MODA - COMBINED UK GDPR PRIVACY POLICY

**For the purposes of Data Protection, Moda is the Data Controller. **

1 - Scope
This Privacy Policy is split into three sections:
Section 1 - covers all Data Subjects including enquiries, residents and employees
Section 2 - applies only to Residents
Section 3 - applies only to Residents using the MyModa App

A Privacy Policy Addendum is available for employees, please ask your manager.

Section 1 - applicable to All Data Subjects

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject).

The 2018 Data Protection Act and the UK General Data Protection Regulation (UK GDPR), along with the Privacy and Electronic Communications Regulations (PECR) and the Data (Use and Access) Act 2025 (DUAA), all seek to protect, enhance and clarify the rights of data subjects. These rights cover the safeguarding of personal data and protect against the unlawful processing of personal data.

This Privacy Policy is for Moda Living Ltd, Moda Life Management Ltd and for the other trading names, which are all listed below:
Moda Life Management Ltd - ICO registration ZA817563
Moda Living Ltd - ICO registration ZA817519
Moda Life Ltd – ICO registration ZB428803
Angel Gardens Opco Limited, Angel Gardens, Manchester - ICO registration ZA600499
Broad Street Opco Limited, The Mercian, Birmingham - ICO registration ZB284248
Soyo Opco Limited – New York Square, Leeds - ICO registration ZB332956
Springside Opco Limited – The McEwan, Edinburgh - ICO registration ZA831163
Tower One Opco Limited – The Lexington, Liverpool - ICO registration ZA831156
Sackville Street OpCo Limited – Hove Central, Hove – ICO registration ZB690413
Holland Street OpCo Limited – Holland Park, Glasgow – ICO registration ZB690412
Birmingham OpCo Limited – Loudon’s Yard, Birmingham – ICO registration ZB689211

For the purposes of data protection and this Privacy Policy all entities will be referred to as Moda.

All data subject requests should be sent to the contact details provided in Clause 11 below.

Moda is pleased to provide the following information:

2 - Who we are

Moda is a developer and operator of homes for rent in the UK.

3 - Personal data

a) The business uses the information collected from you to provide quotations, make telephone contact and to email you information concerning your enquiry.
b) For marketing purposes, Moda may use the contact details provided by you to respond to your enquiries including making telephone contact and emailing information to you which we believe may be of interest to you.
c) When you make initial contact, including through website enquiries, you agree to Moda maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. At all times, the business will work hard to be fully UK GDPR compliant.
d) Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence, when you visit us, from phone calls and details of your visits to our website, including but not limited to personally identifiable information like Internet Protocol (IP) addresses.
e) The business will only collect the information needed so that it can provide you with the services it provides; Moda does not sell or broker your data.
f) Telephone calls may be recorded for training and security reasons and this will be announced at the start of the call. Where recorded, call data is retained no longer than six months unless it is required longer for legal reasons.
g) Information exclusively pertaining to data protection and employees is covered in their employment contract and the Company Handbook.

4 - Legal basis for processing personal data

Legitimate Interests – Where possible Moda relies on legitimate interests when responding to enquiries concerning the services provided and for marketing purposes such as sending a newsletter. Legitimate interests also include direct mail, email, telephone calls, WhatsApp, social media and any other channels to reach those who may be interested in renting or using the facilities provided by the business.

Contractual - where possible personal data belonging to tenants will be processed using contractual as the applicable lawful basis for processing.

Consent - in certain circumstances Moda requires the consent of residents to share their data with certain third parties, this could include explicit consent where special categories of personal data are involved such as medical information.
Compliance with a legal obligation - in certain circumstances the business may need to disclose your Personal Information to meet legal, regulatory or valid governmental requests.

5 – Data sharing

Moda will keep your personal information safe and secure, although our administration team will have access to your contact details so that they can manage your account.

Some of the services used to support the business such as marketing, website management, the MyModa App, legal and debt collection services are outsourced from third-party suppliers.

Moda will only share data where necessary to provide the services it is contracted to provide, such as when data processing is outsourced, or to enforce its contractual rights and to protect tenants.

Moda will always put in place with any third-party suppliers a data processing agreement.

Moda may also disclose Personal Information to enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.

6 - Retention policy

Moda will process personal data for the duration of any business dealings and will continue to store only the personal data needed for up to eight years after any contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details and/or liabilities. For more details a copy of Moda’s Document Retention Schedule is available on request.

7 - Data storage

Data is predominantly processed within the UK and through HubSpot, which for the purposes of European data processing utilises cloud storage in Germany. For your protection HubSpot and Moda have signed Standard Contractual Clauses to allow overseas data transfers. Certain personal data is also held within Microsoft SharePoint for Business, which is hosted on a UK located Microsoft cloud server.

8 - Your rights as a data subject

At any point whilst Moda is in possession of or processing your personal data, all data subjects have the following rights:
• Right to information - you can ask for information about what data is being processed and the rationale for such processing.
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to withdraw consent – you have the right to withdraw your consent at any time.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Moda refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

At your request, Moda can confirm what information it holds about you and how it is processed.

9 - You can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Moda and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, restrict, object to processing and rights to erasure.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

10 - To access what personal data is held, identification may be required

Moda will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months.
A minimum of one piece of photographic ID listed above and a supporting document is required. If Moda is dissatisfied with the quality, further information may be sought before personal data can be released.

11 - Data Subject’s Rights

To exercise your Data Subjects Rights or ask Moda about how your personal data is being processed, please contact the Data Controller using the details below. If you do not get a response within 30 days you can then complain to the ICO.

Moda
The Data Protection Administrator
Central House, Beckwith Knowle, Otley Road, Harrogate, North Yorkshire, HG3 1UG
Telephone: 01423 560200 or email: dpo@modaliving.com

ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113 or email: https://ico.org.uk/global/contact-us/email/

Section 2 - this applies only to Residents

Resident Addendum Privacy Policy

For those with tenancy agreements with Moda, additional information may need to be collected. Only that information necessary for Moda to fulfil its obligations will be collected.

12 - Contractual

By signing your tenancy application, you are also as part of this contract, agreeing to Moda sharing your details (on the basis of contractual) with relevant landlord’s agents and/or consultants. This may also include retaining certain personal information you provide. In certain circumstances Moda may also need your explicit consent to process some limited special categories of personal data for the purpose of administering your tenancy agreement, to protect you and to support the delivery of services in relation to the lease. If you refuse to give explicit consent or withdraw your consent, we may not be able to provide the service required.

13 - Moda promotional material

When you are contacted to introduce a newsletter, survey, service provider or other promotional material relating to your tenancy, you will be given the opportunity to opt out of these if you so wish, and the same opportunity to unsubscribe from any subsequent communications.

14 - Service emails

Certain information appertaining to the contractual aspects of your tenancy agreement and building management will continue to be sent to you even if you have unsubscribed out of receiving promotional information.

15 - Our use of your personal information

Moda will need to use your personal data to provide the services Moda is contracted to provide you, as detailed within this tenancy agreement. A copy of the personal information that is processed and further details of your rights can be accessed via Section 1 of this privacy notice. If you have any questions, please contact Moda's data protection officer, using the contact details also at the end of Section 1.

Section 3 - this applies only to Residents using the MyModa App

Resident Addendum MyModa App Privacy Policy

16 - About the MyModa app

To help you understand the privacy issues relating to the MyModa app we have produced this guide, which we would ask you to spend a few minutes to read.

MyModa is an app, designed and administrated by Spike Global Limited. The app allows residents access to certain information, facilities and services during the course of their tenancy agreement.

Moda Residents are required to use the Moda App for certain building activities, which is a contractual part of your tenancy agreement. Additional information about MyModa is included in a separate policy document titled Data Privacy Extra MyModa, which appears when you first use the MyModa App.

The MyModa App requires the use of a smartphone running either iOS or an Android device. It is also possible to access certain services (but not all) from a web browser.

17 - MyModa mandatory information

The core features provided by MyModa are required by residents to gain building access and enjoy the benefits of their residency, however you can opt out of notifications about promotions and events offered by Moda's third-party service partners.

18 - MyModa data security

For your security all service providers using the app have signed a MyModa data processing agreement. This is a legally binding document to protect your personal data. In addition, other contractual arrangements are also in place to protect your personal data. Please see ‘Data Privacy MyModa’ which is also available when you download the app or sign up to the MyModa resident portal.

19 - MyModa and Canopy

When you apply for a tenancy agreement, you will initially be directed to apply through Canopy, a credit reference service that operates independently of Moda Living. Canopy operates its own website and app and this should not be confused with MyModa. Canopy will only share your credit scoring and other details appertaining to your application for a tenancy agreement with Moda Living and Moda Life Management Limited when you have given your consent.

The supplier’s details are: Canopy, which is the trading name of InsureStreet Limited. 1st Floor One Suffolk Way, Sevenoaks, Kent, England, TN13 1YL.

The provider’s Privacy Policy is available here: https://www.canopy.rent/legal

20 - MyModa App access

Subject to your agreement and appropriate scoring and other checks, Moda Living will make a tenancy offer to you. Once finalised Moda will make available its MyModa App.

21 - MyModa mandatory features

The App provides certain core mandatory facilities for all residents.

21.1 Door access - the door entry part of the app is provided by a third-party supplier called SALTO Systems which also owns Clay. Salto Systems and Clay allow entrance to the front door and your apartment. Salto also accesses the building cameras so that you can see who is at your apartment door before opening it.

The supplier details are: SALTO Systems Limited, Unit 1 The Court, Holywell Business Park, Northfield Road, Southam, Warwickshire - CV 47 OFG.

The provider’s Privacy Policy is available here: https://saltosystems.com/en-gb/legal-data/privacy/privacy-policies/salto-systems/

21.2 MyModa maintenance support - this allows residents to be notified of essential maintenance in the building. Residents can also book property repairs with the onsite Moda team. Where details need to be shared with external contractors, the amount of personal information given to them will be the minimum necessary to complete the required work. Any third-party suppliers are signatures to a legally binding processing agreement.

21.3 Energy bills – Amber, via Community Utilities, provides a paperless bill management service for handling all your water, gas and electricity payments.

The supplier details are: Amber, One Central Square, Cardiff, CF10 1FS.

The provider’s Privacy Policy is available here: https://www.amber.net/privacy-policy/

21.4 Bringme - offers a parcel service for residents and couriers. By signing up to Bringme Box when you move in you can benefit from 24-hour access to a secure parcel locker designed to suit all parcel sizes. Automatic delivery of parcels and correspondence, which will be left in your locker in reception. Bringme can provide an electronic signature and eliminates the need for you to wait for delivery people.

Bringme operates its own website and app and this should not be confused with MyModa.

The supplier’s details are: Bringme, 64 Tower Bridge Road, London SE1 4TR.

The provider’s Privacy Policy is available here: https://help.bringme.com/hc/en-us/articles/360004883893-Privacy-Policy

21.5 Utopi - provides an ongoing analysis of energy data and the usage of your apartment, as well as in the amenity spaces including the dining room, gym and building. All data is retained in an anonymised encrypted format and personal identifiable data is not collected. The data is used for best practice management and the data specifically about your apartment is provided to each resident individually via the MyModa app so that they can see the energy usage of their apartment and other useful information.

The supplier’s details are: Unit 1 Eastworks, 1 Gateway Court, Glasgow, Scotland, G40 4DS.

The provider’s Privacy Policy is available here: https://utopi.co.uk/privacy-policy/

If you have any data protection questions concerning the MyModa app please contact Moda by using the contact details in Clause 11, at the end of Section 1.

Employees

22 - Separate Privacy Policy Addendum just for employees

A separate Privacy Policy Addendum is provided just for employees, please ask your line Manager for a copy.