Centurion Student Services UK Ltd operating under the brand name dwell student living, and/or its related corporations (each, “dwell”, the “Company”, the “Group”, “we”, “us” or “our”) collectively or singularly as the context requires, recognises the importance of protecting Personal Data.
dwell adopts a pragmatic approach in our business conduct. dwell collects Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose for retaining it. We do not collect Personal Data randomly or indiscriminately without purpose.
dwell does not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data. This does not affect any rights which Centurion may have at law in connection with the collection, use or disclosure of your Personal Data.
1.1 “Personal Data” as defined in the GDPR means refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include, but is not limited to (depending on the nature of your interaction with us):
i. your name, NI number, passport number or other identification numbers, telephone number(s), mailing address, email addresses, and any other information relating to you which you have provided us in any form you may have submitted to us (i.e. student accommodation application forms, job application forms, etc.), or in our other forms of interaction with you;
ii. information about your use of our websites and services, including cookies, IP addresses, email subscription, and membership details (where applicable);
iii. your Curriculum Vitae, employment history, testimonials, and referrals, previously drawn income, education background, medical history and disabilities, and legal and bankruptcy history (if applicable); and iv. your payment-related information, such as your bank account details (where applicable).
iv. your payment-related information, such as your bank account details (where applicable).
2.1 Generally, dwell collects your Personal Data in the following ways:
i. when you submit soft or hard copy forms relating to any of our products or services;
ii. when you register for or use any of our services on websites owned or operated by dwell or when you register as a member of websites owned or operated by us;
iii. when you interact with dwell’s employees and staff, including during face-to-face meetings or by way of the telephone;
iv. when you enter into a contract with us or use or purchase our services or products;
v. when you establish any online accounts with us;
vi. when you submit a request for us to contact you;
vii. when you respond to our request to submit additional Personal Data;
viii. when you subscribe or ask to be included in an email or other mailing list;
ix. when you respond to our promotions and other marketing and publicity initiatives;
x. when you respond to our market surveys;
xi. when you submit a job application or a scholarship application;
xii. when we receive references from business partners and third parties;
xiii. when you submit your Personal Data to us for any other reason; and
2.2 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that you have obtained the consent of that third party for the collection, use and disclosure of their Personal Data for the purposes set out above.
3.1 dwell’s goal is to understand your needs and provide you with products and services that you require. To do this effectively, dwell needs to collect certain Personal Data.
3.2 In general, dwell may collect, use and disclose your Personal Data for the following purposes:
a. to provide you with the products or services that have been purchased or requested;
b. to help manage the delivery of and enhance our products and services, including analysing current customer needs and identifying potential future needs;
c. updating your records in our databases; monitoring and maintaining a copy of your record of previous transactions with dwell;
d. to communicate and respond to your queries, requests and complaints;
e. to provide ongoing marketing and publicity information about our products and services and upcoming events which may be of interest to you;
f. to ascertain security clearances and access controls at dwell facilities;
g. for security, surveillance and employee monitoring purposes;
h. to handle disputes and complaints and conduct and facilitate investigations and proceedings when required;
i. to protect and enforce dwell’s contractual and legal rights and obligations;
j. to prevent, detect and investigate crime, and to analyze and manage other commercial risks;
k. to manage the infrastructure and business operations of dwell and to comply with other dwell internal policies and procedures;
l. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving dwell; and m. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
3.3 In addition, Centurion may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
a. If you have a customer account with us, are a prospective customer or a customer:
i. to process your application for a dwell account;
ii. to maintain and administer your dwell account with us;
iii. to verify your personal particulars and process payment requests in relation to provision of products and services, which you may be entitled to, or which you may have requested for;
iv. to provide you with the products and services which you have may have entered into a contract with dwell for or purchased from dwell;
v. to communicate changes and developments to dwells policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you; vi. to send marketing and publicity emails which may of interest to you; vii. to resolve complaints and handle requests and enquiries;
viii. to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of dwell’s products and services provided to you; and
ix. to process your Personal Data in relation to any of the purposes stated above.
b. If you use download or use any of our mobile applications (“apps”):
i. to process your application for subscription services if such services provided for in the apps;
ii. to administer and maintain your account with us;
iii. to verify and process your personal particulars and process payment requests in relation to provision of products and services connected to the app;
iv. to provide you with the goods and services which you have purchased or signed up for via the app;
v. to communicate changes and developments to dwell’s policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
vi. to resolve complaints and handling requests and enquiries; vii. to conduct market research for statistical, profiling, statistical analysis and planning for the improvement of dwell’s products and services provided to you; and
viii. to process your Personal Data in relation to any of the purposes stated above.
c. If you are a prospective tenant/resident or a tenant/resident:
i. to administer and conduct appropriate due diligence checks;
ii. to prepare the relevant dwell lease and/or licence documentation and any other documents as may be required;
iii. to administer the relevant leases or licences ;
iv. to administer and perform financial transactions such as rental payments; v. to resolve complaints and handling requests and enquiries;
vi. to communicate changes and developments to dwell’s policies, terms and conditions and other administrative information; and
vii. any other purpose related to any of the above.
d. If you are a vendor, a prospective vendor or a contractor:
i. to evaluate your proposals for working with dwell and to conduct relevant background checks on you;
ii. to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or security concerns; and
iii. any other purpose relating to any of the above.
e. If you submit a job application to us as a candidate for employment:
i. to evaluate your suitability for employment with dwell, including pre-recruitment checks and checking on provided references for more detailed background screening/vetting;
ii. to organise training and staff development programs;
iii. to maintain and manage employee relations, including annual performance assessments/appraisals;
iv. to administer and manage benefits and payroll processing; v. to provide you with the relevant/correct tools as required for you to do carry out your job responsibilities;
vi. to resolve complaints and handling requests and enquiries;
vii. to communicate dwell’s policies and processes, codes of conduct and standard operating procedures, including for business continuity purposes; and
viii. any other purposes relating to the aforesaid.
3.4 When you apply for or hold a co-brand product which is offered jointly by dwell and its cobrand partner, dwell may also collect, use and disclose your Personal Data with the co-brand partners for offering, marketing and promoting any products, services, offers or events which the co-brand partner thinks may be of interest to you.
3.5 In relation to particular products or services or during your interactions with dwell, we may also notify or have specifically notified you of other purposes for which dwell collects, uses or discloses your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.6 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
a. other divisions, business units or entities within the dwell;
b. dwell’s joint venture/alliance partners;
c. agents, contractors, sub-contractors, third party service providers and specialist advisers contracted by dwell to provide administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
d. any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with dwell or not; e. insurers or insurance investigators and credit providers;
f. in the event of default or disputes, any debt collection agencies or dispute resolution centres;
g. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the whole dwell or entities within the dwell;
h. dwell’s professional advisors such as our auditors and lawyers;
i. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
j. anyone to whom we may transfer our rights and obligations;
k. banks, credit card companies and their respective service providers; and
l. any other party as may be consented to by you, as specified by that individual or in the applicable contract.
dwell requires that third party organisations which handle or obtain Personal Data, such as service providers to dwell, acknowledge the confidentiality and sensitivity of this personal data, undertake to respect any individual’s right to privacy and comply with the GDPR. dwell also requires that these organisations use this information only for limited purposes which have been agreed upon and follow dwell’s reasonable directions with respect to this information.
4.1 dwell endeavours to ensure that Personal Data stored by us is accurate and up-to-date. dwell also understands that Personal Data may change frequently, such as changes of address and other personal circumstances. As such, dwell encourages you to contact the DPO at email@example.com to update your Personal. Incomplete or outdated Personal Data may result in our inability to provide you with the products and services you have requested.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
All electronic storage and transmission of personal data is secured and encrypted with appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, dwell cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
8.1 Please contact us via firstname.lastname@example.org should you wish to have access to or withdraw the consent to collect and use your Personal Data.
Your email should identify yourself and state which Personal Data and information about its use and / or disclosure is requested.. If you withdraw your consent to any or all purposes and depending on the nature of your request, dwell may not be in a position to continue to provide our products or services to you.
10.1 If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact the designated Data Protection Officers for the respective business units as follows:
Published date: Nov 23, 2021
Effective date: Nov 23, 2021