services, or accessing our website.

If you have any questions or anything in this notice is unclear, please get in touch with us using the contact details for the respective company provided in the table above.

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 our websites or for use of our other services for the purposes set out in more detail in this section. Your information may be shared with members of the Sigma Group and with some third parties.

	What we collect	How we use it (our purpose of processing)	Our lawful basis for using it	How long we keep it for
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 name and contact details; – The details of your communications with us; – The details of our messages to you.	We use this information to: – Answer any issues or concerns; – Provide you with the information and services you request from us; – For Sigma Capital Group, allow our Sigma 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 – For Simple Life, allow our Sigma 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 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.	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. For Simple Life, following an enquiry we may contact you regarding homes or developments that are deemed relevant to you based on legitimate interest. In accordance with UK GDPR, you have the option to opt out at any time.
2	Technical 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 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 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	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 group companies, affiliates or our third party partners (such as estate agents or tenancy management partners). This information shall include: – identity information including name, national insurance number, photographic ID, marital status, data of birth, age, gender, family information and occupation; – contact details including home address, email address and telephone numbers; – financial information including salary, bank account details and payment details; – details of any rent arrears and other lease and tenancy information; and – your preferences in receiving marketing from us and our third parties. This information relates to tenancies in respect of properties of which we or our group companies or affiliates are the landlord or in respect of which Simple Life Management Limited are the managing agent. We also receive this information from our third party managing agents. In particular we receive information from Ascend Estates Limited, Direct Lettings (Scotland) Limited and Kinleigh Folkard and Hayward (KFH), (and their partners). Ascend Estates Limited, Kinleigh Folkard and Hayward Direct Lettings (Scotland) Limited are 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.ascendproperties.com www.kfh.co.uk/privacy-policy and www.dlscotland.com	We use this information to: – Carry out credit checks (or enable our partners to carry out credit checks); – Provide our services; – Manage tenants and tenant applications; – Conduct 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 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; – To perform the tenancy contract.	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 from publicly available information sources such as: – Companies House; – social media; and – community forums.	We use this information to: – Maintain market awareness; – Answer any issues or concerns.	– We have a legitimate business interest in maintaining a public profile; – We have a legitimate business interest in understanding customer feedback and in responding to customer communications in a consistent way.	– For as long as the information is publicly available; – 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 incidentally from the operation of CCTV and other security measures.	We use this information to keep our premises and assets secure and protect our employees, tenants, premises, and assets from crime.	– We have a legitimate business interest in providing security over our business, premises, assets, employees and tenants; – To establish, exercise or defend legal claims	– For a limited period of time in accordance with our retention policy; – In the event that data is supportive of an investigation, legal claim or action we will retain it for as long as necessary in the exercise of this and then we will delete it once the retention is no longer necessary.
6	Information that we collect from individuals representing organisations such as our customers and suppliers, including: – Names and corporate contact details; – Other corporate information regarding such individuals, such as job roles.	We use this information to: – Build relationships with other organisations; – Administer our relationships with organisations that we do business with.	– 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; – To perform the contract with our customers and suppliers.	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.
7	Information that we collect from individuals attending events hosted at our premises including: – Photographs of our event attendees taken at our events; – We may collect certain contact details of attendees at events.	We use this information to: – Share information (including photographs and video material) of the events we host within our group of companies and with our tenants and prospective tenants and event attendees; and – Promote future events with assistance from select third parties.	– We have a legitimate business interest in promoting our events and tenancy services. – We have a legitimate interest in engaging with attendees at events. – Where we have the consent of the relevant attendees. – Where we have a legal obligation to share such information.	A reasonable length of time which allows us to share information about our events and promote future events.
8	Where you are a shareholder, when you communicate with us in relation to a shareholding, you may provide us with, or we may otherwise collect personal information, such as: – personal contact details including names, addresses, telephone numbers, and personal email addresses; – bank account and payment details; – shareholder account information; – identification documentation, such as your passport; – shareholding records (including shares held, share purchases, share disposals, dividend entitlements and payments, votes, proxy appointments); – other communications with you. We will collect personal information from a number of sources. These include: – Directly from you when you complete forms, use our website, provide documentation to us or communicate with us; – Third parties authorised by you; – Your and our professional advisors: such as share registrars, lawyers, accountants, financial advisors; – Our brokers who carry out know your customer checks; – Credit reference agencies, money laundering check providers; – Government bodies, the Police or law enforcement and our regulators.	We use this information to: – Administer the shareholding (directly with you or through your or our representatives), including maintaining shareholder records, making shareholder announcements, providing shareholder communications (including the provision of reports and accounts), receiving money and/or making payments (such as in respect of dividends and share sale proceeds) and dealing with enquiries, complaints and other communications. We will also use your personal information for: – dealing with any legal disputes; – complying with any regulatory requirements; – retaining records relating to the Sigma Group and the shareholdings in it.	– To perform and administer our contract with you regarding a shareholding; – To comply with any legal obligations and regulatory requirements; – For our legitimate interests, such as the maintenance of up to date shareholder records and the efficient handling of queries, complaints and other communications; – To establish, defend or bring legal claims.	The duration in which you are a shareholder and for a reasonable period of time thereafter to comply with applicable law.

Direct Marketing

If you are a tenant, Simple Life 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 the details set out in the contact us section above.

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: Simple Life

If you are a tenant, the relevant managing agent will make automated decisions regarding you in the following situations: credit checks and background checks relating to a tenancy. These may be undertaken by us or by third parties acting on our behalf, such as Simple Life Management Limited, Ascend Properties, Kinleigh Folkard and Hayward or Direct Lettings (Scotland) Limited who in turn use third parties, including Let Alliance (www.letalliance.co.uk), Canopy (https://www.canopy.rent/), Callwell (https://callwell.co.uk/privacy-policy/) or HomeLet www.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.

Automated Processing: Sigma Group

Other than the automated decisions required for the services provided by Simple Life (as mentioned above), Sigma Group does not make automated decisions regarding you.

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 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.

For Sigma Capital Group, if you do not provide us with the requested personal information, we may not be able to progress our dealings with you, including with respect to any shareholding in the Sigma Group.

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 among members of our group of companies so we can provide the best service across our group. Each Sigma Group member is 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 Simple Life Management Limited (part of the Sigma Group), Ascend Properties, Kinleigh, Folkard and Hayward and Direct Lettings (Scotland) Limited, who provide tenant management services for us. Ascend Properties, Kinleigh Folkard and Hayward and Direct Lettings (Scotland) Limited are data controllers of your information and you should refer to their policies for details on how they collect, hold, use and share your information. They can be found at: www.ascendproperties.com, www.kfh.co.uk and www.dlscotland.com. Where we are a manager upon behalf of a third party we may share certain information with them, relating to the properties in respect of which we manage on their behalf;
Solicitors and professional services firms who provide us with legal support in relation to our services or any legal claims;
We may also share your information with contractors and service providers, including those who provide and help operate our IT and back office systems and provide us with communications services. 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; and
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.

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

Investors on whose behalf Sigma Group manages relevant properties
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 UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (“adequate country“); or
If we transfer your personal data to service providers who are not located in an adequate country, we will agree specific standard contractual terms approved by the UK Government or the ICO which give personal data the same protection as it has in the UK.

Please contact us using the details in the contact us section above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

How long your information will be held

We will keep your data for as long as it is reasonably necessary, depending upon the type of information and the reason why we collected it from you. It will depend on a number of factors. The criteria we may use to determine the retention period for certain categories of data includes:

whether there is any ongoing contractual, legal or financial claim that relates to your relationship with us; and
whether any applicable law, statute, or regulation allows for a specific retention period; and
what the expectation for retention was at the time the data was provided.

Generally, where there is no legal requirement we will retain physical and electronic records for a period of 6 years after your dealings or communications with us, for the eventuality of any legal dispute arising out of them.

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 using the details in the Contact Us section above.

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 (commonly known as a “subject access request”). 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 interest (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.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) (Tel: 0303 123 1113 or at www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.

More information regarding your legal rights in respect of personal information can be found at www.ico.org.uk/for-the-public.

4 Cookies

We use cookies that identify your browser or device. They collect and store information when you visit our website about how you use it. For more information about cookies, the types of cookies we use and how we use them please see our Cookies Notice.

5 My Simple Life Mobile App Privacy Policy

To view the My Simple Life Mobile App Privacy Policy visit: www.simplelifehomes.co.uk/my-simple-life-app-privacy-policy/

6 Events and Photography/Videography

Simple Life may invite professional photographer(s)/videographer(s) to on site events. The photographs/video material may be used on Simple Life and Sigma Capital 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 slmarketing@simplelifehomes.com 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.

7 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, and to prevent your personal data from being accidentally lost, 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. 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8 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 above.