WEBSITE PRIVACY POLICY – CITY (SCOTLAND) LIMITED

1. Introduction

   1. Welcome to Citylets’ privacy notice in relation to our website at www.citylets.co.uk and related Apps (“Website”).
   2. This privacy notice is issued on behalf of City (Scotland) Limited ("we", "us" or "our"), a company incorporated under company number SC475222 and have our registered office at Q Court 3 Quality Street, Davidson's Mains, Edinburgh, EH4 5BP.
   3. This privacy notice will inform you about what data we collect from you, how we use it, circumstances where we may disclose this data to others and how we keep it secure.
   4. We take the issue of security and data protection very seriously and strictly adhere to applicable data protection legislation. In accordance with the General Data Protection Regulation (EU) 2016/679 we are data controller of any personal data that you provide us.
   5. Any questions relating to this policy and our privacy practices should be sent to The Data Compliance Manager, Citylets, 21 Lansdowne Crescent, Edinburgh EH12 5EH or email us at info@citylets.co.uk

2. How we collect Information from you

   1. We collect and process your personal information in the following ways:
      • you may give us information about you via our Website. This may include information you provide when you contact us via the Website, indicate your interest in a property or agent, or register with us for an account or service;
      • you may give us information by corresponding with us by mail, text, e-mail or other form of electronic communication, telephone or in person;
      • we may receive personal data about you from third parties and public sources;
   2. This Website is not intended for children and we do not knowingly collect data relating to children.
   3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

3. What information we collect

   1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).
   2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
      • Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, employment status ;
      • Contact Data: includes current address, previous addresses, email address, social media addresses and telephone numbers;
      • Financial Data: may include annual income and payment card detail;
      • Technical Data: includes 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 the devices you use to access this Website;
      • Usage Data: includes information about how you use our Website, products and services;
      • Profile Data: includes your username and password, searches made by you, preferences, feedback and survey responses; and
      • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preference.

4. Why we need this information about you

   1. We will only use your personal data when the law allows us to. We use the information we collect about you:
      • to enable us to perform the contract we have entered with you, including provision of the services;
      • to help us with understanding more about how our Website is used;
      • to be able to send you communications that may be of interest to you (such as property details pursuant to registering for property alerts), either electronically, by email, by text or otherwise;
      • to be able to respond to your query;
      • if required to comply with a legal or regulatory obligation;
      • if necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
      • if needed to protect your interests (or someone else's interests);
      • for all other purposes consistent with the proper performance of our operations.
   2. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
   3. We usually do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. Marketing

   1. It is your choice whether you receive information such as Citylets news, market updates or commercial offers from us. If you indicated that you are interested in receiving regular information, we may send you communications electronically or by post. We will not contact you for marketing purposes unless you have given your prior consent. If, at any time, you no longer wish to receive this information, please send a written request to info@citylets.co.uk
   2. All of our email marketing correspondence gives you the option to opt-out of receiving further marketing emails. Please note that you will still receive emails directly related to an enquiry you raised with us or a service or account you registered for.

6. Cookies

   1. We use cookies, pixels and tags (collectively “Cookies”) on our Website in order to help improve our Website and provide you with a more personalised web service. For further details please see our Cookies Policy www.citylets.co.uk/cl/cookies

7. Data security

   1. Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk.
   2. 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.
   3. 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. Sharing of your information

   1. The information you provide to us will be treated by us as confidential. However, through the provision of our services we will disclose your information to property agents and landlords, directly in relation to the properties or agents in which you indicate an interest.
   2. We will only disclose your information to our suppliers or service providers where this is necessary to perform the service requested by you.
   3. We require all third parties to respect the security of your personal data and to treat it in accordance with data protection legislation.
   4. If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

9. No transfers outside the EEA

   We will not transfer your personal data outside of the European Economic Area (EEA).

10. How long we will keep your information

    1. We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

11. Your rights

    1. Under Data Protection legislation, you have the following rights in connection with your personal data, which can be exercised at any time:
       • Right of access: you can request a copy of the personal information we hold about you.
       • Right to rectification: you can request that any incomplete or inaccurate information we hold about you is corrected;
       • Right to erasure: you can request that we delete your personal information where there is no good reason for us to continue to process it. You must provide valid reasoning for your request. This can be exercised in conjunction with the right to object (see below);
       • Right to object: you can object to our processing of your personal information where we are processing on the basis of our 'legitimate interest'. We shall cease processing your personal data unless there are compelling and legitimate grounds for processing which override your interests;
       • Right to restrict processing: you can request that we restrict our processing of your personal information. Information will be retained but not further processed;
       • Right to data portability: where processing of personal data is carried out by automated means, you can request the transfer of your personal information to another party;
       • Right to withdraw consent: where we are processing your personal data on the basis of consent, you have the right to withdraw your consent at any time; and
       • Right to complain: you have a right to lodge a complaint with a Supervisory Authority, which is an independent public authority established in each EU member state in accordance with Data Protection Legislation. The Supervisory Authority for data protection issues in the United Kingdom is the Information Commissioner's Office (ICO).
    2. If you would like to exercise any of your rights above, please contact us at info@citylets.co.uk
    3. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. In the United Kingdom, the Information Commissioner's Office can be contacted via their website - www.ico.gov.uk.

12. Third party websites

    Because we want your experience of our Website to be as informative and useful as possible, we may provide links to websites operated by third parties ("Third Party Websites"). Please be aware that we do not control such Third Party Websites and that such Third Party Websites may send their own cookies to users, or otherwise collect data or solicit personal information. We assume no responsibility for the information gathering practices of Third Party Websites that you are able to access through our Website, and we encourage you to review each Third Party Website's privacy policy before disclosing any personally identifiable information.

13. Changes to our privacy policy

    Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

14. Your duty to inform us

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

15. Contact us

    If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at info@citylets.co.uk