Privacy Policy for EDEN

What information do we collect?

We collect or use the following information to provide and improve products and services for clients, for the operation of client or customer accounts, to protect client welfare, deal with queries, complaints or claims and to comply with legal requirements:

  1. Homestay Hosts (Host Families”):

 

  • Personal information about residents in homestay, including about any children and frequent visitors to the home. This is provided by you during the registration process via our host application (or enquiry) form, email or subsequently via dialogue after registration with us.

 

  • Information recorded during the home inspection visit, such as identify documentation, feedback on suitability to host students and the make-up of the accommodation. This also includes photographs of accommodation (student room(s) and communal areas including exterior of the home).

 

  • Bank details in order to make payments to hosts for students or homestay guests placed with them.

 

  • Changes to your home (e.g additional bedrooms available or changes to your guest preferences) as indicated by you or as obtained during subsequent re-inspection visits.

 

  • Feedback (including complaints) from homestay guests or educational clients.

International Students/Homestay Guests

  • Personal information such as name, gender, nationality, contact details (mobile number and email address), purpose of visit to UK, special requirements (such as medical issues or dietary needs) and other accommodation preferences.

 

  • Visa information for students requiring a UK visa.

 

  • This information is provided by you during the application process via our homestay application (or enquiry) form, email or in subsequent dialogue with us.

General

  • Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

 

  • Statistical and other analytical information collected on an aggregate basis of visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses, browser types and other anonymous statistical data involving the use of the website.

 

  • This website places and accesses certain Cookies on your computer. Urban Hub uses Cookies to improve your experience of using our site and to improve our services. Urban Hub has carefully chosen these Cookies and has taken steps to ensure that your privacy is respected at all times. All Cookies used by this website are used in accordance with current UK and EU Cookie Law.

 

  • You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please refer to the help menu in your internet browser. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.  It is recommended that you ensure that your internet browser is up to date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings

Why does the Urban Hub process personal data?

Urban Hub needs to process data to be able to provide its homestay services. Urban Hub provides a student to host family matching service on behalf of language schools, universities and international “study agents” and requires personal data from homestay hosts and from homestay guests in order to carry out this service.

Urban Hub has a legitimate interest in processing personal data and for keeping records during the provision of its homestay services.

Where Urban Hub processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

Where host families wish to host students aged under 18, Urban Hub is obliged to seek information about criminal convictions and offences. Where Urban Hub seeks this information, it does so because it is necessary for it to carry out (i) its legal obligations (ii) its obligations to the British Council as well as (iii) providing an adequate matching service to students of this age group to educational clients (language schools, international “study agents” and students).

Urban Hub will use your data for the provision of its homestay services. We, and/or our authorised agents may from time to time inform you by telephone, letter, email or post of newer services, special offers, discounts, competitions and promotions.

This website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
  • Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
  • Your right to erasure– You have the right to ask us to delete your personal information.
  • Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information.
  • Your right to object to processing– You have the right to object to the processing of your personal data.
  • Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
  • Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Changes of business ownership and control

Urban Hub may, from time to time, expand or reduce its business and this may involve the sale or the transfer of control of all or part of Urban Hub.

Your data as provided by you will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to us.

We may also disclose data to a prospective purchaser of our business.  In these circumstances, we will take steps to ensure that your privacy is protected.

Our lawful bases for the collection and use of your data

Urban Hub takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees or relevant third parties (as above) in the proper performance of their duties.

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    • We need to process personal data to effectively match students or other homestay guests with suitable host families and to maintain service quality and safety standards. This includes managing applications, making and receiving payments, ensuring suitable accommodations, and complying with legal requirements, such as conducting necessary background checks when hosting minors​

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to comply with legal requirements:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to protect client welfare are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

  • Directly from you
  • Legal bodies or professionals (such as courts or solicitors)
  • Third parties:
    • Eden Asset Management
    • Unity Living
    • Stripe Payment Platform

Urban Hub may also collect personal data about you from third parties. For example, where a host family has expressed an interest in hosting students aged under 18, we may seek (i) personal or past employment references and/or (ii) information on past convictions, cautions, reprimands etc from criminal records checks (e.g. DBS).  Similarly, where a student or homestay guest has contacted us directly, we may request confirmation of enrolment/employment from their place of study/work here in the UK.

Urban Hub will seek information from third parties only once you have consented to Urban Hub doing so and will inform you that it is doing so.

How long we keep information

  • We retain your personal information only as long as necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. Specifically, we will retain your personal data for a period of one year from the date of its collection. After this period, all personal information will be securely deleted from our systems, unless we are legally required or have legitimate grounds to retain it for longer, such as for ongoing legal proceedings or for compliance with a legal obligation under EU or Member State law.

    Data will be stored in a range of different places, including on your application records, in our internal CRM systems and on other IT systems (including email).

Who we share information with

  • Your information may be shared internally and with certain third parties for the purposes of providing our homestay service. This includes, but is not limited to, our (i) Management Team (ii) Accommodation Officers, (iii) Administration Team, (iv) Home Inspectors, (v) Educational Clients (Language Schools, Universities, International “Study Agents”) (vi) Students or other homestay guests  (vii) British Council inspectors carrying out an inspection of Urban Hub, (viii) IT staff if access to the data is necessary for the performance of their roles, (ix) taxi transfer companies (where the student requests a transfer)

    Whereas Urban Hub will share your data with educational clients (Language Schools, Universities, International “Study Agents”), we will not make your data publicly available online, or use it for marketing purposes, without your prior consent to do so.

    However, Urban Hub will create an online profile for each homestay host which is searchable via a closed online search system, accessible to Urban Hub and authorised agents (Language Schools, Universities, International “Study Agents”, and students or other homestay guests wishing to book a homestay). Urban Hub will give access to our online search system only to these authorised agents, and it will not be made publicly available online without the host’s advance permission.

    This profile will include information including basic details about the property and residents of the homestay, photos of the home taken by our Home Inspectors at the home inspection or voluntarily provided by the homestay host. This profile is anonymised and does not include information such as your exact location or address, name, or contact details.

    Information such as the host’s name, address and contact details, are only supplied to the Educational Client, Study Agency, Student or Homestay Guest when a booking is confirmed. The host will also be sent a copy of the booking confirmation at this stage, so they will see which data is being shared.

    As our (i) students/homestay guests and (ii) overseas “study agent” clients are based internationally, your data may be transferred outside the European Economic Area (EEA) in the normal provision of our homestay services.

    Urban Hub routinely shares your information with the British Council inspectors carrying out inspections of Urban Hub. When required to do so to meet legal obligations, we share your information with the Disclosure and Barring Service (DBS) in order to complete criminal records checks. We will only share this information once you have consented to Urban Hub doing so and will inform you that we are doing so. Urban Hub does not routinely share your information with any other statutory or regulatory bodies such as the police, local councils, social services unless expressly required to do so to meet legal obligations.

    Other Data processors: Eden Asset Management

    This data processor processes personal data on our behalf.

    Others we share personal information with:
    • Other financial or fraud investigation authorities

Payment Processing

  • We use Stripe as our payment gateway to process payments on our website. When you make a payment, your financial information is processed directly by Stripe, which specializes in the secure online capture and processing of credit/debit card transactions. As such, we do not store or have access to your credit card details; they are handled by Stripe according to their stringent security standards.

    To better understand how your financial information is handled, we recommend reviewing Stripe’s privacy policy and terms of service. These documents provide detailed information on how your personal and financial data is processed and protected. You can access these documents via the following link: Stripe Consumer Terms of Service

What if you do not provide personal data?

  • You are under no statutory or contractual obligation to provide data to Urban Hub during the registration or application stages or at any time thereafter. However, if you do not provide the information, Urban Hub may not be able to process your homestay application properly at all, nor provide our homestay service to you.

Changes to this Privacy Policy

  • Any changes to this privacy policy will be posted on the website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal data in a manner significantly different from that stated in this privacy policy, or as otherwise disclosed to you at the time it was collected, we will notify you by email and, where required by applicable law, we will obtain consent to changes before those changes come into effect.

    How to complain

    If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

    20 January 2025