Privacy Policy

Privacy Policy Overview

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 MyDomo 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 Domo Student, the trading name under which student accommodation is operated. The accommodation is managed by Moda Life Limited (ICO registration ZB428803) acting as Data Processor on behalf of each Operating Company (the Data Controller) under a Property Management Agreement. For the purposes of this Privacy Policy all entities will be referred to as Domo Student.

The following entities and their ICO registrations are covered by this Privacy Policy:

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

1. Management Structure and Data Processing Relationship

Domo Student is the trading name under which student accommodation services are provided to residents. Each property is owned and operated through a dedicated Operating Company (OpCo), which acts as the Data Controller in respect of all personal data processed in connection with that property.

• Moda Life Limited acts as Data Processor on behalf of each OpCo under a Property Management Agreement (PMA). Under this arrangement:
• The relevant OpCo (as Data Controller) determines the purposes and means of processing residents' personal data.
• Moda Life Limited (as Data Processor) processes personal data only on the documented instructions of the relevant OpCo, in accordance with Article 28 of the UK GDPR.
• A Data Processing Agreement is in place between each OpCo and Moda Life Limited, setting out the subject matter, duration, nature and purpose of processing, the types of personal data involved, and the categories of data subjects.
• Moda Life Limited remains fully liable to the relevant OpCo for any failure by its sub-processors to fulfil their data protection obligations.
• Where personal data is collected through the Domo Student brand — including through enquiry forms, the resident portal, or the MyDomo App — it is processed by Moda Life Limited on behalf of the relevant OpCo. The identity of the relevant OpCo for your property is available on request using the contact details in Clause 11.

2. Who We Are

Domo Student is a developer and operator of student accommodation for rent in the UK.

3. Personal Data

• The business uses the information collected from you to provide quotations, make telephone contact and to email you information concerning your enquiry.
• For marketing purposes, Domo Student 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.
• When you make initial contact, including through website enquiries, you agree to Domo Student 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.
• 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.
• The business will only collect the information needed so that it can provide you with the services it provides; Domo Student does not sell or broker your data.
• 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.
• 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 Domo Student 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 residents will be processed using contractual as the applicable lawful basis for processing.

Consent

In certain circumstances Domo Student 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

Domo Student 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 MyDomo App, legal and debt collection services are outsourced from third-party suppliers.

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

Domo Student 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

Domo Student 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 Domo Student'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 Domo Student 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 Domo Student 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 Domo Student 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, Domo Student 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 Domo Student 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

Domo Student 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 Domo Student 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 Subject's Rights or ask Domo Student 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.

Section 2
Applies Only to Residents Resident Addendum Privacy Policy

12. Contractual

By signing your tenancy application, you are also as part of this contract, agreeing to Domo Student 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 Domo Student 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. Domo Student 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 from receiving promotional information.

15. Our Use of Your Personal Information

Domo Student will need to use your personal data to provide the services Domo Student 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 Domo Student's data protection officer, using the contact details at the end of Section 1.

Section 3
Applies Only to Residents Using the MyDomo App

Resident Addendum — MyDomo App Privacy Policy

16. About the MyDomo App

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

The MyDomo App is designed and administrated by Concurrent. The app allows residents access to certain information, facilities and services during the course of their tenancy agreement.

Domo Student residents are required to use the MyDomo App for certain building activities, which is a contractual part of your tenancy agreement. Additional information about the MyDomo App is included in a separate policy document which appears when you first use the app.

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

17. MyDomo App Mandatory Information

The core features provided by the MyDomo App 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 Domo Student's third-party service partners.

18. MyDomo App Data Security

For your security all service providers using the app have signed a MyDomo App 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.

19. MyDomo App Access

Subject to your agreement and appropriate scoring and other checks, the relevant Operating Company will make a tenancy offer to you. Once finalised, Domo Student will make available its MyDomo App.

20. MyDomo App Mandatory Features

The App provides certain core mandatory facilities for all residents.

MyDomo App Maintenance Support

This allows residents to be notified of essential maintenance in the building. Residents can also book property repairs with the onsite Domo Student 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 signatories to a legally binding processing agreement.

Utopi

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 is used for best practice management.

Utopi, Unit 1 Eastworks, 1 Gateway Court, Glasgow, Scotland, G40 4DS.

Privacy Policy: https://utopi.co.uk/privacy-policy/

If you have any data protection questions concerning the MyDomo App please contact Domo Student using the contact details in Clause 11.

Employees

21. Separate Privacy Policy Addendum for Employees

A separate Privacy Policy Addendum is provided for employees. Please ask your line manager for a copy.