Arland Property (App) Limited (“Maiwai”) takes your privacy very seriously.
This policy explains the nature of the relationship between Maiwai and the building management team (“Management Team”) that operate the buildings in which Maiwai provides its services. It is important for the purpose of our business that we share data with the Management Team to provide our services to you. Maiwai and the Management Team will be independent controllers when handling your personal data.
- What personal data we collect about you;
- How we collect your personal data;
- How we use your personal data;
- The basis on which we use your personal data;
- Who we share your information with;
- How long your personal data will be kept;
- Transferring your personal data outside of the European Union;
- The steps we take to protect your personal data;
- The rights you have in relation to your personal data; and
- How to contact us about this policy.
Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (GDPR), the Data Protection Act 2018, other relevant UK and EU legislation and our professional duties to clients.
Arland Property (App) Limited, registered in England under the Companies Acts, registered number 11788746 and having its registered office at 58 Grosvenor Street, London, England, W1K 3JB.
Contact information for our Data Privacy Manager is provided below under the heading “How to contact us about this policy”.
What personal data we collect about you
We will collect information from you when you use our website and App, including when you visit buildings and premises that enable the use of our App.
Personal data your employer provides to allow you to access the MaiWai App
- name, email address, telephone number.
Personal data you provide when using our services and the MaiWai App
The personal information we may collect about you includes:
- Data that identifies you such as your name, title, address, telephone number, mobile phone number, job title, name of employer, and email address;
- Information about your in App activities, including, purchases, sales, time and location of transactions;
- Information about your geographical location through your GPS and IP address;
- Financial information (e.g. credit card and account numbers, payment details) in connection with a MaiWai shop transaction;
- Data that we collect about your use of our website and App including your password(s), and other monitoring information or information relating to communications we send to you electronically;
- Content that you share with other users through our messaging tools, noticeboard, ride sharing (registration plate), room bookings, parcel deliveries;
- You may provide us with additional information by updating or adding information to your MaiWai account, by participating in community discussions, member chats, ride sharing, inquiries, dispute resolution, customer service calls recorded with your consent, or if you contact us for any other reason regarding our services.
Data that we collect automatically when you use our services and the MaiWai App
- Data that is generated as part of one of your use of the App (directions/navigation, purchases, sales, ride sharing, accessing buildings) or that is linked to your MaiWai account as a result of a transaction in which you are involved, including the time and location of transactions;
- Data that is generated through your other actions when you use our App and which is linked to your MaiWai account;
- Data regarding all other interactions with our App, including your advertising preferences and nearby offers that you access via our App;
- Location data, including the location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device;
- Computer and connection information, such as statistics regarding your use of the App, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your App and building access times, your browser history data, your language settings and your weblog information;
In general, you will be able to choose whether or not to provide us with your personal data. If you do not provide the personal data that we need to collect then this may affect our ability to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you, including use of the App.
How we collect your personal data
We collect most of this information from you:
- When the organisation that you work for provides us with your details to create a MaiWai account;
- When you register for a MaiWai account;
- When you browse, provide information or use our App or website;
- When you contact us or make an enquiry;
- Where you sign up to receive information from us;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so. We will usually use your personal data to provide you with the services via the App.
This will be for one of the following reasons:
- To comply with our legal and regulatory obligations;
- For our legitimate interests or those of a third party;
- For the establishment, exercise or defence of legal claims or proceedings; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We may process special category personal data for the following reasons:
- Where you have given your explicit consent;
- For compliance with a legal obligation;
- For the purposes of establishing, exercising or defending legal claims;
- Where it is in your vital interests;
- Where you have made the personal data public; and/or
- For compliance with an employment law obligation.
There may be additional reasons which will be notified to you where they apply.
When we refer to special category data we mean information such as about race or ethnicity, religious beliefs, sexual orientation, marital status and health.
In general we will only collect data to allow us:
- To provide the App and website to you, including but not limited to enabling and performing transactions and communications with other users (including the transmission of your personal data to other users where necessary to perform the transaction), providing and enhancing features such as and MaiWai account management, providing other services you may use (as described in connection with such services), and ensuring the functionality of our services; and
- Processing of general location data (such as IP address or postcode) in order to provide you with location-based services.
Managing our business
In relation to a number of uses of personal data we refer to above we are using such personal data on the basis that it is in our legitimate interests or those of a third party for us to do so. These interests cover a number of aspects of our business operations, namely, ensuring that we are as efficient as we can be so we can deliver the best service for you at the best price.
We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at firstname.lastname@example.org;
- Using the ‘unsubscribe’ link in any emails that we send to you.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future. You can also update your marketing preferences and give us more detail of the type of information you would like to receive from us.
Use of website and App
Our website and App makes use of Google Analytics and Crashlytics to look at how our website is used. This is done by placing small text files, known as session cookies, on your device to collect information about how visitors use our website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This information is transmitted to and stored by Google servers in Dublin, Ireland.
Who we share your personal data with
We share personal data with:
- The Management Team, including managers of the buildings that use the App where required for the purposes of providing services (e.g. facility management services, building access using near field communication technology);
- Your employer;
- Other users of the App when you use the interactive services (e.g. MaiWai shop, ride share);
- External service suppliers, representatives and agents that we use to make our business more efficient, e.g. technology service suppliers (including Doordeck Limited), marketing agencies, document collation, translators or analysis suppliers;
- Courts, law enforcement authorities, regulators or lawyers or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process or to comply with our legal and regulatory obligations.
We will only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you and to ensure compliance with data protection laws.
We may share aggregated information with other tenants of the building on an anonymised basis.
We may also, should the need arise, need to share some personal data with other parties, such as during a re-structuring or sale of our business. Usually, information will be anonymised but this may not always be possible.
The recipient of the information will be bound by confidentiality obligations.
We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
Other than as set out above, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
How long your personal data will be kept
- Legal and regulatory requirements and guidance;
- Limitation periods that apply in respect of taking legal action;
- Our ability to defend ourselves against legal claims and complaints; and
- The operational requirements of our business.
When it is no longer necessary to retain your personal data (for example when you leave the employment within a building that makes use of the App), we will delete or anonymise it. If you would like more information about how long we hold particular types of personal information then please contact us on email@example.com.
Updating personal data about you
We also need to know that your information is accurate and up to date so please advise of any changes on firstname.lastname@example.org. You should also use this email address if you want to cancel any request you have made to us or you become aware of any inaccuracy in the data we hold about you.
Transferring your personal data out of the European Union
To deliver services to our clients, it is sometimes necessary for us to share your personal data outside the European Union (EU), e.g.:
- Where our service providers are located outside the EU;
- If you are based outside the EU.
These transfers are subject to special rules under European and UK data protection law.
We will, however, implement appropriate safeguards to ensure the transfer complies with European and UK data protection law and all personal data will be secure. If you would like further information on these safeguards please contact email@example.com (see How to contact us about this policy below).
The steps we take to protect your personal data
We will take appropriate technical and organisational measures to keep your personal data confidential and secure. We have appropriate security measures in place which take account, in particular, of the risks arising from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
The rights you have in relation to your personal data
You have the following rights, which you can exercise free of charge:
You can ask us or the building owner to:
- Provide a copy of your personal data;
- Correct any mistakes in your personal data;
- Delete your personal data – in certain situations;
- Restrict processing of your personal data – in certain circumstances, e.g. if you contest the accuracy of the data; and
- Provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
You can object:
- At any time to your personal data being processed for direct marketing (including profiling);
- In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
If you would like to exercise any of those rights, please email us on firstname.lastname@example.org.
Your objection (or withdrawal of consent) may mean we cannot perform the services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
You also have the right to complain to the supervisory authority in the part of the European Union where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner so we would ask that you contact us in the first instance.
Our contact details can be found in the section below
How to contact us about this policy
MaiWai Data Manager, 58 Grosvenor Street, London.
This privacy notice was last updated in December 2019.