Tenancy360 is a private limited company registered in England and Wales with company number 13308651. Tenancy360 Ltd’s registered address is 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
We will obtain your consent to any material changes if this is required by applicable data protection laws.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal information we may process about you broadly falls into the following categories:
Information you provide voluntarily:
- You may be asked to provide information voluntarily about yourself when you use our service. As a user of our service, you may wish to create an account with us. The personal information that you may provide when setting up your account may include your name, email address, postal address, bank account details and telephone number.
- You may also provide us with personal information in your correspondence with us and in the content you upload whilst using the service. If you register to hold an account with us, you will also have a unique identifier and password which enables you to access your account.
- You may provide us with personal information directly in your capacity as a tenant or guarantor (benefitting from our services directly). This personal information may include your name, date of birth, email address, postal address, bank account details, telephone number, name of your employer, salary and the name of your referees.
- As a tenant or guarantor, you may also provide us with access to your transaction data through Open Banking. We will gain your explicit consent to do this and will only process your transaction data for the purposes set out by your letting agent.
- Alternatively, you may be an estate agent who is setting up accounts on our website. In your capacity as estate agent, you may be asked to provide us with personal information such as your name, email address, telephone number, name of your employer and your business bank account details.
- We will use the information you provide:
1. to facilitate the contract between you and your relevant tenant, guarantor or estate agent as appropriate.
2. to provide you with services you have purchased from us where appropriate.
3. to process payments.
4. to verify your identity and collect credit reference and fraud prevention data, as well as publicly available information including, but not limited to, electoral roll, county court judgements, bankruptcy, and insolvency information.
5. to run affordability assessments and other pre-tenancy checks.
6. to prevent, detect and investigation potentially illegal activities.
7. to send you information about the service.
8. to provide customer services to you in relation to the service.
9. to contact you, to deal with enquiries and complaints relating to the use of the service and to notify you of any changes to the service.
10. to provide you with marketing communications by electronic means about our products, services, events and offers which you have requested.
Information we collect automatically:
- Details of your visits to our website (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access.
- We use the information we collect automatically:
1. to administer our website for internal operations including troubleshooting purposes.
2. as part of our effort to keep our website safe and secure.
3. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
4. to develop, improve and personalise the Service so as to improve your experience.
5. to provide third parties with anonymised statistical information about our users.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will disclose your personal information to the following recipients:
1. If you are a tenant or guarantor, to your relevant letting agent for whom we perform the Tenancy360 services.
2. Third party service providers and partners who provide data processing services to us, e.g. to verify your identity.
3. Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure to be necessary to comply with a legal obligation, to exercise our legal rights, to protect the vital interests of any person, or as otherwise required or allowed under applicable law.
5. With your consent, in order to provide the Home Setup and Utility Management Services we may, in the course of provision of the services, share move-to and move-from addresses, moving dates, tenancy details, council tax status, and other data required for the provision of those services (including data relating to other occupants or household members) to Ethical Introductions Ltd (T/A Just Move In).
Where a Tenant receives Home Setup Services provided by Just Move In then, for the purpose of fulfilling the contract for those services, we will need to also provide relevant personal data to Just Move In. Just Move In will store and be a controller of such personal data. Just Move In (full company name Ethical introductions Ltd)provides a privacy notice describing their use of data, available here: www.justmovein.com/privacy
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and may report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
A “cookie” is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but “persistent” cookies - which are not session-based - remain on the viewer’s computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. We may use persistent cookies to allow us to collect information about a viewer’s browsing habits whilst on our site, so that we can monitor and improve our services.
We do not store sensitive information such as account numbers or passwords in “persistent” cookies, and cookies in themselves do not contain enough information to identify you.
In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our website. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.
You can find and control your cookie settings via your browser; your browser help function will tell you how. Please note, it is not possible for Tenancy360 to allow you to carry your settings with you between your browsers and devices so you will need to change these settings for each browser you use.
We will only use your personal data 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 data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not transfer your personal data outside the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (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.
Your personal information is protected under data protection law and you have a number of rights (explained below) which you can seek to exercise.
Please contact us using the details contained in section 1 if you wish to do so, or if you have any queries in relation to your rights. If you seek to exercise your rights we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances.
Right of access: Subject to certain exceptions, you have the right of access to information that we hold about you upon request. You can exercise this right by making a request in writing, by email or telephone using the contact details shown below.
Right to rectify your personal information: If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).
Right to be forgotten: You may ask us to delete information we hold about you in certain circumstances, this is often referred to as the ‘right to be forgotten’. This right is not absolute and only applies in particular circumstances. It may not therefore be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations or to exercise or defend legal claims.
Right to restriction of processing: In some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified. You have the right to ask us to restrict the use of your information certain purposes for example for marketing communications.
Right to object to processing: You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing (including profiling to the extent it relates to direct marketing) and for the purposes of statistical analysis.
Right to data portability: You have the right to receive, move, copy or transfer your personal information to a controller which is also known as ‘data portability’. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means. You should note that this right is different from the right of access (see above) and the types of information you can obtain under the two separate rights may be different.
A fee is not usually required to exercise these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 could 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.
By post to The Data Protection Officer, Tenancy360 Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
By email to DPO@dwelt.io.
By telephoning the Data Protection Officer on 01494 304471.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can contact the ICO by writing to them at Information Commissioner’s Office Client Services Team, Wycliffe House, Water Lane, Wilmslow, SK9 5AF telephone 0303 123 1113. www.ico.org.uk/.