Locale Data Processing Notice


1. Important information

1.1 Purpose of this notice

This notice aims to give you information about the personal data that Locale’s Website/Portal can collect and process on your behalf.  It sets out the scope, nature and purpose of processing by Locale, the duration of the processing and the types of Personal Data and categories of Data Subject.

1.2 Definitions

In this notice the following terms have the meaning given below:

Data Protection Legislation: the UK Data Protection Legislation and (for so long as and to the extent that the law of the European Union has legal effect in the UK) the General Data Protection Regulation ((EU) 2016/679) and any other directly applicable European Union regulation relating to privacy.

Locale: Locale Limited incorporated and registered in England and Wales with company number 05688298 whose registered office is at Beaver House, Hythe Bridge Street, Oxford, England, OX1 2EP.

UK Data Protection Legislation: any data protection legislation from time to time in force in the UK including the Data Protection Act 1998 or 2018 or any successor legislation.

Website/Portal: the website through which Locale makes its software available to you for the purposes of managing commercial, residential and mixed-used properties and property portfolios.

We will be referred to collectively as “Locale”, “we”, “us” or “our” in this notice.

You will be referred to as “the Customer” or “you”.

The terms Data Controller, Data Processor, Data Subject and Personal Data have the meaning given to them in the UK Data Protection Legislation.

1.3 Data Processor

For the purposes of the Data Protection Legislation, Locale is the Data Processor and you, the Customer, are the Data Controller for your personal data.

1.4 Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 21st May 2018.  Historic versions can be obtained by contacting us.

1.5 Third-party links

Locale’s Website/Portal may include links to third-party Website/Portals, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Website/Portals and are not responsible for their privacy statements.

2. Processing

2.1 Scope

We will only process personal data about Data Subjects on your written instructions to do so unless we are required to otherwise process that personal data as a result of any law of the United Kingdom, of the European Union or other member state of the European Union or any other law that applies in the United Kingdom to do so.

2.2 Nature

Further details of the types of personal data our Website/Portal collects and processes is set out below. 

Our Website/Portal does not collect any Special Categories of Personal Data about Data Subjects (this includes details about their race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health and genetic and biometric data).  Nor does our Website/Portal collect any information about criminal convictions and offences.

2.3 Purpose

We have set out below a description of the ways you may use the personal data you have collected and stored in our Website/Portal.


Type of data

To register a new user within our Website/Portal

(a) Identity

(b) Contact

To process and deliver services to users including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to you

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

To manage your relationship with users which will include:

(a) Notifying you about changes to your terms or privacy policy

(b) Asking users to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

To enable users to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

To administer and protect our business and this Website/Portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

To deliver relevant Website/Portal content and advertisements to your users and measure or understand the effectiveness of the advertising you serve to them

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

To use data analytics to improve our Website/Portal, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

To make suggestions and recommendations to users about goods or services that may be of interest to them

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

2.4 Duration

We may process the personal data of Data Subjects for the duration of our agreement with you and thereafter until such time as

  • we receive your written instructions following the termination of our agreement with you to delete or return that personal data to you;
  • you require us to delete that personal data in accordance with your data retention policy which you send to us in writing; or
  • where you have not given us your written instructions or sent us your data retention policy, we will retain the personal data of Data Subjects held in our Website/Portal in accordance with our Data Retention Policy, a copy of which is available on request.

In each case we will delete the personal data we store when we are required to delete it unless we are required to store that personal data as a result of any law of the United Kingdom, of the European Union or other member state of the European Union or any other law that applies in the United Kingdom.

3. Types of Personal Data our Website/Portal can collect

3.1 Personal Data

You may use our Website/Portal to collect, use, store and transfer different kinds of personal data about a Data Subject.  We group them together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, the Data Subject’s login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices the Data Subject uses to access our Website/Portal.
  • Profile Data includes the Data Subject’s username and password, requests to use resources made by the Data Subject, the Data Subject’s interests, preferences, feedback and survey responses.
  • Usage Data includes information about how the Data Subject uses our Website/Portal.
  • Marketing and Communications Data includes Data Subject’s preferences in receiving marketing from you (and third parties) and Data Subject’s communication preferences.

3.2 Aggregated Data

Locale also collects, uses and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from the Data Subject’s personal data but is not considered personal data in law as this data does not directly or indirectly reveal the Data Subject’s identity. For example, we may aggregate Data Subjects’ Usage Data to calculate the percentage of users accessing a specific Website/Portal feature.

4. Categories of Data Subject

4.1 Data subject

You may use our Website/Portal to collect, use, store and other otherwise process personal data about any category of Data Subject whom you ask us to set up within the Website/Portal.  Typically, our Website/Portal is used to collect and process personal data about the following categories of Data Subject:

  • your employees, agents and independent contractors;
  • owners of the freehold or leasehold of the property you manage through our Website/Portal (Property);
  • investors in any Property;
  • employees, agents, independent contractors, members or directors of any company or other corporate entity which owns a Property;
  • lenders to the owner of a Property (Lenders);
  • employees, agents, independent contractors, members or directors of Lenders;
  • tenants or licensees of any commercial, industrial or residential unit with any Property (Tenants); and
  • employees, agents, independent contractors, members or directors of Tenants.