The Project at Hoxton is managed by "Victoria Hall Management Limited". We believe that an individual’s right to privacy of their personal information is fundamental in today’s modern world. We are committed to ensuring that;
- The information we collect is relevant to enabling us to deliver and improve the award-winning services that we provide and for which we are known.
- The information we collect is stored accurately, securely and with your privacy being paramount.
- The information we collect will only be shared with selected third parties where it assists us in delivering our services or where we are required to share such information by law.
Our privacy notice explains in further detail what types of personal information we collect from you and how we will use it.
Who we are
Host is the student-facing brand for Victoria Hall Management Limited ("VHML") and Victoria Hall Management (UK) Limited ("VHM(UK)L"). VHML and VHM(UK)L manage a number of properties on behalf of a number of different owners. We manage the data in "joint-controllership" with such owners.
The joint-controller (building owner) will be defined in an Assured Shorthold Tenancy Agreement, a Licence to Occupy and/or any other similar documentation upon booking accommodation with Host. This information can be found under "Data Protection".
Personal information we collect
Host collects personal information to operate the properties that it manages effectively and to give our customers the best possible service. You provide personal information to us in a number of different ways – for example when you create an account/an application on our booking portal, directly to our reception staff, and when visiting our website (using online identifier technologies like cookies). We sometimes obtain data from third parties, for example, but not limited to, educational establishments, agents and through the transfer of ownership and/or management of a property to Host.
Host gives you choices about the data we collect, and when asked to provide personal data, you may decline. However, please note that if you choose not to provide the personal data that Host requires to enter into a contract with you, you will not be able to take up residence in any of the properties that we manage.
Depending on how you interact with Host, be it through a room booking or being a guarantor the data we collect may vary and can include the following:
Name and contact data. We will collect your first and last name, preferred name, email address, postal address, contact telephone number, and other similar contact data.
Credentials: We will collect your email address as your login credentials for the Host Online Portal. We will also store an encrypted version of your alpha-numeric password used to access the Online Portal.
Identification data: We will collect identification data such as a national identity card, passport, photograph and student ID.
Demographic data: We will collect personal data about you such as your age, gender, and nationality.
Medical data: We will give you the opportunity to provide personal medical data if you feel it is pertinent to your booking with us. We will also collect objectively observed medical data if pertinent to your interactions with us.
Usage data: We will collect data about your interactions with our business systems. For example :
- Online portal data: We will collect data about the pages, the order, the times and duration of pages visited. This includes any error or troubleshooting data that may be produced.
- Website data: We will collect data about the pages, the order, the times and duration of pages visited. We will also collect data about the location of the web user, an IP address, platform, device, and browser details.
- Key system data: If the property you occupy has smart card access technology (RFID), we will collect data about when you enter/leave the building, communal areas, your flat and/or your bedroom.
Financial: We will collect data about any transactions you make with Host and we will also collect financial history (such as proof of earnings, bank statements and similar documentation) in the guarantor application process. We will collect payment details to process payments online and via our receptions and may collect bank account details to process refunds.
Third Party Relationships: We will collect data about your relationships with third parties such as educational establishments, guarantors for accommodation, emergency contacts, nominated consents, and prospective/current roommates.
Content: We will store all the content that we have provided, or received from you, regarding your relationship with Host. This content may be in the form of an electronic message (“email”), instant-message, web-query form, Skype or any other applicable form of communication.
Closed-Circuit Television (CCTV): If you enter a Host property your image will be captured by CCTV cameras.
How we use your personal information
Host collects personal information to operate its business and to provide its customers with the award-winning services for which it is known. This can include using information to continually improve and personalise our products. We will use personal information to communicate with you regarding our accommodation services, employment applications, and to promote related Host services. We also collect personal information in order to comply with legal obligations, for the purposes of entering into a contract with you and the subsequent performance of that contract and where we have assessed that it is in our legitimate interests to do so.
Providing our service. We use personal information to provide, and continually improve, our services to you. This includes operating platforms (such as our booking system StarRez), maintaining and improving our accommodation services, analytics and providing excellent customer service.
- Providing Accommodation Services. We use your personal information to enable us to enter into the relevant documentation with you so that you can take up residence. This can be an Assured Shorthold Tenancy Agreement, a Licence to Occupy and/or any other similar documentation.
If provided, we will use your personal medical information to consider whether it is possible to make reasonable adjustments to the products and services that we provide to you.
- Customer Service. Our staff will use your information to assist with your application, stay and subsequent customer support queries.
- Service Improvement. We will use the information you have provided to continually improve our products and services. For example, we use error logs to constantly track and monitor the performance of our systems.
- Security. We will use your personal information as a means of security and to protect the safety of our systems and customers. For example, to detect fraud, we will ask all our customers to provide at least two forms of authentication before discussing personal information with them. We will also use some of our communication systems to detect malicious behaviour. For example, our Office 365 email solution will detect abnormal usage, spam, abuse, URLs that have been flagged as phishing or malware. As a result, we reserve the right to intercept and/or block any communication which violates our terms and conditions. If we have reasonable cause to suspect that a customer’s account has been compromised and appears to be actively targeting our systems, we will alert that customer using the details that have been provided.
- Operations. We will use information to develop and provide business analysis and intelligence to better enable us to make informed business decisions and to report on different aspects of our business. This information will be used to further improve the services we provide to you.
- Closed-Circuit Television (CCTV). We will use CCTV footage for crime prevention and to improve the safety and security of all persons present at the property.
Communications. We will use the information provided to communicate with you and to personalise these communications. For example, throughout the application process you will receive confirmations about the status of your booking and communications prompting any further action required to complete your booking. During your tenancy you may receive communications regarding our accommodation services which may include information about the property, events, surveys, and welfare. You can also opt-in to further Marketing-specific emails from Host and carefully selected third parties; see the "Marketing" section below for further information. You can manage your subscriptions via the "Privacy" tab on your Host Online Portal account.
Marketing. Host will, from time to time, market its products and services to both current customers and potential customers who have consented to receiving marketing communications.
- Current customers. We will market relevant selected offers and information to our current customers based on the products and/or services they have purchased in the past. We will only send relevant marketing to these customers where they have consented to receiving marketing communications. Customers can unsubscribe from such marketing at any time by clicking on the "unsubscribe" which is contained at the bottom of all marketing based emails. Please note that by unsubscribing this will not prevent you from receiving information regarding any products and/or services that are related to those you have already purchased.
- Potential customers. When a potential customer has shown an interest in the products and/or services that we provide, they will be able to opt-in automatically to receive such marketing information. If you wish to unsubscribe from such marketing all marketing related emails will enable you that to do so.
Our Marketing Department might from time to time receive interesting offers and information from third parties that we feel would be of interest to our customers. We will never provide your information to third parties for marketing purposes but we may send you information from them on their behalf where you have indicated a desire to receive marketing communications from us.
You can also ask us to stop sending you marketing messages at any time by logging into your Online Host Portal account and checking or unchecking relevant boxes in the “Privacy” module to adjust your marketing preferences or by following the opt-out links on any marketing-related message sent to you or by contacting us directly using the contact details contained in this notice.
Where you opt-out from receiving these marketing messages this will not apply to the personal data that you have provided to us as a result of a product/service purchased or any other transactions where legitimate grounds for our non-marketing related processing activities continue to exist.
Change of purpose
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for other reasons which are compatible with the original purpose. If you want us to explain how the processing for any new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for any unrelated purpose, we will notify you and we will explain the legal basis which permits us to do so or alternatively, if necessary, seek your consent.
Please note that we may process your personal data without your consent where this is required or permitted by law.
Reasons we share your personal information
It is important and necessary from time to time for Host to share your personal information. We will only do this with your consent or as necessary to provide the service that you have requested or authorised. We share information with vendors; when required by applicable law or in response to legal proceedings; to protect our customers; to maintain security and to protect Host’s intellectual property rights.
We may have to share your personal data with the parties set out below for the purposes set out in “How we Use Your Personal Information”.
- Internal Third Parties as set out below:
Other related companies acting as joint controllers and who are based in the EEA and undertake leadership reporting.
- External Third Parties who act as joint controllers or processors, including but not limited to:
- Service providers acting as processors based in the European Economic Area (EEA), the US, and Australia who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the EEA who require reporting of processing activities in certain circumstances.
- Third party guarantor providers acting as joint-controllers based in the United Kingdom who provide a guarantor service to students.
- Educational establishments acting as joint-controllers in agreements with VHML/VHM(UK)L based in the EEA to provide accommodation for their students.
- International agents acting as joint-controllers to refer and confirm customers to Host’s accommodation services.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to process it for lawful purposes only. We do not allow our third-party service providers to use your personal data for their own unrelated purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data outside the EEA we endeavour to ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information as to the specific way in which we transfer your personal data outside the EEA.
How we keep your information secure
Host has a regimented approach to privacy and information security. We have developed internal measures to ensure personal information is processed on an "as needed basis". We endeavour to have in place appropriate technical and organisational measures to protect your information. When sharing your information with third parties we will ensure that these parties conform to our information security standards, as highlighted in the "Reasons we share your personal information" section. We carry out regular personal information audits on all of the properties we mange including the staff and third-parties.
We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we keep your personal information for
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, and to comply with any legal, accounting, or reporting requirements.
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 having regard to any applicable legal requirements.
By law we have to keep basic information about our customers including Contact, Identity, Financial, Contractual and Transaction Data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see "Other important information" below for further information.
Also in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Host Online Portal Account
We believe that access to, and amendment of, your personal information is important. All customers with an account with Host can amend some of their privacy settings and check that the personal information we have on file is correct. You can find this facility under "Privacy" on the Host Online Portal.
Other important information
In this section you will find important additional information regarding your rights under applicable Data Protection law and useful contact information.
Host is committed to adhering to all applicable data protection law in the UK and in the European Economic Area (EEA), which , if relevant, includes the following 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 processing it lawfully.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected although 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 to continue to retain 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). This could be where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 your personal data where we are relying on a legitimate interest (or those of a third party) but your particular situation makes you want to object 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 transfer to you, or a third party you have nominated in writing, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you confirmed we could use in the first place or where we used the information to 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 or in relation to the continuing processing of your personal data for non-consent based reasons (e.g. to comply with a legal obligation and/or relating to ongoing provision of services to you). 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 when you withdraw your consent.
You have a right to complain to us by emailing us at [email protected] or to lodge a complaint with the data protection supervisory authority. Host’s nominated data protection supervisory authority in the EEA is:
Information Commissioner’s Office UK
Other important supervisory authority contacts are:
Irish Data Protection Commissioner