Himalayas Realty Group – Student Registration Privacy Policy
Effective Date: 06/05/2025
1. Introduction: Who We Are and Why This Policy Matters
Welcome! This Privacy Policy explains how your personal data is collected, used, shared, and protected when you register your interest in student housing for the 2025-2026 academic year at the University of St Andrews. This registration occurs via a web page and associated advertising campaigns managed for The Himalayas Realty Group Limited ("HRG," "we," "us," "our") by Optimise Outreach Ltd ("Optimise Outreach").
Protecting your privacy is very important to us. We are committed to complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018), and the Privacy and Electronic Communications Regulations (PECR).
Please read this policy carefully before providing your personal data and giving your consent.
2. Our Roles: Data Controller and Service Provider
Data Controller:
The Himalayas Realty Group Limited is the "data controller" for the personal data collected from you through this registration form. This means HRG decides how and why your personal data is processed.
- Company Name: The Himalayas Realty Group Limited
- Company Registration Number: SC610645 (Registered in Scotland)
- Registered Office: 120 Bothwell Street, Glasgow, G2 7JL
- For Data Protection Enquiries (HRG):
- Email: info@himalayasrealty.com
- Phone: 0131 677 1012
Service Provider Facilitating Data Collection:
Optimise Outreach Ltd provides services to HRG for this specific student registration campaign. Optimise Outreach helps HRG collect your data by running online advertisements and hosting the landing page where you submit your information. Data you submit on this page is passed through Optimise Outreach's systems to HRG. Optimise Outreach handles your data only as instructed by HRG to facilitate this collection.
- Company Name: Optimise Outreach Ltd
- For Enquiries Related to Optimise Outreach's Role:
- Email: darren@optimiseoutreach.com
- Phone: 07375 416197
Data Protection Officer (DPO) for HRG:
HRG is not currently required to appoint a formal Data Protection Officer under UK GDPR. However, you can address any data protection enquiries to HRG using the contact details provided above.
3. What Personal Data We Collect
We collect the following personal data when you use the student registration form:
Information you provide directly:
Full Name (Required): To identify you and manage your registration.
Email Address (Required): To communicate with you about your housing interest and, if you consent, to send you marketing updates.
"Tell us a bit about yourself" (Optional Free-Text Field): You may choose to provide additional information such as your studies, hobbies, or lifestyle preferences. This helps us understand your general housing needs better.
Important Note on Optional Information & Sensitive Data:
This field is for general preferences. Please do not include sensitive personal information (also known as "special category data") in this field. 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 or biometric data. HRG does not intentionally collect such data via this field.
If you have specific needs related to such sensitive information (e.g., accessibility requirements due to a disability), please contact HRG directly using their details in Section 2 so they can discuss your requirements confidentially and, where appropriate, obtain your explicit consent to process that specific information.
If you inadvertently provide sensitive information in the optional free-text field, HRG will not process it for its sensitive nature without first seeking your explicit consent for that specific purpose. If it is not relevant to your general housing interest as managed under your primary consent, or if you do not provide explicit consent for HRG to use its sensitive aspect, it may be securely deleted.
Information collected automatically:
Our website may use essential cookies that are strictly necessary for the website to function (e.g., for security or to remember your progress in a form). These do not require your consent. We do not use tracking cookies for analytics or advertising (such as a Facebook Pixel) on this registration page.
4. How We Use Your Personal Data and Our Lawful Bases for Processing
HRG will only use your personal data when the law allows. For this student registration, the uses and lawful bases are:
| Purpose of Processing | Type(s) of Personal Data Used | Lawful Basis under UK GDPR |
|---|---|---|
| To register your interest in student housing for the 2025-2026 academic year and manage HRG's communications with you related to this interest. | Full Name, Email Address, information from "Tell us a bit about yourself" field. | Consent: You provide this by ticking the checkbox: "I agree to Himalayas Realty storing my contact details to manage my interest in student housing." |
| For HRG to send you email communications regarding available student flats and related updates (marketing communications). | Email Address | Consent: You provide this by ticking the checkbox: "I consent to being contacted by Himalayas Realty via email regarding available student flats and related updates." You can withdraw this consent at any time. |
| For HRG to comply with its legal obligations or respond to lawful requests from authorities. | Relevant personal data as required. | Legal Obligation. |
| For HRG to protect its legitimate interests (e.g., website security, fraud prevention), provided your interests and fundamental rights do not override HRG's interests. | Relevant personal data as required. | Legitimate Interests. (HRG will conduct a Legitimate Interests Assessment for such uses). |
Providing Your Data:
- Providing your Full Name and Email Address is necessary for HRG to process your registration of interest. If you do not provide this information, your interest cannot be registered.
- Providing information in the "Tell us a bit about yourself" field is entirely optional.
- Ticking the consent checkboxes is necessary for the specific activities they relate to. If you don't consent to HRG storing your details to manage your interest, your registration cannot be processed. If you don't consent to marketing emails from HRG, you won't receive them.
5. Cookies
The registration page may use cookies that are "strictly necessary" for the provision of the online service you have requested (e.g., to ensure the form works correctly or for security purposes). These types of cookies do not require your consent under PECR.
We do not use non-essential cookies for tracking, analytics (like Google Analytics), or advertising (like a Facebook Pixel) on this specific student registration page. Therefore, a detailed cookie policy or cookie consent banner for such technologies is not required for this page.
6. Who We Share Your Personal Data With
HRG does not sell your personal data. HRG may share your personal data with the following categories of third parties for the purposes described in this policy:
Internal Staff at HRG:
Authorised HRG personnel who need access to your data to perform their roles (e.g., managing student enquiries, arranging viewings).
Service Providers Assisting HRG:
Optimise Outreach Ltd:
As explained in Section 2, Optimise Outreach hosts the registration landing page for HRG. The data you submit is collected via systems managed by Optimise Outreach and then passed to HRG. Optimise Outreach handles your data only as necessary to facilitate this collection and delivery to HRG, according to HRG's instructions.
Other Service Providers for HRG:
We may have to share your personal data with other parties but our aim is to do this only in limited circumstances. This will include:
- Where we have engaged those third parties to process personal data on our behalf. 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.
- If we were to sell, transfer, or merge parts of our business or our assets, we would transfer your data to the entity that acquired our business.
HRG requires third parties assisting it (including Optimise Outreach) to respect the security of your personal data, treat it in accordance with the law, and only handle your personal data for specified purposes and in accordance with HRG's instructions.
Legal or Regulatory Bodies:
If required by law, court order, or to comply with a legal obligation for HRG (e.g., law enforcement agencies, regulatory bodies).
7. International Data Transfers
HRG does not intend to transfer your personal data collected via this form outside the United Kingdom (UK) or the European Economic Area (EEA). The systems used by Optimise Outreach to host this registration page and transmit data to HRG are located within the UK/EEA.
Should any of HRG's other direct service providers (e.g., for email marketing, if used) process data outside the UK/EEA, HRG will ensure appropriate safeguards are in place as required by UK GDPR.
8. How Your Personal Data is Protected (Security Measures)
HRG has 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, access to your personal data is limited to those employees, agents, contractors (like Optimise Outreach for the purpose of data collection and transmission), and other third parties who have a business need to know. They will only process your personal data on HRG's instructions and are subject to a duty of confidentiality.
Optimise Outreach also implements security measures to protect the data transiting its systems on HRG's behalf.
Procedures are in place to deal with any suspected personal data breach, and HRG will notify you and any applicable regulator of a breach where legally required to do so.
9. How Long Your Personal Data is Kept (Data Retention)
HRG will only retain your personal data for as long as necessary to fulfil the purposes it collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, HRG considers 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 HRG processes your personal data and whether HRG can achieve those purposes through other means, and the applicable legal requirements.
- Data Processed via Optimise Outreach Systems: Optimise Outreach will ensure data submitted via the registration form is transmitted to HRG. Optimise Outreach will not retain copies of your personal data submitted via the form beyond what is technically necessary for successful transmission to HRG and for short-term operational backup related to the hosting service, after which it will be securely deleted from Optimise Outreach's systems in accordance with HRG's instructions or agreed operational procedures.
10. Your Data Protection Rights
Under UK data protection law, you have several rights regarding your personal data held by HRG. These include:
- The Right to be Informed: You have the right to be provided with clear, transparent, and easily understandable information about how HRG uses your personal data and your rights.
- The Right of Access: You can request a copy of the personal data HRG holds about you.
- The Right to Rectification: You can request HRG to correct any incomplete or inaccurate personal data it holds about you.
- The Right to Erasure (Right to be Forgotten): You can ask HRG to delete or remove your personal data where there is no compelling reason for HRG to keep processing it. This right is not absolute.
- The Right to Restrict Processing: You can ask HRG to suspend the processing of your personal data in certain situations.
- The Right to Data Portability: This allows you to obtain and reuse your personal data (that you provided to HRG and is processed by automated means based on consent or contract) for your own purposes across different services.
- The Right to Object: You have the right to object to HRG processing your personal data where it is relying on a legitimate interest. You also have an absolute right to object to your personal data being processed for direct marketing purposes.
- Rights in Relation to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, unless certain conditions are met. HRG does not currently use your personal data from this registration form for such automated decision-making that has legal or similarly significant effects.
Managing Your Consent:
You have the right to withdraw your consent at any time for any processing activities where HRG relies on consent as the lawful basis.
- For storing your contact details to manage housing interest: You can withdraw this consent by contacting HRG using their details in Section 12. Please note that if you withdraw this consent, HRG will no longer be able to manage your registered interest.
- For receiving marketing emails from HRG: You can withdraw this consent at any time by clicking the "unsubscribe" link at the bottom of any marketing email HRG sends you, or by contacting HRG directly.
Withdrawing your consent will not affect the lawfulness of any processing HRG carried out before you withdrew your consent.
11. How to Exercise Your Rights
To exercise any of your rights listed above against HRG, or if you have any questions about your rights, please contact HRG using their details provided in Section 2 or Section 13.
When you make a request to HRG, they may need to ask for specific information from you to help confirm your identity. This is a security measure.
HRG will try to respond to all legitimate requests within one month.
12. How to Make a Complaint
If you have any concerns or are unhappy with how HRG (or Optimise Outreach assisting HRG) has handled your personal data, please contact HRG first using their details below so they can try to resolve the issue:
- Email: info@himalayasrealty.com
- Phone: 0131 677 1012
- Postal Address: Data Protection Complaints, The Himalayas Realty Group Limited, 120 Bothwell Street, Glasgow, G2 7JL
You also have the right to lodge a complaint with the UK's data protection supervisory authority, the Information Commissioner's Office (ICO).
- ICO Website: www.ico.org.uk
- ICO Helpline: 0303 123 1113
We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact HRG in the first instance.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services offered. We will post any changes on this page and update the "Effective Date" at the top of this policy. If significant changes are made, HRG may also notify you through other means.
We encourage you to review this Privacy Policy periodically.
14. Contact Us
If you have any questions about this Privacy Policy or HRG's data protection practices, please contact Himalayas Realty Group:
The Data Protection Lead
The Himalayas Realty Group Limited
120 Bothwell Street, Glasgow, G2 7JL
Email: info@himalayasrealty.com
Phone: 0131 677 1012
If you have specific questions about Optimise Outreach Ltd's role in hosting the registration page for this campaign, you can contact:
Darren
Optimise Outreach Ltd
Email: darren@optimiseoutreach.com
Phone: 07375 416197