Privacy Policy

At Vita Student Management Ltd, we take privacy seriously and are committed to protecting your personal information.

This policy explains when and why we, and companies in our Group, collect personal information. It also explains how that information is used, the circumstances in which it may be shared with others, and how it is kept secure.

In this policy, “Group” means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, as defined in section 1159 of the UK Companies Act 2006. It may also include other companies that are closely associated through our management control, even if they are not technically group companies.

This policy applies to individuals who are customers, prospective customers, former customers, users of our website, social media channels and the Vita Student app, as well as other individuals who may be connected to them.

This policy may change from time to time, so please check this page periodically to make sure you are aware of any updates.

This policy was last updated in May 2024.

Who we are (data controller)

Vita Student Management Limited (company registered number 08540975), whose contact details are included in the “Contact us” section below, is referred to throughout this document as “Vita Student”. Vita Student is the data controller in relation to the processing activities described below. This means that Vita Student decides why and how your personal information is processed.

This policy also covers certain other Group companies or closely associated companies under the same management control, which are listed in Schedule 1 to this policy.

Whenever you deal with one of these companies, Vita Student will be the controller of your personal information. Where this policy refers to “we”, “our” or “us”, unless stated otherwise, it means Vita Student or the particular Vita Group company that is the controller of your personal information.

A “controller” is an organisation that decides why and how your personal information is processed.

We provide student accommodation services at certain buildings as a processor on behalf of the owner of those buildings (“Relevant Buildings”). The owner of the Relevant Building is the controller in respect of your personal data where it is processed for the purpose of providing student accommodation services at those buildings.

The Relevant Buildings owner’s full privacy policy, including details of how they process your personal data and how to exercise your rights, can be found at the bottom of this page.

How we collect your information

We collect personal information from you in the following ways.

Personal information you give to us

This is information that you provide to us directly, for example by:

• visiting our website at www.vitastudent.com
• using our web or mobile applications, including online chat
• viewing or following our channels on social media platforms
• posting your own content on social media and tagging our account
• corresponding with us by phone, email, direct message via social media, or otherwise
• attending one of our organised or sponsored events
• making an expression of interest at a campus fair or accommodation event run by your university or college

This information is provided voluntarily.

It includes information you provide when registering to use our site, expressing an interest in making a booking, subscribing to services we provide through our websites and other channels, requesting further information or associated services, or managing your personal details.

It may also include documentation you access, correspondence with us by phone, email or otherwise, and information you provide if you complete surveys that we use for research purposes.

The information you give us will typically include your name, address, email address, phone number(s), age, date of birth, details of your enquiry, details of your course of study, records of correspondence, and responses to marketing campaigns.

Personal information we collect about you

We may collect information about you either automatically or on request. This may include your contact details, geographic and demographic information, preferences, interests and other information you provide through your attendance at events, your survey responses, and your use of our website and app.

This may also include information about the resources you access.

We may automatically collect technical information, including anonymous data collected by the hosting server, the Internet Protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Please see our Cookies Policy for further information.

We may also collect personal information that you allow to be shared from your public profiles on third-party social networks, including your preferences, interests and other behaviours.

Personal information we may receive from other sources

We may obtain certain personal information about you from sources outside our business. These may include Group companies, where you have previously provided details to them, or third-party companies where you have previously consented to your personal information being shared in accordance with their privacy policies.

The personal information we receive from these sources is typically your contact details, certain demographic information, and may also include details of information you have previously requested or preferences you have previously expressed concerning specific areas of interest.

Types of personal information we process about you

We may process a range of personal information about you. To make this easier to understand, we have divided it into categories below and included a short explanation of what each category typically covers.

• Basic contact and identification details, such as name, address, phone number, email address and date of birth*
• Behavioural information, such as your activities, actions and behaviours
• Biographical information, such as your academic background and course(s) of study
• Geo-location information, which contains or reveals the location of your electronic devices
• Access detection information, which allows us to determine periods of occupancy and non-occupancy in your accommodation
• Health and safety information, such as details of your travel into the UK and/or your vaccination status, as well as next-of-kin details for emergencies
• Identification information contained in a formal identification document, such as your passport*
• Images, for example your likeness captured in CCTV footage or photography carried out in our buildings or at events you attend
• Banking / billing information used to collect payments from you or return money owed to you, including information relating to the provision of credit to you*
• Fraud information relating to the occurrence, investigation or prevention of fraud
• Legal information relating to legal claims made by you or against you, or the claims process*
• Booking transaction information relating to accommodation bookings and ancillary services provided to you*
• Correspondence information contained in our communications with you about our products, services or business

*For student residents living in the Relevant Buildings, the Relevant Buildings owner is the data controller in respect of the processing of your personal data for the purpose of providing student accommodation services for those buildings. The Relevant Buildings owner’s privacy policy can be found at the bottom of this page.

How we use your personal information

The purposes for which we use your information, and the legal basis under data protection laws on which we rely, are explained below.

Where there is a legal requirement

We will use your personal information to comply with our legal obligations. This may include assisting a public authority, industry regulator or criminal investigation body, correctly identifying you when you contact us, verifying the accuracy of data we hold about you, and responding to regulators or other legal obligations.

Where it is required to complete or comply with a contract*

We may use and process your personal information where we have sold you a product, supplied you with services, arranged for another party’s products or services to be supplied to you as their appointed agent, or where you are in detailed discussions with us about the sale or purchase of a product or service.

We will use this information in connection with ensuring that the terms of the relevant contract(s) are entered into or carried out.

This may include circumstances in which we are not a party to the contract ourselves but have been appointed to administer or provide services relating to that contract.

For the purpose of this section, a “contract” will typically mean a sale and purchase agreement, lease, or management services agreement. Please refer to the section “Types of personal information we process about you” above for details of the types of personal information we process for these purposes.

*For student residents living in the Relevant Buildings, the Relevant Buildings owner is the data controller in respect of the processing of your personal data for the purpose of providing student accommodation services for those buildings. See the Relevant Buildings owner’s privacy policy here.

Where we have assessed there is a legitimate interest

Where applicable data protection laws permit, we may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or the legitimate interests of a Group company or another third party, for the following purposes:

• to correspond or communicate with you generally, for example with company or location news
• for marketing activities, other than where we rely on your consent to contact you by email or text with information about our products and services, or to share your details with third parties for the same purpose
• to use photography, sound and video recordings of events and experiences you may voluntarily participate in while living in our accommodation, for the purpose of promoting our accommodation experience generally
• to enhance your experience of your accommodation, including running promotions and competitions that you may be entered into automatically, subject to your right to opt out at any time
• for analysis to inform our future marketing strategy and/or enhance or personalise your customer experience
• to verify the accuracy of data we hold about you and create a better understanding of you as a customer or potential customer
• for building security and performance, including monitoring occupancy levels and patterns, and the use of CCTV monitoring in and around communal spaces in our buildings
• for network and information security to protect your information against loss, damage, theft or unauthorised access
• for the prevention of fraud and other criminal activity
• to comply with a request from you in connection with the exercise of your rights, for example where you ask us not to contact you for marketing purposes
• to review facts and improve our service to customers through recordings of calls with our offices
• for the management of any queries, complaints or claims you bring
• for running our business and maintaining appropriate websites, records and service administration
• as may be necessary in connection with the corporate acquisition or disposal of a building
• for the establishment and defence of our legal rights

If you are physically located within Mainland China when we collect your personal information, our use and processing of your personal information may be subject to certain Chinese data protection law requirements.

In those circumstances, we will not rely on the lawful basis of “Legitimate Interests” to use or process your personal information. Instead, for each use of your personal information for which the lawful basis is indicated as “Legitimate Interests”, we will rely on your consent. In such cases, we will not use or process your personal information unless you have consented.

Where you have provided consent

We may use and process your personal information on the basis that you have consented for us to do so, for the following purposes:

• to contact you via email or SMS with marketing information about relevant goods and services, predominantly accommodation and accommodation services
• to enable and enhance your participation in the wider Vita Student experience, including social events and interactions facilitated through services you choose to sign up to, such as the Vita Student app
• to share your data with certain Group companies so that they can contact you with marketing information about similar products and services
• for any other purpose for which consent is required under applicable data protection laws

You may withdraw your consent for us to use your information in any of these ways at any time. Please see “Withdrawing your consent” below for further details.

For users in India: Your information may be shared and/or transferred to jurisdictions other than your place of residence. You may email our Privacy team using the details provided below. For any grievances related to the use of your personal information, you may contact us at:

Attn: The Data & Privacy Officer
E-mail: myprivacy@vitastudent.com

Others who may receive or have access to your personal information

Group companies

We may share your information with other Group companies. They may use your personal information in the ways set out in the section “How we use your personal information” above, in connection with specific ancillary or complementary products and/or services.

For example, this may include products and services that only they can provide for regulatory reasons, or products and services similar to those we offer but under a different brand name.

Some of our Group companies may also act as service providers to us, as explained below.

Please see the start of this policy for a description of what we mean by Group companies with whom we may share your personal information in this way.

The owners or landlords of the Relevant Buildings

We may disclose your information to a third party that owns the building in which you have booked to live at Vita Student, and in respect of which we have been appointed as building manager. This may be for purposes related to them managing their interest in the building and overseeing the services we provide on their behalf.

Details of the Relevant Buildings and the full privacy policies of those landlords, who are the controllers of your personal data, can be found here.

Our suppliers and service providers

We may disclose your information to selected third-party service providers, agents, subcontractors and other organisations where necessary for them to provide services to us or directly to you on our behalf.

These third parties may include cloud service providers such as hosting, data storage and software providers, our customer relationship management provider, our app developer/provider, digital and marketing agencies, administrative service providers and, where relevant, debt management providers.

Where we use third-party service providers in this way, we only disclose the personal information necessary for them to provide their services. We also have contracts in place requiring them to keep your information secure and not to use it other than in accordance with our specific instructions and the purposes set out in this policy.

Credit / debit card payment processors

Where relevant, when you purchase certain products or services via our websites, over the phone, or at one of our residences or premises, a credit or debit card payment may be processed on your instruction by a third-party payment processing agent specialising in secure online capture and processing of payment card transactions.

If you have any questions regarding secure transactions, please ask us at the time of making payment or contact us using the details at the end of this policy.

We do not store or keep a record of your credit card details on our websites or within our own systems.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets, or as part of any business restructuring or reorganisation.

We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with a legal obligation, for example to detect or report a crime, to enforce or apply our contracts, or to protect the rights, property or safety of others.

We may also share your personal data with our legal and other professional advisers, and insurers, from time to time for legitimate reasons.

If and when we do so, we will always take steps intended to ensure that your privacy rights continue to be protected and upheld.

Where we transfer your personal information

Information you provide to us may be transferred to countries outside the EEA. This may happen, for example, where any of our Group companies that need access to that information are incorporated outside the EEA, or where our servers or those of our third-party service providers are located outside the EEA.

These countries may not have data protection laws similar to those in the UK or the EEA.

If we transfer your information outside the EEA in this way, we will take steps intended to ensure that appropriate security measures are in place so that your privacy rights continue to be protected in accordance with this policy.

These steps may include imposing contractual obligations on the recipient of your personal information or ensuring that recipients subscribe to other relevant regulatory regimes or best practice designed to provide adequate protection.

This is mainly relevant to the following third-party service providers that we use:

• Customer relationship management system provider – US based
• Data storage provider – US based
• Hosting provider – US based
• Banking services – global
• Messaging, scheduling and collaboration software application providers – mainly US based, although often hosted locally

We have standard contractual clauses and other relevant safeguards in place for transfers of personal data to these providers and other relevant third parties, as required under applicable data protection laws.

If you require more information about these protections, or would like a copy, please contact us using the details at the end of this policy.

If you use our services, access our systems or view our content while you are outside the UK, your information may be transferred outside the UK in order to provide those services to you.

How long we keep your information for

When we collect your personal information, the length of time we keep it depends on a number of factors, including the purpose for which we use it and our obligations under other laws.

We do not retain personal information in an identifiable format for longer than we consider necessary.

The period for which we retain your personal data may also vary depending on the legal basis we are relying on.

Calls to our offices may be recorded when you contact us by telephone. Any call recordings are retained for no longer than 90 days.

Where your personal data is required to complete or comply with a contract

We may need your personal information to comply with legal and accounting responsibilities, and/or to establish, bring or defend legal claims.

For this purpose, we will retain your personal information for 7 years after the date on which it is no longer needed by us for any of the purposes listed under “How we use your personal information” above.

Where we are only required to retain some of your information for these purposes, we will use reasonable endeavours to minimise that data and not retain information we do not need for the full 7-year period.

Where we have assessed there is a legitimate interest

If you are a citizen of the UK or any EEA country, we will not retain your personal data for longer than 3 years after a Legitimate Interest Assessment has been made or renewed, unless an exception applies.

This period generally reflects your period of study and the length of time for which you may require student accommodation.

If you are not a citizen of the UK or any EEA country, we may retain your personal details for longer than 3 years where we consider it necessary, justifiable, or where there is a legal requirement to do so, subject at all times to upholding your rights as a data subject.

Where you have provided consent

We will retain your personal data for as long as we consider it necessary and justifiable, and in line with your reasonable expectations, subject at all times to upholding your rights as a data subject, including your right to withdraw consent and your right to have your personal data erased.

Even where you have given and not withdrawn your consent, we may decide not to retain your personal data where we consider it is no longer necessary and justifiable.

Security and links to or from other organisations

We are committed to maintaining security standards to ensure that your information is held securely in systems that can be controlled and protected in accordance with data security best practice.

To protect against unauthorised access or disclosure, we put in place suitable physical, electronic and managerial procedures to safeguard the information we collect from you. Where possible, we store information in structured systems such as databases, which can only be accessed using secure passwords and other appropriate security controls.

Occasionally, it may be necessary to store or transfer some of your personal data in unstructured ways, such as on paper or in documents needed to enable us to collect and process that information for the relevant purpose. In these cases, we will take steps to ensure that appropriate procedures and controls are in place.

Unfortunately, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information transmitted to or from our website at all times, and any transmission is therefore at your own risk.

Once we have received your personal information, we put in place appropriate security controls against accidental or unlawful destruction, loss, alteration or unauthorised access.

Our websites may contain links to websites run by other organisations. Similarly, we may refer you from time to time to organisations that are not Group companies and to whom you may provide personal data.

This policy does not apply to those organisations, so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites or third parties, even if you access them using links or contact details that we provide.

Likewise, if you linked to our website, a contact details form, or any other material we have published electronically from a third-party website or an email sent to you by a third party, we are not responsible for the privacy policies and practices of those third parties. We recommend that you check their privacy statements as well.

Where we have given you, or you have chosen, a password that enables you to access certain information in our systems, you are responsible for keeping that password confidential. Please do not share it with anyone and let us know as soon as possible if you think it may have been stolen, exposed or compromised.

Cookies

Like many websites, our website uses cookies. A cookie is a small file that asks permission to be placed on your computer or mobile device’s hard drive.

These cookies help us analyse how our websites are used and improve your experience by tailoring information to you.

For more information on how we use cookies and how to set your cookie preferences, please view our banner and separate Cookies Policy.

Marketing

We may collect your personal data and information about your preferences and interests so that you can receive marketing information directly from us by email, SMS, via third-party social media platforms, and through targeted online promotions in the following ways:

• if you register for “more information” on one of our websites
• if you receive and act on a marketing campaign run by one of our marketing affiliates
• if you tag Vita Student on any of our social media channels using geolocation or recognisable tags including but not limited to @VitaStudent, #VitaStudent or #BeginBig
• if you make a reservation enquiry by telephone to one of our offices
• if you attend one of our hosted or sponsored events
• if you enter a competition or free prize draw that we are running
• if you opt in to receive newsletters or regular insights, interviews, perspectives, videos or podcasts relating to our business or market
• if you engage with electronic content we provide, including by following one of our social media channels
• if you download our app to one of your devices
• if you purchase a product or service from us or one of our Group companies

In any of these situations, we may contact you with further marketing information in the ways mentioned in this policy, except where you indicate that you do not wish to receive this, and otherwise only with your consent where consent is required.

We may contact you with marketing information by telephone, email or post, via third-party social media platforms, or with targeted advertising delivered online through social media and other platforms using your personal information.

We may also use your personal information to tailor marketing to improve its relevance to you. We only do so with your consent where required, and we will respect your preferences where you tell us you do not want a particular type of marketing.

If you tag Vita Student on any of our social media channels using geolocation or tags including but not limited to @VitaStudent, #VitaStudent or #BeginBig, we may use the content you have shared as user-generated content on our channels.

By tagging us in this way, you agree to allow Vita Student to share or republish your content, which may include your name and image, within our social media activity in accordance with the relevant platform’s terms of use.

If you choose to leave a review about Vita Student on a third-party site, Vita Student may publish your name, image and review details.

We will only share your information with third parties for marketing purposes where they are:

• a Group company offering similar products and services, potentially under a different brand name
• a data processor acting on our instructions as data controller as part of the means we use to send marketing information to you and track whether you have received and/or acted on it

If you would like to opt out of receiving marketing from any of our Group companies with whom we may share your information, you can do so at any time by contacting them directly or using the unsubscribe links in any communication you receive from them.

From time to time, we may ask you to update your marketing preferences, including the frequency and method of receiving future marketing information from us.

You have the right to opt out of our use of your personal information for marketing in any of the ways described above at any time. Please see “Withdrawing your consent and objecting” below for more details.

Your rights

If you are located in the UK, an EEA country, India or Mainland China, you have a number of rights in relation to your personal information under data protection law, which are summarised below.

Not all of these rights may apply to individuals in countries outside the UK or EEA, and you may have different rights depending on where you are located.

For certain requests, we may ask you for information to confirm your identity and, where applicable, help us locate your personal information. We will respond within the applicable time limits under relevant data protection laws.

Accessing your personal information and data portability

You have the right to make a reasonable request for a copy of the information we hold about you by emailing or writing to us at the address below.

We may not provide a copy if it concerns other individuals or if we have another lawful reason to withhold that information.

In limited circumstances, you may also have a right to data portability, meaning you can ask us to create a file of electronically processed personal data for transfer to you or a different service provider.

Correcting and updating your personal information

The accuracy of your information is important to us. We want to make sure we can regularly and easily review and correct the information we hold about you.

If any of your personal information changes, particularly your name, address, email address or contact telephone numbers, or if you discover that any information we hold is inaccurate or out of date, please contact us as soon as possible using the details below.

Withdrawing your consent

Where we rely solely on your consent as the legal basis for processing your personal information, as set out under “How we use your personal information”, you may withdraw your consent at any time by contacting us using the details at the end of this policy.

If you withdraw your consent, our use of your personal information before that point will still be lawful.

Objecting to our use of your personal information

Where we rely on a legitimate interest as the legal basis for processing your personal information, you may object to us using your personal information for those purposes by emailing or writing to us at the address below.

Except where we are satisfied that we can continue to process your personal information, we will temporarily stop processing it in line with your objection while we assess the matter.

If we agree that your objection is justified in accordance with your rights under data protection law, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification for continuing to use it.

You may object to us using your personal information for direct marketing at any time, and we will comply with your request within a reasonable time. You can do this by using the unsubscribe links in any electronic marketing we send you.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address below.

Unless the law allows us to continue using your personal information, we will make reasonable efforts to comply with your request.

You may also ask us to restrict the processing of your personal information where you believe it is unlawful, where you have objected to its use and our assessment is pending, or where you require us to keep it in connection with legal proceedings.

In these situations, we may only process your personal information while processing is restricted if we have your consent or are otherwise legally permitted to do so, for example for storage, to protect the rights of another person or organisation, or in connection with legal proceedings.

Complaining to the UK data protection regulator and other data protection authorities

You have the right to complain to the relevant data protection regulator responsible for overseeing the processing of your personal data if you are concerned about how we have handled it.

In the UK, this is the Information Commissioner’s Office (ICO). Please visit www.ico.org.uk for further details.

For residents at any building in Spain, the data protection authority is the Agencia Española de Protección de Datos (AEPD). Please visit www.aepd.es for further details.

Contact us

Our contact details for queries about your personal data, including for exercising any of your data subject rights, are:

Vita Student Management Ltd
Company registered number: 08540975
Address: Horseshoe Farm, Elkington Way, Alderley Edge, England, SK9 7GU
Email: myprivacy@vitastudent.com

Changes to this policy

We may review this policy from time to time, and any changes will be notified to you by posting an updated version on our website(s).

In some circumstances, we may also notify or contact you directly, for example by email, to let you know about changes.

Any such changes will take effect 7 days after the date on which we post the modified terms on our website.

We recommend that you regularly check for updates and review this policy whenever you visit our websites.

This policy was last updated in May 2024.

Schedule 1: Group companies

Vita Group Holdings Limited
Company registered number: 11963176
Address: Horseshoe Farm, Elkington Way, Alderley Edge, England, SK9 7GU
Email: myprivacy@vitagroup.com

Vita Living Management Limited
Company registered number: 10976545
Address: Horseshoe Farm, Elkington Way, Alderley Edge, England, SK9 7GU
Email: myprivacy@vitagroup.com

Select Property Group Limited
Company registered number: 5071388
Address: Horseshoe Farm, Elkington Way, Alderley Edge, England, SK9 7GU
Email: myprivacy@selectproperty.com

Vita Spain Management SLU
Registered in Spain with company NIF number: B67626770
Address: Avinguda Diagonal 538, 5-2, CP: 08036 Barcelona

Union Manchester (East & West) Management Limited
Company registered number: 13561143
Address: Horseshoe Farm, Elkington Way, Alderley Edge, England, SK9 7GU
Email: hello@liveunion.com