Privacy Policy

WHO WE ARE

This Privacy Policy covers Yullux LTD and any of Our subsidiary companies under Section 1159 Companies Act 2006 (referred to as “We” or “Us” or “Our” or “Homehop”). These include:

Yullux Group LTD, registered in The Republic of Cyprus number HE 425228. Registered office address is 15 Georgiou Drosini, Potamos Germasogeia, Limassol, Cyprus.

We are the providers of the Homehop mobile application software (referred to as the “App”) and the websites www.homehop.io (referred to as the “Site”) (together referred to as “Our Platforms”) and any other Services We may operate in the future.

“Members” include estate agents, commercial agents, letting agents, managing agents, landlords, new homes developers, housing associations, overseas property owners, surveyors, banks, building societies, insurance companies, other lenders and financial institutions, Government departments, executive agencies, quangos and selected CRM software providers. We are not an estate agency.

“Partners” are selected companies whom We choose to work with to offer complimentary Services such as currency exchange, utilities and broadband.

“Services” or “Service” include property advertising, insurance and tenant related services (which includes tenant referencing, rent guarantee insurance, landlords’ contents and/or liability insurance, tenant’s contents and/or liability insurances, utilities and broadband), stamp duty land tax calculator, valuation and surveying tools and financial services (which includes mortgage in principle decision and mortgage calculator).

We provide Our Platforms so that:

Our Members can advertise property details for You to view;
We, or Our Members, can provide insurance, tenant and financial services to You;
We can provide You with access to housing market trends and historical property data; and
We can provide Our Members access to valuation and surveying tools.

References to “Users”, “You”, “Yourself” or “Your” is a reference to individuals using Our Platforms or Services.

References to “Personal Information” means information that will allow Us to identify You.

INTRODUCTION

We are committed to protecting Your privacy. This privacy policy (referred to as the “Policy”) explains how and for what purposes We use the Personal Information collected about You when You use the Site or download and use Our App on Your mobile device (“Device”). Please read this Policy carefully.

In the tables below We set out the types of Personal Information We collect, where it comes from, why We collect it, Our lawful basis for processing the Personal Information and how long We will keep it for.

Our Platforms are not intended for anyone under the age of 18 (referred to herein as “Children” or “Child”).

If You have a query about Personal Information relating to Your property on the Platforms, please contact Your estate agent or lettings agent directly or alternatively contact Us on support@homehop.io.

CONTACTING US

We recommend You contact Us via email. If you prefer to corresponded with Us via post, there may be a delay in Us receiving and responding to Your postal enquiries and therefore email correspondence is recommended for a quicker response.

If You would like to stop receiving direct marketing from Us please contact Us via email at support@homehop.io or please write to the Customer Services Team, 15 Georgiou Drosini, Potamos Germasogeia, Limassol, 4043, Cyprus and where possible include a copy of the communications You have received.

If You have any questions about this Policy or Our use of Your Personal Information or would like to submit a subject access request or exercise Your other data subject rights, please contact Our Data Protection Officer/Team via email at support@homehop.io or please write to The Data Protection Officer, 15 Georgiou Drosini, Potamos Germasogeia, Limassol, 4043, Cyprus.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

PROPERTIES ADVERTISED ON OUR PLATFORMS

What We collect and where it comes from

In the course of providing Our Services, We collect property data such as images of properties, including videos and virtual tours, property asking prices, sales history and sold prices, property addresses, floorplans, property locations and property descriptions; and
The property data is provided to Us by Our Members or other third parties on behalf of those Members.

Why We collect it

We will use this information for a number of reasons including:
- To provide Our Platforms;
- To enable Our Members to advertise their properties to the largest online audience available;
- To enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in;
- To allow Users to see current property trends such as the prices of houses for sale in their local area;
- To allow Users to check broadband speeds and deals for properties;
- For Our own commercial purposes such as to identify trends in the property market, to build property databases and automated survey and valuation tools for Our Members to use and to promote Our Platforms and Services on social media and other third-party platforms; and
- To provide Our Members with updates on properties advertised on Our Platforms.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:
- Providing a Service to Our Members by helping them to market properties and understand changing market dynamics and evolving trends;
- Providing a Service to Our Members by advertising properties to potential purchasers or tenants;
- Providing a Service to potential purchasers and tenants so that they know:
- what properties are currently on the market, the price of those properties, and to provide access to potential broadband speeds and deals of those properties through our Partners;
- To provide data services to third parties such as surveyors, banks, building societies, insurance companies and other financial institutions so that they can process this property data for their purposes (this includes providing property valuation tools and surveyor comparison software to Our Members); and
- To help Our Members benchmark their performance and identify requirements for additional services.

How long We will keep it for

We will stop advertising a property when We are instructed to do so by Our Members. However, the property information will remain available on the Platforms as historical property information to allow Users and Our Members to benefit from Services such as identifying previous for sale or sold prices.

HISTORICAL PROPERTY DATA

What We collect and where it comes from

If a property has previously been actively marketed on the Platforms, We will continue to display it on the Platforms as historical property information.

Why We collect it

We will use this information:
- To assist potential purchasers and tenants when forming a view about historical market trends and potential property values;
- To assist vendors when researching the approximate value of their property;
- To enable Users to see detailed property descriptions and images of properties in areas that they may be interested in;
- To allow Users to see property trends that they may be interested in, such as the previous sale and sold prices of properties in their local area; and
- For Our other commercial purposes, such as to identify trends in the property market and to build property databases and automated survey and valuation tools for Our Members to use.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:
- To enhance the Service that We provide on Our Platforms and providing a Service that benefits Our Members, Users, vendors, landlords, potential purchasers and tenants;
- To provide a Service to Our Members by assisting them to more accurately value other properties;
- To provide a Service to vendors and landlords which helps them form a view about the value of their properties;
- Providing a Service to potential purchasers and tenants in understanding what properties have been on the market and the prices of those properties;
- To provide data services to third parties such as surveyors, banks, building societies, insurance companies and other financial institutions so that they can process this historic property data for their purposes; and
- To provide property valuation tools and surveyor comparison software to Our Members.

How long We will keep it for

To the extent that property data is also Personal Information, it is generally the case that it ceases to be Personal Information over time. The historic property data is retained by Us whilst it is required by Us to provide the Services summarised in the “Why We collect it” box.

PERSONAL INFORMATION YOU GIVE TO US

What We collect and where it comes from

We will collect the Personal Information that You give to Us when using Our Platforms or Services:
- If You choose to access a particular search feature, request information or fill in a form on the Platforms You may be asked to provide Personal Information about Yourself, such as:
  - Your name, address and contact details;
  - details of the sort of property You are interested in;
  - the cost and location of the property;
  - Your current residential address;
  - what stage in the home moving process You are;
  - whether You are a first time buyer, a seller, a landlord, a tenant, investor etc.;
  - whether You are re-mortgaging
  - whether You have a property to sell or let.
  - when enquiring about properties overseas, We will also ask for:
    - reason for buying
    - Your country of residence
    - whether You require assistance and advice from Our Currency Exchange partner, Smart Currency;
  - when enquiring about rental properties, the following information may be requested in addition to the above about whether:
    - there will be smokers living in the property
    - You have any pets
    - You consent to the agent performing a credit check and date of birth
    - Your household income exceeds a set amount
    - You are aware of any adverse credit
    - Your employment status
    - Your move (move in dates, desired tenancy length, whether renting for first time in the UK, who You are moving in with)
- If You choose to book an appointment to view a property via the Platforms, You may be asked to provide more details, including:
  - Your availability to view the property;
  - Your preferred moving date;
  - details of Your household income as a proxy for calculating affordability in relation to the advertised monthly rental value of a property;
  - whether You have any adverse credit history that could affect Your application;
  - an indication of whether You are moving alone or with others;
  - Your feedback on a property that You have viewed;
  - Your mobile number for the purpose of providing You updates via text regarding Your property viewing (includes sending reminders about Your booked viewings); and
- If You choose to contact a Member using the telephone number on Our Platforms, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.
- Personal Information that You provide to Us when You:
  - register as a My Homehop User;
  - request property email updates such as Property Alerts about when a property is marketed in Your chosen postcode and meeting Your search parameters;
  - send enquiries to our Members. Copies will be available to view in Your My Homehop account;
  - book property viewings and appointments via Our Site;
  - where We have made the following features available to You, these will be available to view in Your My Homehop account:
    - track a property;
    - access to property viewings and appointments booked via Our Site
    - whether You own the property, are a tenant of the property, or are looking to the buy the property; and
    - adding saved properties and notes.
- We may also ask what stage in the home moving process You are, whether You are a first time buyer, a seller, tenant, a landlord, investor, whether You are re-mortgaging etc.
- Personal Information that You provide when:
  - downloading the App or registering to use the App;
  - participating in discussion boards or other social media functions on Our Platforms;
  - entering into competitions, promotions, surveys and market research studies made available on Our Platforms or if We contact You by email; phone or otherwise; and
  - engaging with additional Services that are available on Our Platforms, such as the stamp duty calculator and mortgage calculator, where you will Provide Us the following Personal Information: location, home moving status (whether you are a first time buyer, buying your next home or buying an additional property/investing), re-mortgaging, are an investor and price of the property.
- Personal Information that You provide by corresponding with Us by phone, e-mail, video calls or otherwise; and
- If You choose to contact Us by phone or video calls or We call You, calls may be recorded for training, monitoring and quality assurance purposes. Phone calls may be monitored in real time. We may also keep a record of call activity, including missed calls.
- Personal Information that You provide to Us when browsing Our investor pages.
- If You choose to generate a quote or apply for any of Our insurance and tenant related Services, You may be asked to provide Personal Information about Yourself, such as:
  - Your full name including title, email address, phone number;
  - Property address You are looking to move to;
  - Date of birth;
  - Employment status and history;
  - Health data;
  - Race or ethnicity;
  - Disclosure of unspent criminal convictions;
  - Payment card details;
- Where Our Members use Our Services to create a tenancy agreement for You to sign and take payment:
  - Our Member will provide the following Personal Information to Us:
    - Your full name including title, current address, email, phone number;
    - Property address You are looking to move to;
    - Any property related documents;
    - Your new landlords contact details;
  - You will provide the following additional Personal Information to Us via Our e-signatory third party provider:
    - Your signed tenancy agreement
  - Our e-signatory third-party provider will provide an audit trail of the tenancy agreement signature process (includes dates, times, email address and IP address of You and Our Member); and
  - You will be transferred to a third-party payment gateway to make payment via open banking Financial Services.

Why We collect it

We will use this Personal Information:
- To make sure that You receive the benefit of the Service. This may include:
  - transferring Your property enquiry to Our Member who is advertising that property so that they can respond to Your enquiry only. Some of Our Members may use:
    - lead handling agencies who handle and process Your enquiry on their behalf; or
    - third party systems to process and store Your enquiry to allow them to respond to and manage Your enquiry;
  - sending Your request to book a property viewing to Our Member who is advertising that property and for Us to confirm Your booking by email or text on Our Member’s behalf;
  - sending Your name, address and contact details to Our Member when You request information or a brochure on a property they are advertising, so that they can contact You;
  - where You book an appointment to view a property, We will create a calendar appointment in Our Members own email system (via calendar software) in order to manage Your booking;
  - transferring other relevant information to Our Member so that they can assess whether the property is suitable for You;
  - enabling Us to send You a link to access an online viewing of the property You have enquired about;
  - allowing You to provide Our Member with feedback on the property once You have viewed it;
  - Our Members must form their own legal basis for processing Your enquiry data if they are processing it for purposes other than responding to Your initial enquiry;
  - When enquiring about properties overseas, We will also share:
    - whether You have agreed to receive advice from Our Currency Exchange Partner, Smart Currency, with Our Member who is advertising the property You are enquiring about for the purpose of assessing Your current situation;
    - A copy of the property enquiry and a link to the property you have enquired about with our Partner, Smart Currency ,where you have agreed to being contacted by Our Partner for the purposes of being able to respond to Your currency enquiry;
  - When enquiring about rental properties, additional information will be requested to enable the agent to better understand Your circumstances and suitability for the property.
- For training and monitoring purposes where calls are recorded; and
- To profile Your activity on Our Platforms.
- To enhance the service you receive from Our Members.
- To provide You with the benefit of Services for registered Users only;
- To provide Property Alerts to You (which You have set up) for properties marketed on Our Platforms that meet Your search criteria;
- To provide You access to Your enquires and bookings of viewings You have sent to Our Members;
- To keep you updated on Your account and Services available to You; and
- To provide You customised content on Our Platforms including suggesting properties or Services relevant to You.
- To provide the Platforms to You and enable You to download the App;
- To enhance the Services that You select on Our Platforms;
- To process any queries that You have about Homehop or its Members;
- To customise and enrich Your experience on Our Platforms;
- To contact You for Your views on Our Services and to notify You occasionally about important changes to Our Terms of Use, this Policy or developments to Our Platforms or Services;
- To deliver relevant advertising to You whilst You are on the Platforms;
- To deliver targeted advertising to You depending on whether You are a first-time buyer, re-mortgaging or are an investor; and
- To provide You customised content on Our Platforms including suggesting properties or Services relevant to You.
- To process and resolve any queries that You may have; and
- For training, monitoring and quality assurance purposes where calls (which may include video calls) are recorded.
- To allow You to subscribe for relevant Homehop regulatory alerts; and
- To process and respond to any queries that You might have.
- To provide You a quote for insurance or tenant related services;
- To process Your application for insurance or tenants related services;
- To process Your tenancy agreement on behalf of Our Member agent and facilitate payment between You and Our Member;
- To perform a contract; and
- Where You have consented, to send You direct marketing regarding insurance and tenant related services.
- To enable You to gather information which provides transparency around the mortgage process;
- To help You to understand what You can afford, using Our mortgage calculator;
- To contact You regarding Your mortgage in principle decision; and
- To allow You to receive a digital mortgage in principle decision from a lender.
- To enable You to apply for Our job vacancies at Homehop.
- To respond to Your requests;
- To add You to Our database of journalists to receive industry and company related press releases; and
- To contact You by phone, email, video call or otherwise regarding stories that We believe may be of interest to You.

Our lawful basis for processing this Personal Information

We have a legitimate business interest to process this Personal Information. These legitimate interests are:
- Enquiries to Our Members: To provide a service to Our Members and/or to provide a service to You;
- Registered User and Property Alerts: To provide You with Our Services;
- General Use of the Platforms:
  - To enable You to download and use the App;
  - To allow Us to gain information about the use of Our Platforms and any improvements that can be made;
  - To provide providing advertising space to Our Members and third parties;
  - To provide You with relevant content on Our Platforms;
- Communications: To ensure that Your queries are addressed and for training, monitoring and quality assurance purposes where calls (which may include video calls) are recorded;
- Investor Relations: To allow You to access Homehop regulatory alerts and to ensure that Your queries are addressed;
- Insurance and tenant related services:
  - To provide You with a quote and to provide access to insurance and tenant related services that may be relevant to You;
- To process Your tenancy agreement on behalf of Our Member agent and facilitate payment between You and Our Member;
- Human Resources: To process Your job application and consider You for Our vacancies;
- Journalists: To enable direct communication between Us and relevant journalists;
We have a contractual reason to process this Personal Information:
- Insurance and tenant related services: To process Your application and provide You the Services;
- Financial services: To process Your mortgage in principle and provide You the Services;
We rely on consent for:
- Allowing Our Member to run a credit check in respect of a rental property You are enquiring about; and
- Sharing Your information with Homehop. Homehop Landlord and Tenant Services and Equifax to undertake the credit check in respect of a rental property You are enquiring about.
- Insurance and tenant related services:
- to send You direct marketing regarding insurance and tenant related services;
- process Your special category and criminal offence data in order to process Your application; and
- Financial Services: to process Your special category data in order to process Your application for a mortgage in principle.

How long We will keep it for

We will store the Personal Information summarised above for the following periods:

All enquiry data will be kept for two years from the date on which You last used Our Platforms or Our Services. After that it will be erased or anonymised so that the data no longer identifies You;
Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted; and
Profiling data will be kept for as long as is required.
Personal Information that You provide to Us when You register as a User will be kept for as long as You have an active account setup on Homehop. The Personal Information relating to Your account will be deleted when You delete Your account or if Your account has been inactive for 5 years (from May 2018), whichever is earlier.
Enquiries you have made to Our Members will be accessible in Your My Homehop account for up to 3 months.
Personal Information that You provide when downloading the App, registering to use the App or for accessing in-App services will be retained for as long as You have the App installed on Your device;
Personal Information that You provide when participating in discussion boards, enter into competitions, promotions, surveys and market research studies will be retained for no longer than two years; and
Personal Information that is provided when You interact with Us through publicly available social media platforms will only be retained on the social media platforms which You use to publicly interact with Us (we will not copy or store it separately) and this Personal Information will be retained for as long as You keep it on Your social media accounts (for tweets and direct messaging via social media platforms, please see “Communications” heading below).
Personal Information that You provide to Us when We correspond by telephone, e-mail, direct messaging or tweets through social media will be retained on Our systems:
- For no longer than 25 months on Our ticketing system from the date of communication or until Your query is resolved.
- For no longer than 24 months for the original e-mail correspondence;
- For no longer than 18 months for recorded calls; and
- For 3 years where any correspondence relates to either Our insurance and tenant related services or financial services.
Personal Information that You provide to Us when browsing Our investor pages will be kept for as long as You maintain an investor User account on Our investor pages. Any Personal Information which We hold in Your investor User account will be deleted when You delete Your investor User account.
Personal Information You Provide Us will be kept for 3 years or for as long as required to perform a contract;
Where Our Member agent uses Our Services to create a tenancy agreement for You to sign, We will retain Your Personal Information for the following periods:
- 6 years after tenancy has ended where the application has been successfully completed; or
- Up to 12 months where a tenancy application has not been signed/and or finalised.
Where Our Member uses Our Services to perform a credit check in respect to a rental property You are enquiring about, the credit check will be retained for 3 years.
We will retain Your Personal Information for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information and whether We can achieve those purposes through other means, and the applicable legal requirements.
We retain Personal Information for as long as is required to fulfil the purpose (whether that be for the current job application or retaining on file for future job vacancies) or until You notify Us that You wish for Your Personal Information to be deleted.
We retain Your Personal Information until You notify Us that You wish for Your Personal Information to be deleted or until Our records indicate You no longer undertake journalistic activities that relate to Our products or Services.

PERSONAL INFORMATION WE RECEIVE FROM THIRD PARTIES

What We collect and where it comes from

We may receive Personal Information about You if You use any of the other websites We operate or the other Services We provide via the App. In this case We will have informed You, when We collected the Personal Information, that it may be shared internally and combined with other Personal Information collected on Our Platforms.

Our Members
Our Members may provide us Your Personal Information such as name, email address, property address, whether You purchased or rented a property or instructed Our Member to sell or rent Your property.

Where you have consented to a credit check being performed in respect to renting a property from one of Our Members, the credit reference agency will share the results of the credit check with Us.
When You apply for a job vacancy via a recruitment agency, they will provide Us Personal Information about You; or
Where Your job application is successful and prior to an offer of employment, We will request a reference from Your referees. They will provide Us Personal Information about You.
Where You are a Journalist, We may receive Your Personal Information (email address, name, number, company You work for and whether You are a freelancer) from third party press services.

Why We collect it

We will use Your Personal Information:
- To allow You to participate in the interactive Services available on Our Platforms or to participate in competitions or promotions via Our Platforms;
- To pass Your searches and messages on to Our Members to help them communicate with You directly and to provide a more personalised service to You. This may include contacting You about other relevant properties, adding You to their enquiry database for future contact and offering You their additional services, however they must form their Own lawful basis for doing so;
- To provide Services and information to Our Members which they can use to benchmark their performance;
- To customise and enrich Your experience on Our Platforms;
- To contact You for Your views on Our Services and to notify You occasionally about important changes to Our Terms of Use or this Policy or developments to Our Platforms or Services;
- Credit Reference Agencies: To perform a credit check and share the results with Us and Our Member to allow Our Member to assess Your suitability for renting a property.
- Human Resources: To process Your job application and consider You for one of Our job vacancies;
- Journalists: To send You Press releases that may be relevant to You and correspond with You and
- Our Members: from time to time Our Members may share Your personal data with Us for the purpose of:
  - evaluating their performance and identifying training needs; or
  - providing You supporting evidence for a valuation of Your property where You have invited Our Member to perform a market appraisal.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:
- Enhancing the Service that You receive on Our Platforms;
- Providing a Service to Our Members so they can respond to enquiries;
- Providing information necessary to enable Us to provide a competitive, cost effective service;
- Job applicants: Enabling Us to recruit for Our job vacancies in order to provide Our Platforms and Services;
- Journalists: To respond to Your enquiries and provide timely information and press releases; and
- Our Members:
  - To provide Our Members insights into the effectiveness of Homehop, to evaluate Our Members performance and identify any training needs.
  - To help facilitate Our Members share with You supporting evidence for a marketing appraisal.
We rely on consent to process this Personal Information:
- Credit Reference Agencies: They will share the results of Your credit check with Us and Our Member in order for Our Member to assess Your suitability for a rental property.

How long We will keep it for

We will store this Personal Information for two years from the date on which You last used Our Platforms or Services at which point it will be erased or anonymised so that the data no longer identifies You;
Human Resources: We retain Personal Information for as long as is required to fulfil the purpose (whether that be for the current job application or retaining on file for future job vacancies) or until You notify Us that You wish for Your Personal Information to be deleted;
Journalists: We retain Your Personal Information until You notify Us that You wish for Your Personal Information to be deleted or until Our records indicate You no longer undertake journalistic activities that relate to Our products or Services; and
Our Members: We will only retain Your Personal Information for as long as necessary to fulfil the purposes We collected it for. Once the purpose has ended, We will anonymise Your Personal Information (so that it can no longer be associated with You) for research or statistical purposes and We may use this information indefinitely without further notice to You.
Credit Reference Agencies: We retain the results of a credit check for 3 years.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

What We collect and where it comes from

This is different to “Personal Information You give to Us” because it relates to technical data that We collect. We may:
- Collect technical information that has the potential to identify You, including the type of Device You use, a unique identifier (for example, Your Device’s IMEI number), the internet protocol (IP) used to connect Your computer to the internet, the MAC address of the Device’s wireless network interface, or the mobile phone number, Your login by the Device, mobile network information, Your Device operating system, the type of browser You use on Your Device and its time zone setting, the browser plug-in types and versions, operating system and platform; browser type and version and Your login data;
- Collect Personal Information about Your visit to Our Platforms and/ or Your interactions with Our direct marketing using tracking pixels to identify device types, the full Uniform Resource Locators (URL) clickstream to, through and from Our Platforms (including date and time), products You viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and how You use Our Platforms, products or Services;
- Collect details of Your use of Our App or Your visits via the App, the resources that You access and the advertisers and partners that You contact;
- Use GPS technology on Your Device to determine Your current location. Some of Our location-enabled services require Your Personal Information for the feature to work;
- Set a unique application number which is contained within the App. When You install or uninstall the App or when the App searches for automatic updates, that number and information about Your installation (for example, and the type of operating system) may be sent to Us; and
- Combine technical information with other information that We have about You to help Us with Our processing of Your Personal Information as set out in this Policy.

Why We collect it

We will use the information summarised above:
- To provide Our Platforms to You;
- To customise and enrich Your experience on Our Platforms;
- To provide You with GPS enabled functionality;
- To deliver relevant content and advertisements to You on Our Platforms and measure or understand the effectiveness of the advertising We serve to You;
- To use data analytics to improve Our Platforms, Services, marketing, customer relationships and experiences;
- To conduct reviews that assist Us in the improvement and optimisation of Our Platforms;
- To identify what versions of the App are being used or when the App is uninstalled from a Device;
- To ensure that content from Our Platforms is presented in the most effective manner for You and for Your device;
- As part of Our efforts to keep Our Platforms safe and secure;
- To administer Our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To respond to and deal with Your queries or complaints and to provide or improve Our customer service to You; and
- For internal training purposes.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:
- To help ensure the on-going security of the Platforms;
- To enhance the service that You receive on the Platforms;
- To provide information necessary to enable Us to provide competitive, cost effective Services;
- To provide customer support including dealing with Your complaints, enquiries and to improve customer service;
- To monitor quality and conduct staff training;
- To study how Our Platforms are used, including how customers use Our Services, to develop them, to develop and grow Our business, to inform Our marketing strategy, to define types of customers for Our Services and to keep Our Platforms updated and relevant; and
- To operate Our business and Platforms (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, provision of administration and IT services, network security and to prevent fraud);
If You wish to use a location data service which engages Your Device’s GPS tracker, You will be asked to consent to Your Personal Information being used for this purpose upon registering to use the App. You can withdraw Your consent at any time by turning off the location services settings for the App on Your Device.

How long We will keep it for

We will store this Personal Information for two years in order to allow Us to review and monitor normal traffic patterns and trends on Our Platforms at which point it will be erased or anonymised so that the data no longer identifies You. We will store the unique application number for as long as the App is installed.

TENANT AND GUARANTOR REFERENCING

What We collect and where it comes from

In the course of providing Our Services We may collect Personal Information about You (either as a tenant or where You are acting as a guarantor):
- When a landlord or Our Member requests that a tenant reference is conducted in respect of You, they will provide Us with Your name, phone number and email address;
- When You provide to Us in Your application, or as part of correspondence with You by email or phone regarding Your application or tenant reference, or where You request a call back from Us:
  - Contact and identity data: Including name, date of birth, national insurance number, address including previous addresses, email address, phone number and gender;
  - Employment data: Including salary, job title, contract type, place of work and length of employment;
  - Education data: Including student number and university;
  - Financial data: Including bank account details, transactional data from open banking, tax codes, benefits and pension details, credit accounts held, credit score, repayment performance and any adverse credit history such as County Court Judgments, IVAs, debt relief orders and bankruptcy, or other adverse credit or tenancy history. We may receive Personal Information about others, such as the names of Children if You provide information about any benefits You receive. To verify Your income, We may collect documents such as benefit award letters, bank statements, P60s, pay slips, scholarship letters and employment contracts;
  - Property data: Including address, rent and moving in date as well as details about property You have previously owned or rented;
  - Lifestyle data: We may also collect data about Your compliance with previous tenancy agreements including paying the rent on time, the condition of Your last property when You moved out, Your honesty/trustworthiness, Your smoking status and whether You have any Children and/or pets;
  - Next of kin details; full name, postal address, telephone number and postcode;
  - The above Personal Information and any related or similar Personal Information You give Us is known as “Referencing Data”;
- We may collect any of the above contact, property or identity Personal Information directly from a landlord or Our Member when they request an instant credit history is conducted on You;
- We may collect some of the above Personal Information about You as part of the tenant referencing process from publicly available sources such as Companies House and the Electoral Register and from third parties such as credit reference agencies (Equifax) and Your referees (employers, pension providers, accountant, managing agent and landlords);
- For rent guarantee insurance:
  - If We did not conduct the tenant reference check, We may receive the Referencing Data from the tenant referencing agent who conducted the tenant reference check about You;
  - In the event of a claim, We may also obtain Personal Information from third parties including the other party to the claim, witnesses, experts, solicitors and claim handlers; and
- If You use Our call back feature, We also collect best time to contact You.
In the course of providing Our Services We may collect Personal Information:
- When Our Member requests that a tenant reference is conducted they will provide Us with Your name, phone number and email address;
- If You request a quote or apply for an insurance product, We will collect the following additional Personal Information: title, date of birth, address of property to be insured, monthly rent of property, correspondence address, occupation, industry, number of properties You own, whether the insurance is for a new mortgage application, criminal offence data (unspent convictions or pending prosecutions other than motoring convictions);
- We will collect the following Personal Information if You pay for the insurance product by payment card (PAN number, expiry date and CVV) or direct debit (bank account number and sort code); and
- In the event of a claim for one of the insurance products You have purchased through Us, We may also obtain Personal Information from third parties including the other party to the claim, witnesses, experts, solicitors and claim handlers.
In the course of providing Our Services We may collect Personal Information:
When Our Member requests that a tenant reference is conducted, they or the tenant will provide Us with Your name, phone number and email address so that We can contact You to provide a reference for the tenant or guarantor (via telephone, email or SMS);
When You provide Us a reference for a tenant, You may provide Us with additional Personal Information as part of that reference. The reference You provide will be shared with Our Member and may be shared with the landlord of the property to provide supporting evidence on a tenant’s suitability to rent a property, or shared with the tenant or guarantor where We are legally required to do so;
- Landlord: name, email address, phone number, confirmation of your rental property address that the tenant rented from You;
- Accountant: accountancy firm, accountancy contact name, accountancy postal address, telephone, email, fax and how long the applicant has been a client of Yours; and
- Employer or other type of referee: referee name, referee position, telephone email, fax.
From time to time, We may contact You by email or telephone to collect Your opinions and feedback on Our Services.

Why We collect it

We use Your Personal Information to conduct a reference check;
We will use this to send You a SMS and/or email asking You to complete an application form, which We require in order to conduct a tenant reference check for You. We may also call You on Your mobile number if We do not hear from You;
To contact You regarding Your application and respond to any queries You may have;
To obtain a tenant reference. This includes conducting (Ourselves or via a third party, as explained in this Policy) credit checks, affordability checks, verifying the Personal Information that has been provided to Us, fraud/ money laundering checks, ID checks and confirming Your right to rent in the UK;
We will share Your Personal Information with third parties for the purposes of conducting a tenant reference. This may include with employers, accountants, pension providers, credit reference agencies and landlords. These third parties will then be asked to provide a reference in respect of You to Us. Once We have completed the tenant referencing process, We will provide Your landlord or managing agent with the Referencing Data and results of the tenant reference;
We will process Your Personal Information to provide an instant credit history for the landlord/managing agent. This will involve sharing Personal Information with Equifax for the purpose of a soft credit check which will be used by Us in providing an instant credit history. Once We have completed the instant credit history process, We will provide Your landlord or managing agent with the results;
We will provide You the option to share Your transactional history through Open Banking to support Your tenant reference;
If the tenant reference is positive, We may contact You (as a tenant) about contents and/or liability insurance, utilities and broadband products that may be of interest to You via text, email and/or telephone. We will not contact guarantors for marketing purposes.
If You decide to take out insurance products with Us, We will need to use this Personal Information to process Your application and, if successful, put the insurance in place. This may involve Us sharing Your Personal Information with applicable underwriters and insurance providers to put the insurance in place;
If You take out insurance with Us, to notify You of changes to the insurance product and/or terms;
To manage Our relationship with You where You take out insurance products:
- To manage payments, fees and charges;
- To manage Your insurance policy;
- To collect and recover monies owed;
- To assist with any claims including payment of any insurance claims;
- To contact You regarding renewal of Your policy;
If You fail to pay Your rent or comply with the tenancy agreement whether or not We provide insurance services to Our Members or landlords (such as rent protection), We may need to process the Referencing Data. We will process this Personal Information to:
- Take steps to enforce the tenancy agreement against You;
- Collect payment due by You (including instructing debt collection agencies or bailiffs);
- Obtain Your whereabouts (including instructing tracing agencies);
- Pursue a claim against You;
Provide Our Members the property address of their rental properties where a Rent Guarantee policy has been purchased from Us;
Where You choose to use Our Platforms to generate a quote or purchase an insurance policy or utility, We will pass Your details to the Member in order they can process Your application/ quote;
We may need to share Your Referencing Data with the managing agents, insurance providers, underwriters, legal advisors, bailiffs, debt collection agencies and other third parties in furtherance of collecting payments by You, enforcing the tenancy agreement or pursuing any claim against You. This may also include sharing Your Referencing Data with the other party to the claim, witnesses, experts, solicitors and claim handlers;
To understand where You are in Your journey so We can provide assistance with Your application; and
We will share Your Personal Information (name of tenants, rental property address, email address, telephone number, tenancy start date and length of tenancy) with One Utility Bill Limited where Our Member has instructed Us to do so. This will be for the purpose of administering utilities and council tax billing at the rental property for Your tenancy.
Send You an email with a summary of the referencing results for You to approve (where Our Member has this functionality switched on);
Contact You via telephone regarding insurance products that may be relevant to You; and
Where We have obtained consent, contact You via email or SMS to provide quotes for insurance products that may be relevant to You.
We will use Your Personal Information to contact You to request a reference on behalf of a tenant (the reference You provide will be used to support their Tenant Reference check);
The reference You provide:
- Will be shared with Our Member and may be shared with the landlord of the property to provide supporting evidence on a tenant’s suitability to rent a property; and
- Will only be shared with the tenant where We are legally required to do so.
To contact You by email or telephone for market research purposes and to obtain feedback on Our Services in order to help Us improve our Services, processes and offerings.

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information. These legitimate interests are:
- To carry out tenant referencing services and perform Services for Our Members;
- To provide an instant credit history / service to managing agents or landlords;
- To recover payments due or to make payments;
- To provide customer support including dealing with Your complaints, enquiries and to improve customer service, monitor quality and conduct training;
- To protect managing agents / landlords by enforcing tenancy agreements and collecting debts and part of the insurance process;
- To provide You access to insurance and tenant related services which may be relevant to You. Contact may be via email, text, telephone or otherwise;
- To assist You with generating a quote for insurance, utilities and tenant related services;
- To assist with administering utilities and council tax billing at the rental property for Your tenancy;
In some instances We may rely on Consent to process Your Personal Information:
- If the tenant reference is positive, We may send You direct marketing about insurance products that may be of interest to You via SMS or email;
- To process transactional data from open banking to support Your tenant reference;
- If You decide to take out insurance products with Us, We will need to use this Personal Information to process Your application and, if successful, put the insurance in place. This may involve Us sharing Your Personal Information with applicable underwriters and insurance providers to put the insurance in place;
- To process special category (such as smoking and benefits received which may reveal sensitive data) and criminal offence data as part of Your application;
Where necessary to comply with a legal obligation:
- When We are performing fraud/money laundering checks;
- Notifying You of changes to the insurance products or terms; and
Performance of a contract with You or Our Members.
We have a legitimate interest to process this Personal Information. These legitimate interests are:
- To provide You with a summary of the referencing results for You to approve (where Our Member has this functionality switched on);
- To carry out tenant referencing services and perform services for Our Members;
- To provide You access to insurance and tenant related services which may be relevant to You. Contact may be via email, text, telephone or otherwise;
- To provide You access to insurance products which may be relevant to You (contact may be via text, telephone or otherwise);
- To assist You with generating a quote for insurance where requested by You;
In some instances We may rely on Consent to process Your Personal Information:
- If You decide to take out insurance products with Us, We will need to use this Personal Information to process Your application and, if successful, put the insurance in place (which may involve Us sharing Your Personal Information with applicable underwriters and insurance providers); and
- To process special category and criminal offence data as part of Your application.
We have a legitimate interest to process this Personal Information. These legitimate interests are:
- To carry out a tenant reference and provide Services for Our Members; and
- To contact You to request a reference on a tenant which provides supporting evidence on a tenant’s suitability to rent a property.
We have a legitimate interest to process Your Personal Information in order to help improve Our Services, processes and offerings.

How long We will keep it for

Tenants, Guarantors, Landlords and Referees:

We will only retain Your Personal Information for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information and whether We can achieve those purposes through other means, and the applicable legal requirements;
We have to keep basic Personal Information about You (including Your contact, identity, financial and transactional data) for 3 years after You cease being a customer or after completion of the tenant reference check, whichever occurs last, for tax purposes;
All Personal Information will be destroyed after 3 years to ensure compliance with any regulatory authority; and
In some circumstances We may anonymise Your Personal Information (so that it can no longer be associated with You) for research or statistical purposes in which case We may use this information indefinitely without further notice to You.

FINANCIAL SERVICES (e.g., Mortgage in Principle)

What We collect and where it comes from

In the course of providing Our Services We collect Personal Information when You apply for a mortgage in principle decision via Our Platforms. When You start Your application, You provide Us the following Information about Yourself and other applicants (who are party to the mortgage in principle and have agreed to You submitting their Personal Information to Us):

Contact and identity data: Full names (including any previous known names), date of birth, gender, country of birth and nationality;
Applicant data: Number of people applying;
Employment data: Employment status, job title, job role, industry, contract type, length of employment, self employed details where relevant (sole trader, freelancer, partner director with 20% share or less, director with more than 20% share, length of self-employment, if a subcontractor whether Your contract is likely to be renewed and remaining length on Your contract) , whether You are an employee for tax purposes, whether you are permeant employee, temporary or are a fixed term contractor, annual income and additional earnings (includes commission, overtime and bonuses), second job information, planned retirement age and years ;
Financial data: Mortgages held, how You will be financing Your property purchase, property price/value, deposit details (amount and source of money), mortgage term, state benefits You receive, credit cards and store cards, loans (buy now pay later, personal loans, finance such as hire purchase and personal contract payment), whether You have been declared bankrupt or entered into a voluntary agreement in the last 6 years, retirement income, income from other sources (maintenance, pension, investments, rent) regular outgoings, whether Your income is likely to drop in the next 2 years and buy how much and whether your regular outgoings are likely to increase in the next 2 years and by how much);
Property data: Property ownership, secondary or primary residence, ownership status of Your current address, property addresses from last 3 years and whether You have an armed forces postal address, type of property being purchased;
Lifestyle data: Whether You have any dependents, age of dependents and Your personal spending;
Your consent to share special category data with Our Member lender; and
What stage of the home-moving process You are and whether you are a first time buyer, re-mortgaging, investing, selling etc.;
Our Member lender will provide Us their decision on Your mortgage in principle and a unique reference number;
Where either You identify Yourself (or We identify You) as vulnerable in the course of corresponding with Us, We will record the category of vulnerability in Our ticketing system in order to meet Our legal obligations.

Why We collect it

We will use the information summarised above:
- To process Your application for a mortgage in principle;
- To send You an email with Your mortgage in principle status;
- To notify You by email when Your mortgage in principle decision is about to expire;
- To contact You about Your mortgage in principle decision and next steps:
- To comply with impacting regulation and fulfil any legal obligations

Our lawful basis for processing this Personal Information

We have a legitimate interest to process this Personal Information to:
- Provide You with a mortgage in principle decision in order to help simplify the home moving process;
- Keep You updated on the status of Your mortgage in principle decision;
- Provide assistance on next steps;
We rely on Consent to process Your Personal Information which is special category data;
Performance of a contract with Our Member mortgage lender; and

We have a legal obligation to process Your Personal information to achieve compliance.

How long We will keep it for

We will retain Your Personal Information for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which We process Your Personal Information and whether We can achieve those purposes through other means, and the applicable legal requirements;
We will retain email address, full name, loan size, property value, mortgage in principle end reference number and the result of the mortgage in principle decision (including reason for any declined application) for up to 6 years, after which it will be deleted or anonymised;
We retain the following Personal Information for no longer than Your session on Our Platforms (i.e. the period of time You are active on Our Platforms) unless We anonymise it or there has been no activity during Your session for 30 minutes, in which case We will delete the following data:
- Special category data collected for the purpose of providing a mortgage in principle decision;
- Where we anonymise Your Personal Information (so that it can no longer be associated with You) for the purposes of regulatory reporting, monitoring key performance indicators, gaining market insights or for research or statistical purposes then We may use this information indefinitely without further notice to You.

SHARING OF PERSONAL INFORMATION BETWEEN HOMEHOP AND ITS SUBSIDIARIES

Personal Information You provide Us may be shared between Our subsidiaries in order to:

provide Our Platforms and Services to You;
improve Our Platforms and Services; and
customise Your experience on Our Platforms.

PROFILING

We may from time to time profile Your activity when using Our Services or Our Platforms.

This profiling is based on telephone and email enquiries You send to Our Members, properties advertised on Our Platforms, cookies and information You either provide Us or We collect in the course of using Our Platforms and Services. We may use this information both now and, in the future, to identify:

any properties You may have for sale or let;
whether You are intending to sell or let Your property;
if You have subsequently instructed one of Our Members to advertise Your property;
what stage in the home moving process You are;
whether You have a mortgage in principle decision;
whether You are a first time buyer, re-mortgaging, investing, a seller, tenant, a landlord etc.;
if You may require a valuation of Your property; and
whether You have been through Our tenant referencing.

It takes place to help Us and Our Members:

understand what sort of properties You may be interested in;
identify opportunities to improve training;
match enquiries sent to Our Members with properties advertised on Our Platforms. This is to provide Our Members with market insights where Your property was subsequently advertised with another Member. This will be provided for training purposes only to help Our Members improve their processes for identifying where enquiries may have a property for sale or rent, either now or in the future;
to categorise Your activity to help Us and Our Members determine how likely You are to require services from Our Members. Members may then contact You to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing Your Personal Information);
use this information to customise Your experience on Our Platforms such as:
- suggest properties that may be of interest to You;
- suggest Our mortgages, valuations, insurance and referencing Services to You; and
- suggesting services from Our third party advertisers that may be relevant and of interest to You based on Your use of Our Platforms.

You can always object to Our profiling by emailing Us here support@homehop.io. Any profiling data that We hold about You will only be kept for as long as is required to perform the Services to Our Members and provide Our Platforms and Services to You.

USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING AND OTHER COMMUNICATIONS

Direct Marketing

Sometimes We may Use Your Personal Information to provide direct marketing messages to You; either directly from Us or on behalf of Our Members. You can opt out of direct marketing at any time from Our entities below by:

Using the unsubscribe links located at the bottom of the direct marketing emails We send You. Please ensure You click through to manage Your full marketing preferences;
Log into Your My Homehop account to manage your marketing preferences; or
Contacting Us directly on support@homehop.io.
Using the unsubscribe links located at the bottom of the direct marketing emails We send You. Please ensure You click through to manage Your full marketing preferences; or
Contacting Us directly on support@homehop.io.
Contacting Us directly on support@homehop.io

It may take up to 72hours from the time You receive confirmation from Us that Your preferences are being updated to unsubscribe You from direct marketing.

You can always make use of Our Platforms and Our Services without having to agree to direct marketing. The types of things that We may do include:

Providing direct marketing advertisements and communications to You via email, text, post or telephone;
Making suggestions and recommendations to You and other Users of Our Platforms and Our Services about goods or Services that may interest You or them;
Communicating with You on third party social media platforms;
Monitoring the effectiveness of Our direct marketing communications and Your responses to it which can help Us improve Our Services and communications;
Using a clear image GIF to track results of an email campaign such as the device You use. You can turn this off for future emails by turning off images in the email itself;
Where Your tenant reference is successful We may use Your Personal Information to contact You via text, email and/or telephone to inform You about insurance, utilities, broadband or other tenant related services (We obtain Your consent to send direct marketing to You for this processing as part of the tenant reference application form); and
We will retain Your marketing preferences to ensure We comply with Your instructions.

You can request the list of Our Members from whom We send marketing by contacting Our Data Protection Officer.Other Communications

When You opt out of receiving direct marketing from Us, You will still continue to receive transactional messages from Us regarding Our Platforms and Services. We have a legitimate interest to send You these communications, examples of which include:

Important updates to Our Services, Privacy Policy and Platforms;
Managing Your My Homehop account;
For security reasons;
To contact You about Your mortgage in principle decision;
Receiving Property Alerts where You have set them up in Your My Homehop Account (You can amend your Property Alerts at any time in Your My Homehop account);
Where a home hunter shares a property with You via Our Platforms; and

PHOTOS, IMAGES AND VIDEOS OF YOU

Where You have agreed to participate and feature in videos, images and photos for Us, these will be used for the purpose outlined to You at the time, which can include to promote Homehop or its subsidiaries. This will be retained for no more than 3 years after the purpose has ended. We have a legitimate interest to use these on any of Our Platforms or 3rd party social media platforms.

REMOVING PROPERTY DATA FROM OUR PLATFORMS

If You have any concerns about the properties advertised on the Platforms, please contact Us at support@homehop.io and We will endeavour to resolve the issue promptly.

If You are a vendor or landlord of a property that is being actively marketed on Our Platforms and You want this removed, please contact Your estate agent or lettings agent directly in the first instance.

If You have concerns about historical property information about a property featured on Our Platforms and You can prove to Us that You have a valid association to that property, please contact Us at support@homehop.io.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?

We retain access to all Personal Information that We have collected from You or about You. Once Your Personal Information has been passed to one of Our Members in the course of providing Our Services (most typically when You communicate with an estate agent through Our Platforms) then Our Member will have a copy of the Personal Information that You have provided within Your enquiry and Your contact details which they will use to get in touch with You.

Property data, it is provided to Us by Our Members (or third parties that act on their behalf). Our Members (or any third party that acts on their behalf) will be responsible for Personal Information in their possession and that Personal Information will be subject to any privacy terms or policies that the Member has in place. We are not responsible for use (or misuse) of Your Personal Information by any of Our Members.

When Our Services are available via the websites of Our partners or Members, those partners or Members may have access to Your Personal Information. We may also have links to other third party websites from Our Platforms. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Information about You. We are not responsible for the content, security, privacy policies and practices of any other third party websites, even if You access them using links from Our Platforms or if You can access Our Platforms or use Our Services from them. We recommend that You check the policy of each website that You visit and make sure that You are comfortable with the terms of such policies before You visit them or provide any Personal Information to them.

If Our business is sold or merged, or if We sell or buy any business or assets, We may disclose Your Personal Information to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If We offer or supply a Service to You that is provided on Our behalf by a third party, We may have to pass Your Personal Information to them in order to deliver the service. The categories of third parties (who are acting as Data Processors which means they are responsible for processing Personal Information on behalf of Us) include:

Telephony providers (including call recording);
Our support ticketing systems;
SMS providers;
E-calendar providers;
E-signatory providers;
Payment providers;
Translation and transcription providers;
Market research agencies;
IT providers who provide systems to Us for the purposes of hosting and supporting Our Platforms; and
Marketing agencies and systems that allow Us to send marketing communications to You and to make sure the marketing communications are relevant.

We may also use third parties to provide Services on Our behalf which may include processing (but not using themselves) Your Personal Information; for example, to complete partial addresses or to augment the Personal Information We hold about You. In either case, We will not pass Your Personal Information to anyone who is not also subject to adequate privacy commitments in Our contract with them.

Credit reference agencies for the purpose of checking that the details You have provided Us are correct and to obtain further details (as set out above);
Payment providers to set up a direct debit and/or take payment from You;
Insurance brokers, providers and underwriters for the purpose of arranging insurance policies;
Debt collection agencies, tracing companies, bailiffs and legal advisors in order to recover monies due from You, to trace Your whereabouts or in pursuit of a claim against You; and
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

We may be required to share Your Personal Information with the following external parties:

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
Police or other such regulatory authority as part of an investigation or otherwise for legal or regulatory purposes;
Dispute Resolution agencies for the purposes of dealing with any complaints;
UK law enforcement agencies and third party security companies for the purposes of ensuring that We comply with the law and have adequate security measures in place; and
We will disclose Your Personal Information to other third parties if We are under a duty to disclose or share Your Personal Information in order to comply with any legal or regulatory obligation or request. This includes exchanging Personal Information with other companies for the purposes of fraud protection and credit risk reduction.

We require all Our third party service providers to respect the security of Your Personal Information and to treat it in accordance with the law. We do not allow Our third party service providers to use Your Personal Information for their own purposes and only permit them to process Your Personal Information for specified purposes and in accordance with Our instructions.

You can request a list of Our third party partners and affiliates by contacting Our Data Protection Officer.

WHERE DO WE STORE YOUR PERSONAL INFORMATION?

The Personal Information that We collect from You may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA, but We are under a duty to make sure that Our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that Your Personal Information is treated securely and in accordance with this Policy. By submitting Your Personal Information to Us, You agree to this transfer, storing or processing.

Unfortunately, the transmission of Personal Information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to Our Platforms; any transmission is at Your own risk. Once We have received Your Personal Information, We will use strict procedures and security features to try to prevent unauthorised access.

We follow strict security procedures to ensure that Your Personal Information is not damaged, destroyed or disclosed to a third party without Your permission and to prevent unauthorised access to it. The computers that store the Personal Information are kept in a secure facility with restricted physical access and We use secure firewalls and other measures to restrict electronic access. If We are working with third parties, We will require them to have in place similar measures to protect Your Personal Information.

Only employees who need access to Your Personal Information to perform a specific job are granted access to personally identifiable Personal Information. In addition, We limit access to Your Personal Information to those agents, contractors and other third parties who have a business need to know. They will only process Your Personal Information on Our instructions and they are subject to a duty of confidentiality.

Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Platforms, You are responsible for ensuring Your password is unique and for keeping this password confidential. We ask You not to share Your password with anyone.

We have procedures in place to deal with any suspected Personal Information breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

We recommend You do not use public or shared devices where You are providing Your Personal Data to Us (such as mortgage in principle applications, sending enquiries about properties, requesting a quote etc) and take appropriate steps to ensure You have removed any local storage or session-based data from your shared/public Device.

YOUR RIGHTS

You have the right to ask Us not to process Your Personal Information at any time.

You have the right to use Our Platforms without consenting to direct marketing and the communication services that We provide. We will inform You (before collecting Your Personal Information) if We intend to Use Your Personal Information for such purposes or if We intend to disclose Your Personal Information to any third party for such purposes. We always use the most recently submitted form to be Your current consent status. If You are a registered User, but not signed in when You submit a form, We will not be able to Use Your saved settings so will deem Your consent choice to be as per the form You submit at the time. You can exercise Your right to prevent such processing by selecting the specific options in the fields or forms when You become a registered User.

You also have a right to:

Request access to or rectification of the Personal Information which We hold about You;
Request erasure of Your Personal Information in certain circumstances;
Restrict the processing of Your Personal Information;
Receive Your Personal Information that You have provided to Us;
Object to or restrict Our processing of Your Personal Information in certain circumstances; and
Request that We transmit Your Personal Information to another data controller.

Where We process Your Personal Information because You have given Us Your consent to do so, You have the right to withdraw Your consent at any time.

Where We process Your Personal Information under legitimate interests, if You object to processing, this will not affect any processing which has already taken place. In some limited instances, objecting to processing of all Your Personal Information may mean You are not able to use some of Our Services or Platforms.

To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy. We may need to request specific information or identification documents from You to help Us confirm Your identity and ensure Your right to access Your Personal Information (or to exercise any of Your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

We try to respond to all legitimate requests within one month. Occasionally it may take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

As part of Our Data Protection obligations and to help Us improve Our Service, We maintain a register of Data Subject Right Requests which contains limited Personal Information (email address, type of request, reason for request, resolution, reference number, application number etc.). These records are only available to Our Data Protection Team or would only be made available to the Information Commissioner’s Office upon request. We will retain these records for up to 6 years from the conclusion of the Data Subject Right Request, after which any Personal Information will be anonymised.

You have the right to complain to the Information Commissioner’s Office if You feel unhappy with the way We process Your Personal Information. Please visit www.ico.org.uk for more information.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the Personal Information We hold about You is accurate and current. Please keep Us informed if Your Personal Information changes during Your relationship with Us.

COOKIES AND TRACKING

Like many website and App providers, We use “cookies” to enable Us to personalise Your visits to Our Platforms, simplify the signing-in procedure, keep track of Your preferences and to track the usage of Our Platforms. We use a mixture of third and first party cookies. Our lawful basis for using cookies are as follows:

Strictly Necessary Cookies: We rely on legitimate interests as Our lawful basis for collecting and processing this data;
Functional Cookies: We rely on consent as Our lawful basis for collecting and processing this data; and
Targeting and Tracking Cookies: We rely on consent as Our lawful basis for collecting and processing this data.

Some web browsers incorporate a “Do Not Track” feature. Currently, as there is not yet an accepted industry standard for how to respond to Do Not Track signals, Our Services and Our Platforms do not currently respond to such signals, however You can:

if You want to restrict ads in general on Your Devices You may opt out from ad tracking by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalisation” (as applicable to Your Device) in Your Device settings.

THIRD PARTY ADVERTISING

As well as providing the Services on Our Platforms, We also feature advertising from third parties. We use a range of advertising partners and technologies to help deliver third party advertisements on Our Platforms which may be relevant to You. To help ensure the advertisements are relevant, We match property listings data, information from cookies and clickstream data to create audience segments. We share Our audience segments with Our advertising partners and only allow certain companies to purchase advertising space on Our Platforms. For example third parties may wish to display advertisements to Users of Our Platforms which We deem as being renters and therefore We will offer space On Our Platforms where renters visit.

We use different technologies and practices for advertisers to purchase advertising space on Our Platforms. This includes Us selecting advertisements through a bidding process from selected companies which allows real-time advertising on Our Platforms, working with digital agencies or directly with third party advertisers. You can request a list of the partners with whom We work by contacting Our Data Protection Officer.

SPECIAL CATEGORY DATA AND CRIMINAL OFFENCE DATA

For Our tenant referencing, insurance, tenant and financial Services, We do collect special categories of Personal Information about You (this may include Your race or ethnicity, information about Your health and any criminal convictions). We rely on explicit consent to collect and process this data, the only exception being for insurance products where We rely on ‘insurance’ as Our condition of processing. We only keep this information for as long as is necessary. We employ appropriate technical and organisational measures to ensure Your Personal Information is secure.

AGGREGATED DATA

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from Your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal Your identity. For example, We may aggregate Your usage data to calculate the percentage of users accessing a specific feature on Our Platforms. However, if We combine or connect aggregated data with Your Personal Information so that it can directly or indirectly identify You, We treat the combined data as Personal Information which will be used in accordance with this Policy.

CHANGE OF PURPOSE

We will only use Your Personal Information for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. Please note that We may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CHANGES TO THIS POLICY

We may change the terms of this Policy at any time. Any changes We may make to this Policy in the future will be posted on Our Platforms and displayed on-screen when You use Our App.

You may be required to read and accept any revised Policy to continue Your use of Our Platforms. The amended terms will be made available with new uploads or updates of the App and will be displayed in the Privacy Policy section of the App.

Please check back frequently to see any updates or changes to this Policy, as You will be deemed to accept such changes from Your continued use of Our Platforms.

Issue date: 22 September 2022