Purple Frog Asset Management Limited takes your privacy and the security of your data extremely seriously. Below, you will find information about us, how we collect and handle your data, and your rights under data protection laws.
1. Who we are
Purple Frog Asset Management Ltd is registered as a company in the UK (company no: 14323557).
Our head office is situated at 47 Calthorpe Road, Edgbaston, Birmingham B15 1TH. Telephone number: 0121 227 4188. Email: Ops@purplefrogproperty.com
2. The information we collect
As part of our services for the sourcing, provision and management of student accommodation, as well as requirements set out in UK and EU law, we need to collect certain personal information.
Information is collected under different circumstances and not all information will be required from all customers. As part of our commitment to your data, we will only collect what is necessary. For more information about the data we collect from you, please contact us (see below).
|Name||Date of Birth||Gender||Ethnicity||Nationality||Passport / photo ID|
|Email address||Telephone number||Current address||Previous addresses in the last three years||Tenancy address||Property address|
|Forwarding address||IP address||Bank statements||Student ID||University course||University name|
|University course length||Year of study||Student / Employment status||Visa / immigration status||National insurance number||Health / disability|
|Utility Bills||Council Tax liability||Right to Rent documents||Company name||Company number||Employer’s Name|
|Occupation||Pay slips||Salary / Self-employed accounts||Proof of address||Proof of deposit||Proof of funds|
|Proof of ownership||Mortgage details||VAT number||Property management certificates (HMO licence, gas safety certificates)||Texts, phone calls, letters, emails and social media messages||Next of kin / guarantor|
|P45 / P46 / P60||Doctor's Note / Statement of Fitness for Work||Attendance Records||Employment History / CV||Bank details (including Account Number, sort code, bank, bank address, IBAN, SWIFT, BIC, billing address)|
3. How we collect it
In the general conduct of business, we will only collect information relevant to the services being sought across the range of services we offer. Were possible, we will collect information directly from yourself. Occasionally, we will collect data from a spouse / partner / family member, or business associates, university or employer.
We will also use trusted sources. These include:
• Government / Land / Police registers
• Credit / Default Agencies
• Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)
• Insurance Companies
• Other Law firms
• Health providers
• through consent to third parties disclosing information about you to us that they have collected (for instance, property portals, such as RightMove).
Such information will generally be collected directly via the use of any of our standard forms, over the internet, via email, in our branches or through a telephone conversation with you. We may also collect personal information through our affiliates or suppliers.
In addition, you may choose to submit information directly to us via several methods, including:
• Through Purple Frog website
• In response to marketing or other communications
• Through social media
• By signing up for a Purple Frog service
• Through participation in an offer or promotion
• In connection with an actual or potential business or employment relationship with us
You may also agree to third parties disclosing information about you to us that those third parties have collected.
We collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets. We may use third-party web analytics services on our websites and mobile apps.
As part of our services, we provide you with the possibility of connecting your profile to Facebook. Some information about you will automatically be collected, depending on what information you have made available on the network and your privacy settings for sharing such information on the network. Depending on the settings, we may collect the following information about you: Name and/or username, and E-mail address.
4. How we use this information
Purple Frog will never sell or share your information, outside what is required by our normal business practices. Generally, we will collect, use and hold your information for the purposes of:
• Assessing applications for and providing services to our clients and tenants, which may include providing information to members of your family/household, anyone acting on your behalf
• Ensure properties and tenancies are managed to industry and legal standards
• Comply with legal and regulatory requirements for marketing, letting and managing properties
• Conducting business, developing relationships with Purple Frog Group and its subsidiaries
• Process payments / transactions including: Accounting, Authorisation, Clearing, Chargebacks, Auditing, Billing, Reconciliation, Collection, Complaints, Enquiries, Credit Checks and related dispute resolution activities
• Protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent quality, integrity, compliance and security of business processes
• Create and manage any accounts, associated authentication criteria (id’s and passwords) you may have with Purple Frog
• Provide, administer and communicate with you about Purple Frog, its services, offers, industry and sector news, retailers and partners.
• Operate, monitor, evaluate and improve our products, services, websites, other digital assets and business.
• Developing new products and services
• Managing communications, assess effectiveness and optimisation of advertising
• Functionality of our websites, and other digital assets
• Evaluate your interest in employment and contact you regarding possible employment opportunities
• Training and monitoring of staff
• To assist companies and organisations trying to regain monies owed or suing for breach of contract (provided companies can prove existence of contract during tenancy dates)
Please note: the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. It may also be processed by staff operating outside the European Economic Area who work for us or for one of our agents or suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
5. Lawful basis of processing
We have several legal bases for collecting and processing your information. These are:
Performance of a contract
Where you enter into a contract with us, or we act as an agent on behalf of a client, and we need to process your information as part of this contract.
Some information is processed under our legal obligations under UK and EU law, and local regulations. This includes checking information to comply with right to rent and anti-money laundering checks. We are also obliged to collect data to ensure that properties comply with property law and are in a safe condition, for instance, gas safety certificates and HMO licences.
This includes processing information that can be used in case of an emergency, such as next of kin.
Some information is processed by Purple Frog as part of its legitimate interests. This includes:
• Debt recovery
• Risk assessment
• Due diligence
• Network and information security
• Suppressions and managing opting out of communications
• Direct marketing
• Web analytics
• Cloud storage
• Updating customer details
• Processing complaints
Where we process information under consent we will seek you clear and unambiguous consent prior to processing your data. This includes joining our student community or landlord newsletter mailing lists.
6. Information we share
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. When we do share data, we will only share the minimum that is required to complete the task. As part of the normal course of doing business and complying with laws and regulations, we share information we collect with, but not limited to:
• Landlords and landlord associates
• Other tenants and guarantors, where you are on a joint and several contract
• Vetted affiliates and partners
• Service providers to perform services on our behalf:
I. Hosting Datacentres, Infrastructure, Cloud Services
II. Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
III. Tradespeople and maintenance contractors
IV. Data processors that help us deliver services, such as StuRents and Docusign
V. Data processors that help deliver marketing, such as Rocketseed and MailChimp
VI. Online data processors, such as RightMove, may access data that they collect on our behalf, such as call recordings
• Deposit Protection Agencies
• Financial organisations (including banks and insurance companies)
• Debt collection and tracing agents
• Public and government bodies
• Professional advisers, such as lawyers and accountants
• Councils, health and care providers
• Land Registry Office, Her Majesty’s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies
• Agents and Landlords requiring references as to your suitability to rent, via your written consent
• Other agents who may assist with marketing your property
• Companies that supply services to properties that we manage
• Companies or organisations that you have formed contracts with while living in a property we manage
Where we use third parties to process data, we require these service providers to safeguard the privacy and security of personal information that they process on our behalf. We authorise them to only use or disclose the information as necessary to perform services on our behalf or comply with legal requirements.
Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
Our website links to other sites that are not affiliated with Purple Frog. Where this occurs, we bear no liability for the third party’s privacy and data protection. We highly recommend that you review the third parties' privacy policies if you decide to continue using their site or services.
Purple Frog reserves the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.
Credit Reference and Fraud Prevention Agencies
When you join Purple Frog, we may check your details with one or more credit reference and fraud prevention agencies to help us decide whether there is a risk that you may not pay your bills and also to help us make decisions about the goods and services we can offer you.
We may search at credit reference and fraud prevention agencies for information about you and all the people you are applying with.
If you are providing information about other people on a joint application, you must make sure they agree that we can use their information to do this. If you give us false or inaccurate information and we suspect fraud, we will pass your details to credit reference and fraud prevention agencies. Law enforcement agencies (such as the police and HM Revenue & Customs) may receive and use this information.
We and other organisations may also see and use information about you that the credit reference and fraud prevention agencies give us to:
• Check details on applications you make for credit and credit-related services
• Check your identity
• Prevent and detect fraud and money laundering
• Manage credit and credit-related accounts or services
• Recover debt
• Check details on proposals and claims for all types of insurance
• Check details of employees and people applying for jobs with us
When credit reference agencies receive a search from us, they will record this on your credit file whether your application is successful or not.
If you have an account with us, we may give details of it and how you manage it to credit reference agencies. If you have an account and do not repay money you owe in full or on time, credit reference agencies will record this debt. They may give this information to other organisations and fraud prevention agencies to carry out similar checks, find out where you are and deal with any money you owe. The credit reference agencies keep records for six years after your account has been closed, you have paid the debt or action has been taken against you to recover the debt.
We and other organisations may see and use information from other countries that is recorded by fraud prevention agencies.
If you want to see what information credit reference and fraud prevention agencies hold about you, you can contact the following agencies in the UK. The information they hold may not be the same, so it is worth contacting them all. They will charge you a small fee.
Consumer Services Team
PO Box 491
Phone: 0845 366 0071
Customer Support Centre
PO Box 9000
Phone: 0844 481 8000
Credit File Advice Centre
PO Box 1140
Phone: 0844 335 0550
With other suppliers: We may share information with your previous or new suppliers to allow us to transfer services (This includes your tenancy address, telephone/email address and information about meter readings and equipment or charges you owe your previous supplier).
With parties interested in your meters: If we suspect someone has committed fraud or stolen energy by tampering with your electricity or gas meters or by diverting the energy supply, we will share this information with Ofgem and other people who are interested
(such as energy suppliers, landlords and housing associations).
Pastoral care / your vital interest
With organisations that may be able to help you: If we believe that you (or a member of your household) need extra care (for example, because of your age, health, disability or financial circumstances), we may record and share this information with: social services, charities, health care and other support organisations.
7. How long we keep information for
We will keep information for a reasonable amount of time in order to perform the purposes listed above. We only keep your information for as long as necessary.
We generally keep personal information for 7 years after last contact with you. However Purple Frog reserves the right to keep information for longer if we feel that this is in the legitimate interests of Purple Frog. This may include for auditing purposes or to show Article Four use of HMO properties that we manage.
8. Your rights and choices
Under data protection rules, you are afforded a number of rights that govern how we collect and use your data, and how we communicate with you. There are
1) Access and correction
You may have the right to:
• Obtain confirmation that we hold personal information about you
• Request access to and receive information about the personal information we maintain about you
• Receive copies of the personal information we maintain about you
The right to access personal information may be limited in some circumstances by local law requirements.
To exercise these rights, please email Ops@purplefrogproperty.com to request a Subject Access Form. We will respond to a request within 30 days or receiving your completed Subject Access Request form.
Please note that we may refuse requests that are unreasonably repetitive, require disproportionate technical effort (such as developing new systems or fundamentally changing existing practice). If your request contains private information about other people, we reserve the right to contact those individuals to obtain their consent, before complying with your request.
2) Update and correct inaccuracies
If you feel that the information we hold about you in incorrect or inaccurate you can contact us outlining the information you feel is incorrect of inaccurate if you feel that any of the information we hold about you is inaccurate, you can tell us so that where appropriate this can be corrected.
Where a mistake is made in data processing then you can ask to have it rectified. Any third parties who have received the data from us should then be told of the rectification.
3) Object to processing of your personal information
This allows you to object to our processing of data about you. We must then stop processing data unless we can establish legitimate reason for continuing. In particular this applies where we are relying on our own legitimate interests or those of a third party to process data but it can also apply in other situations.
If you would like to object to any processing of your information by Purple Frog you can contact us outlining what processing of information you would like to object to.
4) Information blocked, anonymized or deleted
In certain circumstances where your rights override our legitimate interests, or if data has been unlawfully processed, you have a right to ask us to delete any data we hold about you (the so called right to be forgotten).
You can also ask us to suspend processing of your personal data and we must then restrict processing of data. This includes where you are contesting the accuracy of a statement or the lawfulness of the processing.
5) Withdrawal of consent
Where your consent provides us with the legal basis to process information about you, you can withdraw this at any time by telling us using the details provided in this Privacy statement.
Where we are sending you marketing emails, you are able to opt out of these using the ‘unsubscribe’ button at the bottom of each email.
6) Data portability
This allows individuals to reuse their personal data for their own purposes across different services. This allows them to move, copy or transfer personal data more easily
9. If you want to complain
We take your data and privacy very seriously. If you have questions or concerns about how we are handling your data, you can contact us at Ops@purplefrogproperty.com. We will confirm receipt of your email within one working day and will answer your question or concern in line with our standard complaints procedure.
We are registered with the Information Commissioner’s Office (IC0). If, for some reason, you feel that we have not answered your concern, you can contact the here:
Information Commissioner's Office
Wycliffe House, Water Lane
10. Updating this privacy statement
We will update this statement from time to time, so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavour to inform you directly about these changes.
Last updated: October 2022