PRIVACY POLICY

Welcome to the Nido Management UK's privacy notice.

Nido Management UK Limited (“we“, “us”, “our” or “Nido Management UK”) respects your privacy and is committed to protecting your personal data. This privacy notice (together with our website terms of use and any other documents referred to in it) will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting http://www.nidostudent.com/ (“our website”) you are accepting and consenting to the practices described in this privacy notice.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected
  4. Disclosures of your personal data
  5. International transfers
  6. Data security
  7. Data retention
  8. Your legal rights
  9. Glossary

 

Individuals are entitled to know the identity of the entity that makes decisions about how their data is used – this will be the “controller” of the data. For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “General Data Protection Regulation” or “GDPR”) and any other applicable laws, Nido Management UK is both the Controller and Processor.

As used in this privacy notice, the term “Regulations” shall include the General Data Protection Regulation, as from time to time applicable, amended, restated or supplemented and any law, statute or regulation supplementing, amending, implementing and/or replacing the GDPR.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Nido Management UK Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

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.

 

CONTACT

As Nido Management UK  is both the controller and processor, we are responsible for collecting and processing your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

CONTACT DETAILS

Our full details are:

Nido Management UK Limited
Data Privacy Team
1 Knightsbridge
London
SW1X 7LX

GDPR@nidostudent.com

Telephone number: 00 44 20 7349 1330

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

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.

 

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, process, store and transfer different kinds of personal data about you which we have grouped together. This may include (without limitation):

  • Information that you give us: you may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, subscribe to our service, post material, participate in discussion boards or other social media functions on our website, request further services, your preferences in receiving marketing from us and our third parties, your communication preferences, purchases or orders made by you, your interests, preferences and when you report a problem with our website. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys and fill out feedback that we use for research purposes, although you do not have to respond to them. The information you give us may include your name, maiden name, last name, marital status, title, date of birth, gender, address (billing and delivery), username and password or similar identifier, e-mail address and phone number, financial information and credit card information, personal description and photograph;
  • Information we collect about you: with regard to each of your visits to our website we may automatically collect the following information:
      • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, 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. We collect this personal data by using cookies and other similar technologies; and
      • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
  • Information we receive from other sources: we may receive further information about you of the categories set out above if you use any of the other websites we operate or the other services we provide. In this case any data collected may be shared internally and combined with data collected on this website. We may also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  • Automated technologies or interactions.As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns.. We may also receive technical data about you if you visit other websites employing our cookies. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

We may also collect, use and share aggregated data such as statistical or demographic data for any of the purposes above. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We may make use of the personal data we have collected from you to enable us to comply with our third parties or advertisers’ wishes by displaying their advertisement to that target audience. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We will only use the personal data you give to us when the law allows us to. Most commonly, we will use the personal data you give to us in the following circumstances:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you [Insert mode of contact: by electronic means (e-mail or SMS)] with information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by [Insert mode of contact: electronic means] only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
  • to notify you about changes to our service;
  • to ensure that content from our website is presented in the most effective manner for you and for your computer;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • where we need to comply with a legal or regulatory obligation.

The legal basis for this processing is our legitimate interests and business and, where applicable, the proper performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and the proper administration of our website and business.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party 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 using the contact details, above.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We may use the information we collect about you:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our website safe and/or secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
  • to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data in accordance with this privacy notice with any company outside the Nido Management UK group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time using the contact details above.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy, here.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with both Internal and External Third Parties as follows:

INTERNAL THIRD PARTIES

Other companies in the Nido Management UK group acting as joint controllers or processors and who are based in the EEA and may provide IT and system administration services. We may therefore share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

EXTERNAL THIRD PARTIES

We may share your information with selected third parties including:

  • service providers acting as processors based in the EEA and may provide IT and system administration services.
  • professional advisers who may act as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or EEA who require reporting of processing activities in certain circumstances.
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if Nido Management UK or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; and/or
  • to protect the rights, property, or safety of Nido Management UK, our clients, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of services to you, the marketing of your products and designs, 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 privacy notice and in compliance with the Regulations and any other applicable laws.

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.

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.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal obligations under the Regulations and any other applicable laws as well any 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 the applicable legal requirements.

Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers for tax purposes or for any other shorter or longer period that may be imposed to us by the Regulations or any other applicable laws (the “Data Retention Period”).

Upon elapsing of the Data Retention Period, all your personal data stored and retained by us will be deleted from our files and records.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are:

  • 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 lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though 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 continuing to process 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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law, the Regulations or any other applicable laws. 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 of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground 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 of 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 provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a 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. 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 at the time you request to withdraw your consent.
  • Not be subject to automated decision making, including profiling of your personal data. You may object to be subject to any automated data processing decisions, unless such automatic processing is necessary for entering into or performance of a contract between you and us, is lawfully authorised and/or based on your explicit consent.

If you wish to exercise any of the rights set out above, please contact us at:

  • Nido Management UK limited
    Data Privacy Team
    1 Knightsbridge
    London
    England
    SW1X 7LX

or via email at GDPR@nidostudent.com.

 

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.