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Privacy Policy
Privacy Notice and Consent
We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store and use personal information and how to contact us and supervisory authorities in the event you have a complaint. This policy explains how information about you is collected and used.
We ask that you read this privacy policy carefully as it contains important information on:
- the personal information we collect about you
- what we do with your information, and
- who your information might be shared with.
Who we are
Rafter Investco S.a.r.l (‘we’ or ‘us’) is a company having its registered office at 412f, Route D’Esch, Luxembourg, L-1471 are the ‘data controller’. As the data controller, we respect your right to privacy and will only process personal information you provide to us in accordance with applicable data protection laws and as described in this policy. Applicable data protection laws include (i) the General Data Protection Regulation (Regulations 2016/679) (“GDPR”); and (ii) all other existing or new applicable laws relating to or impacting on the processing of information of a living person and privacy)
If you have any questions about how we collect, store and/or use your personal information, or if you have any other privacy-related questions, please contact us on info@rafter-group.com
What information will we collect?
Personal information provided by you
We collect personal information about you (such as your name, postal address, email address, phone numbers, date of birth, payment details) when you sign up to participate in or receive a service from us, such as getting an online quote, live chat, reserve a unit online, manage your account online, or face to face if you come to our site to sign a storage agreement. We also collect personal information when you contact us, send us feedback, complete customer surveys, or participate in competitions. Our website also uses cookies (see “Use of cookies” section below) and collects IP addresses (which means a number that can uniquely identify a specific computer or other device on the internet).
Personal information provided by third parties
Occasionally we may receive information about you from other sources (which may include identity or credit reference agencies), which we will add to the information we already hold about you in order to help us provide services to you and to improve and personalise our service to you. If you apply for a job with us, we may receive information from any previous employer or person who will provide a reference on your behalf.
Personal information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data;
- receive on his/her behalf any data protection notices; and
- give consent to the transfer of his/her personal data abroad.
Sensitive personal information
We will not usually ask you to provide sensitive personal information. We will only ask you to provide sensitive personal information if we need to for a specific reason, for example, if we believe you are having difficulty dealing with your account due to illness. If we request such information, we will explain why we are requesting it and how we intend to use it.
Sensitive personal information includes information relating to:
- your ethnic origin
- your political opinions
- your religious beliefs
- whether you belong to a trade union
- your physical or mental health or condition
- your sexual life, and
- whether you have committed a criminal offence
We will only collect your sensitive personal information with your explicit consent.
Children
We do not knowingly collect personal data relating to children under the age of 16. The only exception to this is that from time to time we may run competitions within our local communities which invite children to enter. Parental consent will always be essential in these cases and the data will be used solely in relation to the competition and not for any other marketing purposes. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to your child, please contact us using the details provided.
How we share your personal information and who we share it with
We will not sell, rent or otherwise disclose your personal data to any third party, except as described in this policy.
We may provide your personal information to Rafter Group subsidiaries/affiliated companies and to third party processors to process personal information on our behalf for the purposes set out in this policy. These parties are required to process such information based on our instructions and in accordance with any up to date law and regulations.
The third party providers to whom we may disclose your personal data are:
- service providers under contract with us to support our business operations, such as technology services, identification and authentication services, fraud prevention, debt collection;
- our insurers and insurance brokers if you take out insurance coverage through us;
- any person who you have named as a person we can contact to discuss your account;
- any person who is your agent or representative, such as the holder of a power of attorney, a legal guardian or person administering a will;
- any person who we are negotiating with as a potential buyer of our business or property or if we are proposing to merge our business with another business.
We may disclose your personal information where:
- we are required to do so by applicable law, by a governmental body or by a law enforcement agency in connection with any investigation to help prevent or detect unlawful activities;
- to establish or exercise our legal rights or defend against legal claims;
- to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
How do we collect information from you?
We gather information directly from you and also via our websites and other technical systems. If you visit our storage facility, some personal data may be collected from monitoring devices and systems such as closed circuit TV (CCTV) and door entry systems at the site.
We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
Use of cookies
A cookie is a small text file which is placed onto your computer (or other electronic device such as a mobile telephone or tablet) when you use our website. We use cookies and on our website and may also use other similar tracking technologies such as web beacons, action tags, Local Shared Objects (‘Flash cookies’) or single-pixel gifs on our website. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify you individually. We use analysis software to look at IP addresses and cookies to improve your experience as a user of our website. We do not use this information to develop a personal profile of you. If we do collect personally identifiable information, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. For further information on our use of cookies visit our website cookie policy.
How will we use the information about you?
We use the lawful basis of legitimate interest when contacting you in relation to obtaining a storage price from us and contract when you become a customer. We collect information about you for a number of reasons, namely to:
- identify you and manage any accounts you hold with us;
- contact you for reasons related to the service you have signed up for or to provide information you have requested;
- follow up on enquiries in accordance with industry guidelines and provide quotes for storage/details of offers;
- deal with payment for our services;
- notify you of any changes to our website or to our services that may affect you; or
- resolve disputes or collect overdue payments.
We also collect personal information to comply with our legal obligations, for example to comply with anti-money laundering and counter-terrorist financing requirements.
So that we can make sure we give a high quality service, we collect personal information to:
- conduct research and analyse website visitor behaviour patterns;
- customise our website and its content to your particular preferences;
- improve our services;
- detect and prevent fraud;
- carry out security vetting;
- collect and process CCTV images so we can fulfil our contractual obligation to deliver a secure self storage environment and/or assist in the establishment of or defence of any crime or other investigation; and
- prevent offensive, inappropriate or objectionable content being sent to or posted on our sites or to stop any other form of disruptive behaviour.
If you agree, we will contact you to let you know about other products or services that may be of interest to you—see ‘Marketing’ section below;
If we propose to use your information for any other uses we will ensure that we notify you first. If we need your consent to use your information for these other purposes, we will give you the opportunity to opt in or to refuse. If you opt in, you will be able to opt out at any time.
Marketing
When you request a quotation we will contact you to discuss your needs and enable us to make sure that we are providing you with an accurate price. We will ask whether you would like us as a Group of Companies to send you other marketing messages by asking you to tick the relevant boxes when you complete our online enquiry form, come to our storage facility to sign a storage agreement or provide us with your contact details though another means.
If you have consented to receive such other marketing from us, you can opt out at any time. Simply follow the link to unsubscribe in the email.
Identity and Credit checking
We may do an identity or credit check on you:
- so that we can make credit decisions about you and people or businesses associated with you, and
- to prevent and detect fraud and money laundering
Our search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address or who are financially linked to you.
Other credit businesses may use your information to:
- make credit decisions about you and the people with whom you are financially associated
- trace debtors, and
- prevent and detect fraud and money laundering
If you provide false or inaccurate information to us and we suspect fraud, we will record this.
If you want to see your credit file, please contact the credit reference agency we use Credit Assist.
When will we contact you?
We may contact you to let you know about any changes to the service you have signed up for or to provide information you have requested. Where you have opted to receive further information from us, we will invite you to participate in surveys about our services (but it is your choice if you wish to take part) and we will contact you for marketing purposes. You can tell us to stop contacting you for marketing at any time – see the section on your rights below. If you ask us to stop contacting you, you can also ask us to start again at any time.
When will we contact any other person about you?
If you provide us with details of any other person we can contact to discuss your account, we may contact that person and discuss and share the details of your account with that person and deal with that person in relation to your account as if that person was you. We may particularly want to do this if we are unable to get in touch with you for any reason. If you change your mind, you can email or write to us and have this person taken off your account as an alternate contact person.
Data privacy for job applicants
In order to process your job application, we will collect the following information about you:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your entitlement to work in the UK;
- interview and assessments;
- references from former employers.
We may also collect, store and use the following ‘special categories’ of more sensitive personal information:
- equal opportunities monitoring information;
- whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process
How do we collect your personal data?
We will collect this information from a range of sources, which will include your application form, CV, passport or other identity documents, or information provided directly by you through interviews or other forms of assessment.
We may also collect personal data about you from third parties, such as references supplied by former employers, employment agencies and social media.
Unsolicited CVs
If we receive an unsolicited CV at any time, we may retain this unsolicited data on file.
How will we use your personal data?
We will need to process your personal data:
- where we need to process your personal data to take specific steps at your request before entering into a contract with you or we need to process data to enter into a contract with you. This may include making reasonable adjustments to the recruitment process to accommodate disabilities as and when requested;
- where we need to process your personal data to comply with a legal obligation, for example if your application is successful we will check your right to work in the UK before a job offer is made;
- where our legitimate reason for processing your personal data is to enable us to gather data so that we can assess which candidate’s skills and experience best match our job role requirements and is therefore most suitable for employment. We also need to process job application information in order to respond to and defend against any legal complaints. We will process your personal data for these legitimate reasons provided that your interests and fundamental rights do not override those interests;
- where we need to protect your interests (or someone else’s interests); and
- where it is needed in the public interest or for official purposes
Who your information might be shared with
We may disclose your personal data (where it is lawful to do so) to:
- other companies within our group;
- service providers under contract with us to support our business operations, such as fraud prevention, debt collection, technology services and credit reference agents;
- our insurers and insurance brokers if you take out insurance cover through us;
- trade associations of which we are a member;
- law enforcement or government agencies in connection with any investigation to help prevent or detect unlawful activity;
- our business partners in accordance with the ‘Marketing’ section above;
- any person or agency if we need to share that information to comply with the law or to enforce any agreement we may have with you or to protect the health and safety of any person;
- any person who you have named as a person we can contact to discuss your account;
- any person who is your agent or representative, such as the holder of a power of attorney, a legal guardian or person administering a will; or
- any person who we are negotiating with as a potential buyer of our business or property or if we are proposing to merge our business with any other business or payment processors or relevant credit card providers.
If we pass data on to insurers, they may enter your data onto a register of claims which is shared with other insurers to prevent fraudulent claims. If we use an outside party to process your information, we will require them to comply with our instructions in connection with the services they provide for us and not for their own business purposes.
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example:
- access to your account is controlled by a password and user within our secure software system;
- we store your personal data on secure software; and
- information is backed up and stored on the secure server.
We have strict security and confidentiality procedures covering the storage and disclosure of your information in order to keep it safe and to prevent unauthorised access. We only allow certain authorised employees to have access to your personal information who need to use it to fulfil their job responsibilities. These employees are trained in the proper handling of customer information. Employees who do not comply with our internal rules are subject to our usual disciplinary procedures.
While we will use all reasonable efforts to keep your personal data safe, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).
Our website contains links to websites and applications owned and operated by other people and businesses. These third party sites have their own privacy policies and use their own cookies and we recommend that you review them before you provide them with personal information. They will tell you how your personal information is collected and used whilst you are visiting these other websites. We do not accept any responsibility or liability for the content of these sites or the use of your information collected by any of these other sites and you use these other sites at your own risk.
What can I do to keep my information safe?
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org Get Safe Online is supported by HM Government and leading businesses.
Transfers of my personal information abroad
We will not process any personal data in jurisdictions other than the EEA, however some of our service providers may hold personal data in jurisdictions outside of the UK. This transfer will only happen where we have specific safeguards in place to protect your personal data.
How long do we keep your personal information?
We will hold your personal information on our system for as long as is necessary for the service you have requested, for the length of time set out in any contract between us, unless you have told us you want us to remove us from the system (see section “Right to be forgotten” below) or, in the case of customers, for up to seven years in accordance with financial regulations.
What rights do you have?
Right to request a copy of your information
You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please:
- email, call or write to us (see ‘How can you contact us?’ below)
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information you want a copy of, including any account or reference numbers, if you have them
We will not charge any fee for this service in most cases.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below)
- let us have enough information to identify you (e.g. account number, user name, registration details), and
- let us know what information is incorrect and what it should be replaced with
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below). You can also click on the ‘unsubscribe’ button at the bottom of any email newsletter we may send you. It may take up to seven days for this to take place.
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone)
Right to be forgotten
You can ask us to delete the data we hold about you in certain circumstances. You can do this if it is no longer necessary for us to hold the data for the purpose it was collected (for example if you are no longer a customer), or if we are using it without your consent or you have to ask us to delete it to comply with any of your legal obligations. You can also do this if you originally gave your consent to us using your information and you want to change your mind, If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us?’ below).
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know why you would like us to delete your data from our systems.
We will take steps to make sure the information is deleted from our systems and by any people who are processing your information for us unless we have to carry on using the information for legal reasons.
How to contact us
Please contact Rafter Group UK Limited, who will handle all queries on behalf of Rafter Investco S.a.r.l, if you have any questions about this privacy policy or the information we hold about you.
If you wish to contact us, please send an email to info@rafter-group.com or write to us at Rafter Group UK Limited, 3rd Floor, 72 Borough High Street, SE1 1XF.
Changes to the privacy policy
We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access our website.
If you would like this policy in another format (for example, audio, large print, braille), please contact us.
Board of Directors
This policy applies from 30 November 2023