Privacy Policy

Privacy Notice
This Privacy Notice was last changed on 26 May 2022.

1     Who we are

Sigma Capital Group plc (03942129) and our group companies, including Sigma Capital Property Ltd and Sigma PRS Management Ltd (the “Sigma Group”) respect your privacy. This privacy notice sets out the way we use your information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled.

Sigma Capital Group plc and each of the Sigma Group companies are a data controller of the personal data that we/they collect and process about you. Each of the Sigma Group companies complies with this privacy notice.

If you have any questions or anything in this notice is unclear, please get in touch at the following email address: [email protected] or use the contact details in the Contact Us section at the end of this notice.

We may change portions of this privacy notice from time to time. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites and/or e-mail and/or postal mail within a reasonable period prior to the change becoming effective.

If you are a tenant or an applicant to be a tenant, using our Simple Life services, you should refer to the separate privacy notice on our website at www.simplelifehomes.co.uk/privacy. Please read that notice carefully as it provides further information on how the Sigma Group uses your personal information in respect of the Simple Life services.

2     Your information

Data Collection and Usage: General
We will collect and use your personal information for the purposes set out in more detail in this section. Your information may be shared within the Sigma Group and with some third parties.

What we collectHow we use itWhy we use it
1Information when you communicate with us whether in person, through our website or via email, over the phone or via any other medium, including:
- Your contact details;
- The details of your communications with us;
- The details of our messages to you.
We use this information to:
- Answer any issues or concerns;
- Provide you with the information and services you request from us;
- Allow our Sigma Group companies and/or designated estate agents or tenancy management partners to contact you in response to your enquiry and/or provide you with the services that you have requested;
- Develop new services;
- Improve our services;
- Personalise our service.
We use this information because:
- We require to meet legal, regulatory or other compliance obligations;
- We have a legitimate business interest in understanding customer feedback and in responding to customer communications in a consistent way;
- We have a legitimate business interest in providing and improving our services;
- We have a contractual obligation or a legitimate interest to respond to our customer requests.
2Information that we collect through your use of our website including:
- Device information such as operating system, unique device identifiers, the mobile network system;
- Hardware and browser settings;
- Date and time of requests;
- The requests you make;
- The pages you visit and search engine terms you use;
- IP address.
We use this information to:
- Provide our services;
- Develop and improve our website;
- Identify issues with the website and user's experience of it;
- Ensure that content on our website is presented in the most effective manner for you and your computer;
- Monitor the way our website is used.
We use this information because:
- We have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it across multiple devices.
3Where you are a tenant, information you provide to us relating to your tenancy (or application) or which we receive from our third party partners, such as estate agents or tenancy management partners. This information shall include:
- name, address, contact details, salary, age, gender, marital status, Whatfamily information and occupation;
- financial information including bank account details and payment details;
- details any rent arrears and other lease and tenancy information.
This information relates to tenancies in respect of properties of which we are the landlord or in respect of which we are the manager on behalf of a third party.
In particular we receive information from Ascend Estates Limited and Kinleigh Folkard Hayward (and their partners). Ascend Estates Limited and Kinleigh Folkard Hayward is a data controller of information they provide to us and you should refer to their policy for details on how they collect, hold, use and share your data. This can be found at: www.ascendproperties.com www.kfh.co.uk
We use this information to:
- Carry out credit checks (or enable our partners to carry out credit checks);
- Provide our services;
- Manage tenants and tenant applications;
- Conducting analysis on tenancy data, including location, rental growth, demographics, length of tenancy and other data to inform or improve our services, obtain portfolio valuations and raise finance
We use this information because:
- We require to meet legal, regulatory or other compliance obligations;
- We have a legitimate interest in managing our tenancies and otherwise operating our business as a property rental company.
4Information that we collect incidentally from other sources or public sources, including:
- Information available in the media;
- Information collected by security systems.
We use this information to:
- Maintain market awareness;
- Provide security to our sites;
- Answer any issues or concerns.
We use this information because:
- We have a legitimate business interest in maintaining a public profile;
- We have a legitimate business interest in providing security over our business;
- We have a legitimate business interest in understanding customer feedback and in responding to customer communications in a consistent way.
5Information that we collect from individuals representing organisations, including:
- Contact details of individuals working for organisations;
- Other personal information regarding such individuals.
We use this information to:
- Build relationships with other organisations;
- Administer our relationships with organisations that we do business with
We use this information because:
- We have a legitimate business interest in developing and maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them.
6Information that we collect from individuals attending events hosted at our premises include:
- Photographs of our event attendees taken at our events.
We use this information to:
- Share information of the events we host within our group of companies and with our tenants and prospective tenants; and
- Promote future events with assistance from select third parties.
We use this information because:
- We have a legitimate business interest in promoting our events and tenancy services.

Data Collection and Usage: Shareholders
In addition to the general uses of personal information set out above, if you are a shareholder in the Sigma Group (or you represent an individual or organisation who is a shareholder) we will collect and use personal information for the purposes set out in more detail in this section. Your information may be shared with members of the Sigma Group and with some third parties.

What we collectHow we use itWhy we use it
1When you communicate with us in relation to a shareholding, you may provide us with or we may otherwise collect personal information, such as:
- personal contact details including names, addresses, telephone numbers, and personal email addresses;
- bank account and payment details;
- shareholder account information;
- identification documentation, such as your passport;
- shareholding records (including shares held, share purchases, share disposals, dividend entitlements and payments, votes, proxy appointments);
- other communications with you.
We will collect personal information from a number of sources. These include:
- Directly from you when you complete forms, use our website, provide documentation to us or communicate with us;
- Third parties authorised by you;
- Your and our professional advisors: such as share registrars, lawyers, accountants, financial advisors or brokers;
- credit reference agencies, money laundering check providers;
- Government bodies, the Police or law enforcement and our regulators.
Administering the shareholding (directly with you or through your or our representatives), including maintaining shareholder records, making shareholder announcements, providing shareholder communications (including the provision of reports and accounts), receiving money and/or making payments (such as in respect of dividends and share sale proceeds) and dealing with enquiries, complaints and other communications.
We will also use your personal information for:
- dealing with any legal disputes;
- complying with any regulatory requirements;
- retaining records relating to the Sigma Group and the shareholdings in it.
We use this information:
- To perform and administer our contract with you regarding a shareholding;
- To comply with any legal obligations and regulatory requirements;
- For our legitimate interests, such as the maintenance of up to date shareholder records and the efficient handling of queries, complaints and other communications;
- To establish, defend or bring legal claims.

Direct Marketing
We may use personal information you give us for direct marketing purposes to provide updates; newsletters; events; offers or other communications that we think may interest you. We will only do this with your consent or where we otherwise have a legitimate interest to do so and are permitted by applicable law. We may share personal information with third parties to help us with our marketing and promotional projects, or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, post  and other forms of communications from us or our promotional partners in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:

  • Click “unsubscribe” at the bottom of an email we sent you.
  • e-mail us using [email protected] or contact us using the details set out in the Contact Us section.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you or respond to your inquiries or complaints, and similar communications.

Automated Processing
We make automated decisions regarding you in the following situations: credit checks and background checks relating to a tenancy. These may be undertaken by third parties acting on our behalf, such as Ascend Properties and Kinleigh Folkard and Hayward (KFH) who in turn use third parties, including  Let Alliance (www.letalliance.co.uk) and Homelets (www.homelet.co.uk).

We will conduct our credit check on you prior to a tenancy commencing. We will conduct a search against your available credit file. If our search against your credit file illustrates to us that you have an inappropriate credit rating, a decision will be taken automatically to not proceed with your application to become a tenant.

Submitting to a credit reference check is necessary for us to offer you a tenancy. If this information is not provided we cannot agree to provide a tenancy to you.

If you disagree with the decision you are entitled to contest this by contacting us at the following email address: [email protected]

Legal Requirements
Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

If you do not provide us with the requested personal information we may not be able to progress our dealings with you, including with respect to any shareholding in the Sigma Group.

Information we share
There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

  • We may share information about you among members of our group of companies so we can provide the best service across our group. Each Sigma Group member is bound to keep your information in accordance with this privacy notice;
  • In respect of tenants we share your data with our service providers, such as Ascend Properties and KFH, who provide tenant management services for us. Ascend Properties and KFH is a data controller of your information and you should refer to their policy for details on how they collect, hold, use and share your information. This can be found at: www.ascendproperties.com and www.kfh.co.uk. Where we are a manager upon behalf of a third party we may share certain information with them, relating to the properties in respect of which we manage on their behalf;
  • In respect of shareholders we will share personal information with Link Asset Services who manages our share register and provide associated services. Link Asset Services shall be a data controller in respect of the information that they hold about you. Please review their privacy notice at www.linkassetservices.com/privacy-policy. We will also share personal information with payment providers who help us manage dividend and other payments to our shareholders;
  • Solicitors and professional services firms how provide us with legal support in relation to our services or any legal claims;
  • We may also share your information with the following other certain contractors or service providers, including those who provide and help operate our IT and back office systems. This includes Zypha Limited;
  • Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function; and
  • We may also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you or to fulfil our legitimate interests in promoting our services.

Your personal information may also be transferred to other third party organisations in the following scenarios:

  • If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
  • If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
  • If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police, HMRC and the Information Commissioner’s Office;
  • If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Finally, your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Where your information will be held
When we share your information, your information may be transferred outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Please also note that our directors and other individuals working for us may in limited circumstances access personal information outside of the EEA if they are travelling outside of the EEA. If they do so access to personal information will be subject to using our security measures.

How long your information will be held
We will keep your data for as long as it is reasonably necessary, depending upon the type of information and the reason why we collected it from you. It will depend on a number of factors. The criteria we may use to determine the retention period for certain categories of data includes:

  • whether there is any ongoing contractual, legal or financial claim that relates to your relationship with us; and
  • whether any applicable law, statute, or regulation allows for a specific retention period; and
  • what the expectation for retention was at the time the data was provided.

Generally, where there is no legal requirement we will retain physical and electronic records for a period of 6 years after your dealings or communications with us, for the eventuality of any legal dispute arising out of them.

3     Your rights

You have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at [email protected] or in one of the ways provided in the Contact Us section at the end of this privacy notice.

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and certain other information about it to check that we are lawfully processing it.

Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.

Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: you may request the transfer of certain of your personal information to another party.

Objection: where we are processing your personal information based on a legitimate interests (or those of a third party) you may challenge this.  However we may be entitled to continue processing your information based on the our legitimate interests or where this is relevant to legal claims.  You also have the right to object where we are processing your personal information for direct marketing purposes.

Automated Decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

More information regarding your legal rights in respect of personal information can be found at www.ico.org.uk/for-the-public/. You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where we are based, or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner’s Office (Tel: 0303 123 1113 or at www.ico.org.uk).

Cookies
We use cookies that identify your browser or device. They collect and store information when you visit our website about how you use it. For more information about cookies, the types of cookies we use and how we use them please see our Cookies Notice.

Security
We are committed to keeping your personal information safe. We’ve got physical, technical and administrative measures in place to prevent unauthorised access or use of your information. However, the Internet is an open system and we cannot and do not guarantee or warrant the security of any information that you transmit on or through our Website or that we otherwise maintain.

Changes to the Notice
This notice will be changed from time to time. If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.
If you would like to access previous versions of this privacy notice please contact us using the details in the Contact Us section.

Contact Us
It is important to ensure that the personal information we hold about you is accurate and up‐to‐date, and you should let us know if anything changes. You can contact us using the details below.

If you are a shareholder you may contact us or our registrars using the details below.

Sigma Group: If you have any questions about this privacy notice please contact us: using [email protected] or on 0333 999 9926, or at 18 Alva Street, Edinburgh EH2 4QG.

Registrar: Please contact Link Asset Services: using the contact details set out at LinkAssetServices.com.