Chapter B Privacy Policy

1. Introduction

At Chapter B, we understand that relocating to a new country requires trust. Protecting your personal information is an important part of earning and maintaining that trust.

This Privacy Policy explains how Chapter B collects, uses, stores, shares and protects your personal information when you:

• visit our website;
• contact us;
• book a consultation;
• purchase or use our services;
• join our community; or
• otherwise interact with Chapter B.

We are committed to handling your personal information responsibly, transparently and in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Please read this Privacy Policy carefully before using our services.

2. Who We Are

Chapter B is the trading name of Foxhorn Ltd, a company registered in England and Wales.

Foxhorn Group Ltd operates the Chapter B website and provides the relocation concierge services described in this Privacy Policy.

For the purposes of applicable data protection legislation, Foxhorn Ltd, trading as Chapter B, is the Data Controller responsible for the personal information collected and processed through the Chapter B website and our services.

Contact Details

• Legal Business Name: Foxhorn Ltd
• Trading Name: Chapter B
• Company Number: 16499079
• Registered Office: 40 Young Street, Cambridge, CB1 2LZ, United Kingdom
• Email: hello@mychapterb.com
• Website: www.mychapterb.com

If you have any questions about this Privacy Policy or how we process your personal information, please contact us using the details above.

3. The Information We Collect

The personal information we collect depends on the services you request and how you interact with us.

Identity Information

This may include:

• full name;
• date of birth (where required);
• nationality;
• passport details (only where voluntarily provided or reasonably required for the services requested); and
• other identification documents voluntarily provided by you.

Contact Information

This may include:

• email address;
• telephone number;
• WhatsApp number;
• postal address; and
• emergency contact details (where voluntarily provided).

Relocation Information

This may include:

• intended arrival date;
• current country of residence;
• university or employer details;
• course information (where relevant);
• preferred location;
• accommodation preferences;
• property requirements;
• budget;
• move-in dates;
• guarantor information (where relevant); and
• any other information you choose to provide to help us deliver our services.

Financial Information

Depending on the services requested, this may include:

• accommodation budget;
• proof of funds;
• guarantor details;
• bank account information voluntarily provided by you for relocation purposes; and
• payment information processed through our payment providers.

Chapter B does not store your full payment card details.

Communications

We may retain records of communications between you and Chapter B, including:

• emails;
• WhatsApp messages;
• telephone call notes;
• consultation notes;
• feedback;
• enquiries; and
• customer support correspondence.

Documents You Provide

You may choose to provide documents including:

• passport copies;
• visa documentation;
• tenancy documents;
• proof of student status;
• proof of employment;
• guarantor documentation;
• Right to Rent documentation;
• identification documents; or
• other documents relevant to your relocation.

We only request documents that are reasonably necessary for the services we are providing.

Sensitive Personal Information

In limited circumstances, you may choose to provide sensitive personal information, such as information concerning a disability, health condition, religious requirement or other personal circumstance relevant to your accommodation or relocation needs.

We will only request or process this type of information where it is reasonably necessary, where an appropriate lawful basis and additional conditions under data protection law apply, and where suitable safeguards are in place.

Where appropriate, we may ask for your explicit consent before processing this information. You may withdraw that consent at any time, although doing so may affect our ability to provide services that depend upon that information.

Technical Information

When you visit our website, we may automatically collect information including:

• IP address;
• browser type;
• device information;
• operating system;
• pages visited;
• referring website;
• time spent on our website; and
• similar technical information collected through cookies and analytics technologies.

Information We Need to Provide Our Services

Certain personal information may be required in order for us to respond to your enquiry, enter into a contract with you or provide your chosen services.

Where requested information is necessary for these purposes and you do not provide it, we may be unable to accept your booking, provide part or all of the services requested, communicate with relevant landlords, letting agents, accommodation providers and other third parties involved in your relocation or complete particular relocation-related tasks.

We will tell you where providing information is optional.

4. How We Collect Your Information

We collect personal information in several ways.

Information You Provide Directly

This includes information you provide when you:

• complete an enquiry form;
• book a consultation;
• purchase one of our service packages;
• contact us by email, telephone or WhatsApp;
• join our community;
• complete surveys or provide feedback; or
• send us documents relating to your relocation.

Information Collected Automatically

When you use our website, certain technical information may be collected automatically through cookies, analytics tools and similar technologies.

Further information is available in our Cookie Policy.

Information Received from Third Parties

In limited circumstances, we may receive information from Third Parties where this is necessary to provide our services.

This may include information received from:

• property providers;
• letting agents;
• universities;
• utility providers;
• payment providers;
• identity verification providers (where applicable); or
• other organisations where you have authorised them to share information with us.

We will only obtain such information where there is an appropriate legal basis for doing so.

5. How We Use Your Personal Information

We only use your personal information where we have a lawful reason to do so. The way we use your information depends on the services you request, how you interact with us and the choices you make.

We may use your personal information to:

• provide the relocation, accommodation search and concierge services you have requested;
• communicate with you before, during and after the delivery of our services;
• arrange consultations, property viewings and other appointments;
• identify suitable accommodation based on your preferences and requirements;
• communicate with landlords, letting agents, accommodation providers and other third parties on your behalf where you have requested or authorised us to do so;
• provide move-in planning, settling-in support and community services;
• process payments and maintain financial records;
• verify your identity where reasonably necessary;
• respond to enquiries, feedback and complaints;
• improve our services, website and client experience;
• comply with our legal and regulatory obligations;
• protect our legal rights and resolve disputes where necessary;
• prevent fraud, misuse of our services or other unlawful activity; and
• send marketing communications where you have chosen to receive them or where we are otherwise permitted to do so by law.

We will only use your personal information for the purposes for which it was collected, unless we reasonably consider that another compatible purpose is appropriate and lawful.

6. Our Lawful Bases for Processing

Under the UK General Data Protection Regulation (UK GDPR), we must have a lawful basis for processing your personal information.

Depending on the circumstances, we rely on one or more of the following lawful bases.

Performance of a Contract

We process personal information where it is necessary to provide the services you have requested or to take steps before entering into a contract with you.

This includes activities such as:

• arranging consultations;
• providing accommodation search services;
• communicating with landlords, letting agents, accommodation providers and other third parties involved in your relocation;
• coordinating relocation services;
• processing payments; and
• providing post-arrival support.

Legitimate Interests

We may process personal information where it is reasonably necessary for our legitimate business interests, provided that those interests are not overridden by your rights and freedoms.

Examples include:

• improving our services;
• maintaining client records;
• responding to enquiries;
• ensuring the security of our website and systems;
• preventing fraud and misuse;
• managing our business operations;
• handling complaints;
• establishing, exercising or defending legal claims;
• resolving disputes; and
• protecting and enforcing our legal and contractual rights.

Whenever we rely on legitimate interests, we carefully consider and balance your privacy rights against our legitimate business needs.

Consent

In certain circumstances, we rely on your consent to process personal information.

This may include:

• sending marketing communications where consent is required;
• using certain non-essential cookies;
• collecting optional information that is not necessary to provide our services; or
• processing information where we have specifically requested your permission.

Where we rely on your consent, you may withdraw it at any time. Withdrawing your consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.

Legal Obligation

We may process personal information where necessary to comply with legal or regulatory obligations.

This may include complying with:

• court orders;
• requests from law enforcement or regulatory authorities;
• tax and accounting requirements;
• anti-fraud obligations; or
• other legal obligations applicable to Chapter B.

7. Who We Share Your Information With

We treat your personal information with care and confidentiality.

We will never sell your personal information to third parties.

We will only share your personal information where it is necessary to provide our services, where you have authorised us to do so, or where we are legally required or permitted to do so.

Depending on the services you request, we may share information with:

• landlords, letting agents and other property providers;
• universities and student accommodation providers;
• utility and broadband providers;
• banks or financial institutions, where requested by you;
• transport providers, where requested by you;
• WhatsApp (Meta), which we use to communicate with clients, provide customer support and deliver certain aspects of our relocation services. Information you choose to send through WhatsApp is also processed in accordance with WhatsApp's own privacy practices;
• Stripe, which processes payments and related transaction information in connection with our services;
• Google Workspace, which we use for business email, document management, secure cloud storage and internal business operations;
• website hosting providers and other technology service providers that support the operation and security of our website and services;
• professional advisers, including accountants, insurers and legal advisers;
• government authorities, regulators or law enforcement agencies where required by law; and
• any other Third Party where you have instructed or authorised us to share your information.

We only share the minimum amount of personal information reasonably necessary for the relevant purpose.

All organisations processing personal information on our behalf are expected to handle it securely and in accordance with applicable data protection legislation.

8. International Transfers

Chapter B is based in the United Kingdom.

Where possible, your personal information will be processed and stored within the United Kingdom or countries that benefit from an adequacy decision recognised by the UK Government.

In some circumstances, your personal information may be transferred outside the United Kingdom where this is necessary to provide our services or where one of our trusted service providers processes information internationally.

Some of our trusted service providers, including Google Workspace and Stripe and WhatsApp (Meta) may process or store personal information using infrastructure located in multiple countries. Where this results in a restricted international transfer, we will use appropriate safeguards recognised under applicable data protection legislation, such as approved contractual clauses or another lawful transfer mechanism.

9. Data Security

We take the security of your personal information seriously.

We maintain appropriate technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures may include:

• secure cloud-based storage, including Google Workspace;
• password-protected systems;
• multi-factor authentication where appropriate;
• encryption in transit and at rest where supported;
• restricted access to personal information on a need-to-know basis;
• secure payment processing through Stripe;
• staff awareness of confidentiality obligations; and
• regular review of our security practices.

Although we take reasonable steps to protect your information, no method of transmitting information over the internet or storing electronic data can be guaranteed to be completely secure. For this reason, we cannot guarantee absolute security.

10. How Long We Keep Your Information

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which it was collected.

The length of time we retain information depends on factors including:

• the services provided;
• our legal and regulatory obligations;
• accounting and tax requirements;
• the need to resolve complaints or disputes;
• the protection of our legal rights; and
• applicable limitation periods under the laws of England and Wales.

Unless a longer or shorter retention period is required or permitted by law:

• general client records, including booking information, correspondence, consultation notes and service records, may be retained for up to seven (7) years following the completion or termination of our services;
• financial and accounting records may be retained for up to seven (7) years where required to comply with applicable legal, tax and accounting obligations;
• identity documents, such as passport copies, visa documents, Right to Rent documentation and other identification documents provided solely for the purpose of delivering our services, will normally be securely deleted once they are no longer reasonably necessary for that purpose, unless we are required or permitted by law, or have another lawful basis, to retain them for a longer period.

At the end of the applicable retention period, personal information will be securely deleted, destroyed or anonymised where appropriate.

11. Your Rights

Under the UK General Data Protection Regulation (UK GDPR), you have a number of rights in relation to your personal information.

These rights may include the right to:

• request access to the personal information we hold about you;
• request that inaccurate or incomplete information be corrected;
• request that your personal information be erased in certain circumstances;
• request that we restrict the processing of your personal information;
• object to processing based on our legitimate interests in certain circumstances;
• object at any time to the use of your personal information for direct marketing;
• request a copy of your personal information in a portable format where applicable;
• withdraw your consent where processing is based on consent; and
• lodge a complaint with the Information Commissioner's Office (ICO).

These rights are not absolute and may be subject to legal or regulatory exceptions.

If you wish to exercise any of your rights, please contact us using the details provided in this Privacy Policy.

We will respond to your request without undue delay and, in any event, within one calendar month, as required by applicable data protection legislation. If your request is particularly complex or if we receive multiple requests from you, this period may be extended by up to a further two months.

The response period begins from the date we receive your request, provided we have sufficient information to verify your identity.

12. Marketing Communications

We may occasionally send you information about our services, community events, newsletters, relocation guidance or other updates that we believe may be relevant to you.

Where required by law, we will only send marketing communications where you have given your consent or where we are otherwise permitted to do so under applicable electronic marketing legislation.

You have an absolute right to object at any time to the use of your personal information for direct marketing. Once you object, we will stop using your information for that purpose, although we may retain limited details on a suppression list to ensure that your preference is respected.

You may unsubscribe from marketing communications at any time by:

• clicking the "unsubscribe" link included in our emails;
• contacting us directly using the details provided in this Privacy Policy; or
• requesting removal through any other communication channel we make available.

Choosing not to receive marketing communications will not affect essential service-related communications regarding your enquiries, bookings or the services we provide.

13. Cookies

Our website uses cookies and similar technologies to improve your browsing experience, understand how our website is used and support the operation of our online services.

Cookies may be used to:

• ensure our website functions correctly;
• remember your preferences;
• improve website performance;
• analyse website traffic and visitor behaviour; and
• enhance the overall user experience.

Where required by law, we will obtain your consent before placing non-essential cookies on your device.

Further information about the cookies we use, the purposes for which they are used and how you can manage your cookie preferences can be found in our Cookie Policy.

14. Children's Privacy

Our services are primarily intended for adults and individuals aged 18 years and over who are relocating to the United Kingdom.

We do not knowingly collect personal information from children under the age of 18 without the involvement or consent of a parent or legal guardian where required by law.

If you believe that a child has provided us with personal information without appropriate consent, please contact us. We will take reasonable steps to investigate the matter and, where appropriate, delete the information.

15. Third-Party Websites

Our website, emails or other communications may contain links to third-party websites or services.

Chapter B is not responsible for the content, security or privacy practices of third-party websites.

We encourage you to read the privacy policies of any third-party websites you visit before providing them with your personal information.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations or the way we process personal information.

The latest version will always be published on our website together with its effective date.

Where appropriate, we may also notify you of significant changes by email or through other appropriate communication channels.

We encourage you to review this Privacy Policy periodically to remain informed about how we protect your personal information.

17. Contact Us

If you have any questions about this Privacy Policy, your personal information or how Chapter B processes your data, please contact us.

• Legal Business Name: Foxhorn Ltd
• Trading Name: Chapter B
• Email: hello@mychapterb.com
• Website: www.mychapterb.com
• Postal Address: 40 Young Street, Cambridge, CB1 2LZ, United Kingdom

We will be happy to assist you and will respond to privacy-related enquiries as promptly as reasonably practicable.

18. Your Right to Complain

If you are dissatisfied with the way we have handled your personal information, we encourage you to contact us first so that we have the opportunity to understand your concerns and, where possible, resolve them.

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection matters.

You can contact the ICO using the details below:

• Information Commissioner's Office (ICO)
• Website: https://www.ico.org.uk
• Telephone: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Lodging a complaint with the ICO does not affect any other legal rights or remedies that may be available to you.

Chapter B is committed to protecting your privacy and handling your personal information responsibly. If you have any questions about this Privacy Policy or how we process your information, we encourage you to contact us using the details above.