Privacy Policy & Cookies

Last updated: 04-09-2019

TENANT APPLICANT AND CURRENT TENANT PRIVACY POLICY

Accommodation.co.uk is a Website operated by Accommodation Lettings Ltd (”We”). We are registered in England and Wales under company number 11423942 and have our registered office at WeWork, No1 Spinningfields, Quay Street, Manchester, M3 3JE

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we collect, process and look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you.

We will firstly summarise the purpose of this policy, provide you with our full contact details and your rights in respect of the personal data we hold about you. We then deal with (i) what data we collect from you; (ii) how it is collected; (iii) how long we retain the data; (iv) how we use the data; and (v) what third parties we may disclose your data to. We will then summarise this in a table in section 10, Data Summary below. Finally, we provide further information in sections 11 to 15 other aspects of our use of your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to be provided services by us or in any other way provide us with personal information through this Website.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.
This policy should be read in conjunction with the following policies which also apply to your use of our Website:

  • Our Terms of Use www.accommodation.co.uk/terms/terms-of-use
  • Our Terms and Conditions in respect of the Services we provide to you (if you are a landlord); and
  • Our Cookie Policy https://accommodation.co.uk/privacy/cookies

1.2 CONTROLLER
We are the controller and are responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the named individual using the details set out below.

1.3 CONTACT DETAILS
Our full details are:

Company name: Accommodation Lettings Ltd
Company number: 11423942
Registered office: WeWork, No1 Spinningfields, Quay Street, Manchester, M3 3JE
ICO registration number ZA468080
Contact name: John Lomas
Email address: DPO@accomodation.co.uk
Telephone number: 0203 868 4944

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

3.0 THE DATA WE COLLECT AND HOLD ABOUT YOU
3.1 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, e-signature and reference data from previous landlords.
  • Contact Data includes billing address, residential address (including bedroom number if a house in multiple occupation), rental property address (including all applied for properties and any properties actually rented by the data subject), delivery address, email address (including personal email address, student email address and work email address) and telephone numbers (including mobile, residential and work phone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 data but is not considered personal data 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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 have summarised the personal data we collect from you in section 10 below.

4. HOW IS YOUR PERSONAL DATA COLLECTED AND WHO IS COLLECTING IT?
We use different methods to collect data from and about you including through:

  • Direct interactions. We may collect your Identity, Contact, Financial Transaction, Profile and Marketing and Communications Data directly from you when you fill in forms or by corresponding with us by post, phone, email, directly through the functionality of the Website or otherwise.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://accommodation.co.uk/privacy/cookies

We have summarised the personal data we collect from your and who is collecting it in section 10 below.

5. WHY WE COLLECT YOUR DATA
There are a number of reasons why we may collect your data, we have listed some below (this is not an exhaustive list);

  • To create Tenancy Agreement;
  • To reference the applicant;
  • To contact the tenant for property management;
  • To operate the business lawfully and efficiently;
  • To use for deposit scheme Prescribed Information;
  • To use in legal proceedings (for possession/arrears); and
  • To notify utility companies and council.

The specific reason we collect different personal data from you is detailed in the summary in section 10 below

6. LAWFUL BASIS FOR PROCESSING AND USE OF YOUR DATA
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:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 have summarised the lawful basis on which we process the specific personal data we collect from you in section 10 below.

7. HOW IS YOUR DATA STORED
Most of the personal data we collect from you will be stored electronically on our secure systems. The specific way we store data is specified in the table in section 10 below.

8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the external third parties set out below to enable us to use your personal data in line with our lawful basis for processing your personal data;

  • Landlord and tenant referencing companies, for example Movem, Northrow;
  • CRM system provider, for example HubSpot;
  • E-signature platform, for example Eversign;
  • Key management solution provider, for example Key Nest;
  • Deposit protection scheme provider, for example MyDeposits;
  • Customer support provider, for example ZenDesk;
  • Payment system provider, for example Cardstream;
  • Property portals, for example Rightmove, Zoopla & Spareroom; and
  • Location finder, for example GetAddress.io & Google API.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based UK who provide consultancy, banking, legal, insurance and accounting services.
  • Utility companies (gas, electric, internet providers etc);
  • Local council;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In certain circumstances these third parties may become Data Controllers under the Data Protection Act 2018 and in those circumstances those third parties will contact you regarding their use of your personal data.
We have summarised the third parties to which we disclose the personal data we collect from you in section 10 below.

9. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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 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 requirements.?
In some circumstances we may 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.
We have summarised the period we retain the specific personal data we collect from you in section 10 below.

10. DATA SUMMARY
In this section we summarise how the information given in sections 3 to 8 above are used. We use the terms highlighted in bold in those sections in the summary table below and so please cross reference with the relevant section above if necessary. The section that some column references to is given in the table headings.

Data Held Who is collecting How collected Why collected Lawful basis for processing How is data stored Who is data share with Disposal data
Identity Accommodation.co.uk and landlords Online, telephone, email To create Tenancy Agreement. To reference the applicant. To contact the tenant for property management. To operate the business lawfully and efficiently. To use for deposit scheme Prescribed Information. To use in legal proceedings (for possession/arrears). To notify utility companies and council Contract, legitimate interest, legal obligation Electronically Reference agency, payment gateway processor, deposit scheme,  identity check agency Successful applicants 10 years after the tenant leaves. Failed applicants 1 year
Contact Accommodation.co.uk and landlords Online To create Tenancy Agreement. To reference the applicant. To contact the tenant for property management. To operate the business lawfully and efficiently. To use for deposit scheme Prescribed Information. To use in legal proceedings (for possession/arrears). To notify utility companies and council Contract, legitimate interest, legal obligation Electronically Deposit scheme,  payment gateway processor, identity check agency Successful applicants 10 years after the tenant leaves. Failed applicants 1 year
Financial Accommodation.co.uk Online To set up rent payments Contact, legitimate interest Electronically Payment gateway processor 1 year
Transaction Reference agency Online To reference applicant Contract, legitimate interest Electronically Reference agency 1 year
Technical Accommodation.co.uk Online To provide better customer experience Legitimate interest Electronically 1 year
Profile Accommodation.co.uk Online To provide better customer experience Contract, legitimate interest Electronically 1 year
Usage Accommodation.co.uk Online To provide better customer experience Legitimate interest Electronically 1 year
Marketing Accommodation.co.uk Online, telephone, email To provide requested services Contract, legitimate interest Electronically 1 year

11. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have therefore established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company or third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or any other transactions between us.

11.1 COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see https://accommodation.co.uk/privacy/cookies

11.2 CHANGE OF PURPOSE  
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.

12. INTERNATIONAL TRANSFERS  
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

13. DATA SECURITY
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.

14. GENERAL
14.1 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18/06/19, previous versions can be obtained by contacting us.
We may change this privacy policy from time to time. If so, we will notify you by website update.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

14.2 THIRD-PARTY LINKS
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

14.3 NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

14.4 WHAT WE MAY NEED FROM YOU
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.

14.5 TIME LIMIT TO RESPOND
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

14.6 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

GUARANTOR PRIVACY POLICY

INTRODUCTION
www.accommodation.co.uk is a Website operated by Accommodation Lettings Ltd (”We”). We are registered in England and Wales under company number 11423942 and have our registered office at We Work, No1 Spinningfields, Quay Street, Manchester, M3 3JE
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we collect, process and look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you.
We will firstly summarise the purpose of this policy, provide you with our full contact details and your rights in respect of the personal data we hold about you. We then deal with (i) what data we collect from you; (ii) how it is collected; (iii) how long we retain the data; (iv) how we use the data; and (v) what third parties we may disclose your data to. We will then summarise this in a table in section 10, Data Summary below. Finally, we provide further information in sections 11 to 15 other aspects of our use of your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to be provided services by us or in any other way provide us with personal information through this Website.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.
This policy should be read in conjunction with the following policies which also apply to your use of our Website:

  • Our Terms of Use www.accommodation.co.uk/terms/terms-of-use
  • Our Terms and Conditions in respect of the Services we provide to you (if you are a landlord); and
  • Our Cookie Policy https://accommodation.co.uk/privacy/cookies

 1.2 CONTROLLER
We are the controller and are responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the named individual using the details set out below.

1.3 CONTACT DETAILS
Our full details are: 

Company name: Accommodation Lettings Ltd
Company number: 11423942
Registered office: WeWork, No1 Spinningfields, Quay Street, Manchester, M3 3JE
ICO registration number ZA468080
Contact name: John Lomas
Email address: DPO@accomodation.co.uk
Telephone number: 0203 868 4944

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

3.0 THE DATA WE COLLECT AND HOLD ABOUT YOU
3.1 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, e-signature and reference data from previous landlords.
  • Contact Data includes billing address, residential address (including bedroom number if a house in multiple occupation), rental property address (including all applied for properties and any properties actually rented by the data subject), delivery address, email address (including personal email address, student email address and work email address) and telephone numbers (including mobile, residential and work phone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 data but is not considered personal data 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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 have summarised the personal data we collect from you in section 10 below.

4. HOW IS YOUR PERSONAL DATA COLLECTED AND WHO IS COLLECTING IT?
We use different methods to collect data from and about you including through:

  • Direct interactions. We may collect your Identity, Contact, Financial Transaction, Profile and Marketing and Communications Data directly from you when you fill in forms or by corresponding with us by post, phone, email, directly through the functionality of the Website or otherwise.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://accommodation.co.uk/privacy/cookies

We have summarised the personal data we collect from your and who is collecting it in section 10 below.

5. WHY WE COLLECT YOUR DATA
There are a number of reasons why we may collect your data, we have listed some below (this is not an exhaustive list);

  • To create Tenancy Agreement;
  • To reference the applicant;
  • To contact the tenant for property management;
  • To operate the business lawfully and efficiently;
  • To use for deposit scheme Prescribed Information;
  • To use in legal proceedings (for possession/arrears); and
  • To notify utility companies and council.

The specific reason we collect different personal data from you is detailed in the summary in section 10 below.

6. LAWFUL BASIS FOR PROCESSING AND USE OF YOUR DATA
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:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 have summarised the lawful basis on which we process the specific personal data we collect from you in section 10 below.

7. HOW IS YOUR DATA STORED
Most of the personal data we collect from you will be stored electronically on our secure systems. The specific way we store data is specified in the table in section 10 below.

8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the external third parties set out below to enable us to use your personal data in line with our lawful basis for processing your personal data;

  • Landlord and tenant referencing companies, for example Movem, Northrow;
  • CRM system provider, for example HubSpot;
  • E-signature platform, for example Eversign;
  • Key management solution provider, for example Key Nest;
  • Deposit protection scheme provider, for example MyDeposits;
  • Customer support provider, for example ZenDesk;
  • Payment system provider, for example Cardstream;
  • Property portals, for example Rightmove, Zoopla & Spareroom; and
  • Location finder, for example GetAddress.io & Google API.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based UK who provide consultancy, banking, legal, insurance and accounting services.
  • Utility companies (gas, electric, internet providers etc);
  • Local council;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In certain circumstances these third parties may become Data Controllers under the Data Protection Act 2018 and in those circumstances those third parties will contact you regarding their use of your personal data.
We have summarised the third parties to which we disclose the personal data we collect from you in section 10 below.

9. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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 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 requirements.
In some circumstances we may 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.
We have summarised the period we retain the specific personal data we collect from you in section 10 below.

10. DATA SUMMARY
In this section we summarise how the information given in sections 3 to 8 above are used. We use the terms highlighted in bold in those sections in the summary table below and so please cross reference with the relevant section above if necessary. The section that some column references to is given in the table headings.

Data Held Who is collecting How collected Why collected Lawful basis for processing How is data stored Who is data share with Disposal data
Identity Accommodation.co.uk and tenant applicant Online To reference guarantor. To contact guarantor. To use on guarantee. To use in deposit scheme Prescribed Information if guarantor pays deposit. To use in legal proceedings (for possession/arrears) Contract, legitimate interest. Legal obligation for deposit scheme Electronically Reference agency 1 year
Contact Accommodation.co.uk and tenant applicant Online To reference guarantor. To contact guarantor. To use on guarantee. To use in deposit scheme Prescribed Information if guarantor pays deposit. To use in legal proceedings (for possession/arrears) Contract, legitimate interest. Legal obligation for deposit scheme Electronically Reference agency 1 year
Transaction Reference agency Online to reference applicant Contact, legitimate interest Electronically 1 year

11. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have therefore established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company or third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or any other transactions between us.

11.1 COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see https://accommodation.co.uk/privacy/cookies

11.2 CHANGE OF PURPOSE  
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.

12. INTERNATIONAL TRANSFERS  
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

13. DATA SECURITY
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.

14. GENERAL

14.1 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18/06/19, previous versions can be obtained by contacting us.
We may change this privacy policy from time to time. If so, we will notify you by website update.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

14.2 THIRD-PARTY LINKS
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

14.3 NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

14.4 WHAT WE MAY NEED FROM YOU
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.

14.5 TIME LIMIT TO RESPOND
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.

14.6 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

LANDLORD PRIVACY POLICY

INTRODUCTION
www.accommodation.co.uk is a Website operated by Accommodation Lettings Ltd (”We”). We are registered in England and Wales under company number 11423942 and have our registered office at We Work, No1 Spinningfields, Quay Street, Manchester, M3 3JE
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we collect, process and look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you.
We will firstly summarise the purpose of this policy, provide you with our full contact details and your rights in respect of the personal data we hold about you. We then deal with (i) what data we collect from you; (ii) how it is collected; (iii) how long we retain the data; (iv) how we use the data; and (v) what third parties we may disclose your data to. We will then summarise this in a table in section 10, Data Summary below. Finally, we provide further information in sections 11 to 15 other aspects of our use of your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to be provided services by us or in any other way provide us with personal information through this Website.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.
This policy should be read in conjunction with the following policies which also apply to your use of our Website:

  • Our Terms of Use www.accommodation.co.uk/terms/terms-of-use
  • Our Terms and Conditions in respect of the Services we provide to you (if you are a landlord); and
  • Our Cookie Policy https://accommodation.co.uk/privacy/cookies

1.2 CONTROLLER
We are the controller and are responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the named individual using the details set out below.

1.3 CONTACT DETAILS
Our full details are:

Company name: Accommodation Lettings Ltd
Company number: 11423942
Registered office: WeWork, No1 Spinningfields, Quay Street, Manchester, M3 3JE
ICO registration number ZA468080
Contact name: John Lomas
Email address: DPO@accomodation.co.uk
Telephone number: 0203 868 4944

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

3.0 THE DATA WE COLLECT AND HOLD ABOUT YOU
3.1 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, e-signature and reference data from previous landlords.
  • Contact Data includes billing address, residential address (including bedroom number if a house in multiple occupation), rental property address (including all applied for properties and any properties actually rented by the data subject), delivery address, email address (including personal email address, student email address and work email address) and telephone numbers (including mobile, residential and work phone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 data but is not considered personal data 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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 have summarised the personal data we collect from you in section 10 below.

4. HOW IS YOUR PERSONAL DATA COLLECTED AND WHO IS COLLECTING IT?
We use different methods to collect data from and about you including through:

  • Direct interactions. We may collect your Identity, Contact, Financial Transaction, Profile and Marketing and Communications Data directly from you when you fill in forms or by corresponding with us by post, phone, email, directly through the functionality of the Website or otherwise.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://accommodation.co.uk/privacy/cookies

We have summarised the personal data we collect from your and who is collecting it in section 10 below.

5. WHY WE COLLECT YOUR DATA
There are a number of reasons why we may collect your data, we have listed some below (this is not an exhaustive list);

  • To create Tenancy Agreement;
  • To reference the applicant;
  • To contact the tenant for property management;
  • To operate the business lawfully and efficiently;
  • To use for deposit scheme Prescribed Information;
  • To use in legal proceedings (for possession/arrears); and
  • To notify utility companies and council.

The specific reason we collect different personal data from you is detailed in the summary in section 10 below

6. LAWFUL BASIS FOR PROCESSING AND USE OF YOUR DATA
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:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 have summarised the lawful basis on which we process the specific personal data we collect from you in section 10 below.

7. HOW IS YOUR DATA STORED
Most of the personal data we collect from you will be stored electronically on our secure systems. The specific way we store data is specified in the table in section 10 below.

8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the external third parties set out below to enable us to use your personal data in line with our lawful basis for processing your personal data;

  • Landlord and tenant referencing companies, for example Movem, Northrow;
  • CRM system provider, for example HubSpot;
  • E-signature platform, for example Eversign;
  • Key management solution provider, for example Key Nest;
  • Deposit protection scheme provider, for example MyDeposits;
  • Customer support provider, for example ZenDesk;
  • Payment system provider, for example Cardstream;
  • Property portals, for example Rightmove, Zoopla & Spareroom; and
  • Location finder, for example GetAddress.io & Google API.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based UK who provide consultancy, banking, legal, insurance and accounting services.
  • Utility companies (gas, electric, internet providers etc);
  • Local council;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In certain circumstances these third parties may become Data Controllers under the Data Protection Act 2018 and in those circumstances those third parties will contact you regarding their use of your personal data.
We have summarised the third parties to which we disclose the personal data we collect from you in section 10 below.

9. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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 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 requirements.
In some circumstances we may 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.
We have summarised the period we retain the specific personal data we collect from you in section 10 below.

10. DATA SUMMARY
In this section we summarise how the information given in sections 3 to 8 above are used. We use the terms highlighted in bold in those sections in the summary table below and so please cross reference with the relevant section above if necessary. The section that some column references to is given in the table headings

Data Held Who is collecting How collected Why collected Lawful basis for processing How is data stored Who is data share with Disposal data
Identity Accommodation.co.uk Online, telephone, email To arrange valuation and consultation. To fulfil the terms of business. To complete Prescribed Information Contract, legal obligation, legitimate interest Electronically Payment gateway processor, deposit scheme,  identity check agency 10 years
Contact Accommodation.co.uk Online, telephone, email To arrange valuation and consultation. To fulfil the terms of business. To complete Prescribed Information Contract, legal obligation, legitimate interest Electronically Deposit scheme 10 years
Transaction Accommodation.co.uk and payment gateway processor API Contract fulfilment Contract Electronically 10 years
Financial Accommodation.co.uk Online Contract fulfilment Contract Electronically 10 years

11. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have therefore established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any other company or third party for marketing purposes

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or any other transactions between us.

 11.1 COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see https://accommodation.co.uk/privacy/cookies

11.2 CHANGE OF PURPOSE  
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.

12. INTERNATIONAL TRANSFERS  
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

13. DATA SECURITY
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.

14. GENERAL

14.1 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18/06/19, previous versions can be obtained by contacting us.
We may change this privacy policy from time to time. If so, we will notify you by website update.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

14.2 THIRD-PARTY LINKS
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

14.3 NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

14.4 WHAT WE MAY NEED FROM YOU
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.

14.5 TIME LIMIT TO RESPOND
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.

14.6 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

PREVIOUS LANDLORD PRIVACY POLICY

INTRODUCTION  

www.accommodation.co.uk is a Website operated by Accommodation Lettings Ltd (”We”). We are registered in England and Wales under company number 11423942 and have our registered office at We Work, No1 Spinningfields, Quay Street, Manchester, M3 3JE
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we collect, process and look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you.
We will firstly summarise the purpose of this policy, provide you with our full contact details and your rights in respect of the personal data we hold about you. We then deal with (i) what data we collect from you; (ii) how it is collected; (iii) how long we retain the data; (iv) how we use the data; and (v) what third parties we may disclose your data to. We will then summarise this in a table in section 10, Data Summary below. Finally, we provide further information in sections 11 to 15 other aspects of our use of your personal data.

1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to be provided services by us or in any other way provide us with personal information through this Website.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.
This policy should be read in conjunction with the following policies which also apply to your use of our Website:

  • Our Terms of Use www.accommodation.co.uk/terms/terms-of-use
  • Our Terms and Conditions in respect of the Services we provide to you (if you are a landlord); and
  • Our Cookie Policy https://accommodation.co.uk/privacy/cookies

1.2 CONTROLLER
We are the controller and are responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the named individual using the details set out below.

1.3 CONTACT DETAILS
Our full details are:

Company name: Accommodation Lettings Ltd
Company number: 11423942
Registered office: WeWork, No1 Spinningfields, Quay Street, Manchester, M3 3JE
ICO registration number ZA468080
Contact name: John Lomas
Email address: DPO@accomodation.co.uk
Telephone number: 0203 868 3944

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.  

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

3.0 THE DATA WE COLLECT AND HOLD ABOUT YOU
3.1 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, e-signature and reference data from previous landlords.
  • Contact Data includes billing address, residential address (including bedroom number if a house in multiple occupation), rental property address (including all applied for properties and any properties actually rented by the data subject), delivery address, email address (including personal email address, student email address and work email address) and telephone numbers (including mobile, residential and work phone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 data but is not considered personal data 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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 have summarised the personal data we collect from you in section 10 below.

4. HOW IS YOUR PERSONAL DATA COLLECTED AND WHO IS COLLECTING IT?
We use different methods to collect data from and about you including through:

  • Direct interactions. We may collect your Identity, Contact, Financial Transaction, Profile and Marketing and Communications Data directly from you when you fill in forms or by corresponding with us by post, phone, email, directly through the functionality of the Website or otherwise.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://accommodation.co.uk/privacy/cookies

We have summarised the personal data we collect from your and who is collecting it in section 10 below.

5. WHY WE COLLECT YOUR DATA
There are a number of reasons why we may collect your data, we have listed some below (this is not an exhaustive list);

  • To create Tenancy Agreement;
  • To reference the applicant;
  • To contact the tenant for property management;
  • To operate the business lawfully and efficiently;
  • To use for deposit scheme Prescribed Information;
  • To use in legal proceedings (for possession/arrears); and
  • To notify utility companies and council.

The specific reason we collect different personal data from you is detailed in the summary in section 10 below

6. LAWFUL BASIS FOR PROCESSING AND USE OF YOUR DATA
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:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 have summarised the lawful basis on which we process the specific personal data we collect from you in section 10 below.

7. HOW IS YOUR DATA STORED
Most of the personal data we collect from you will be stored electronically on our secure systems. The specific way we store data is specified in the table in section 10 below.

8. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the external third parties set out below to enable us to use your personal data in line with our lawful basis for processing your personal data;

  • Landlord and tenant referencing companies, for example Movem, Northrow;
  • CRM system provider, for example HubSpot;
  • E-signature platform, for example Eversign;
  • Key management solution provider, for example Key Nest;
  • Deposit protection scheme provider, for example MyDeposits;
  • Customer support provider, for example ZenDesk;
  • Payment system provider, for example Cardstream;
  • Property portals, for example Rightmove, Zoopla & Spareroom; and
  • Location finder, for example GetAddress.io & Google API.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based UK who provide consultancy, banking, legal, insurance and accounting services.
  • Utility companies (gas, electric, internet providers etc);
  • Local council;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In certain circumstances these third parties may become Data Controllers under the Data Protection Act 2018 and in those circumstances those third parties will contact you regarding their use of your personal data.
We have summarised the third parties to which we disclose the personal data we collect from you in section 10 below.

9. DATA RETENTION – HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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 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 requirements.
In some circumstances we may 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.
We have summarised the period we retain the specific personal data we collect from you in section 10 below.

10. DATA SUMMARY
In this section we summarise how the information given in sections 3 to 8 above are used. We use the terms highlighted in bold in those sections in the summary table below and so please cross reference with the relevant section above if necessary. The section that some column references to is given in the table headings.

Data Held Who is collecting How collected Why collected Lawful basis for processing How is data stored Who is data share with Disposal data
Identity Accommodation.co.uk Online, telephone, email To reference applicant Contract, legitimate interest Electronically Successful applicants 10 years after the tenant leaves. Failed applicants 1 year
Contact Accommodation.co.uk Online To reference applicant Contract, legitimate interest Electronically Successful applicants 10 years after the tenant leaves. Failed applicants 1 year

11. MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have therefore established the following personal data control mechanisms:

Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any other company or third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or any other transactions between us.

11.1 COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see https://accommodation.co.uk/practise/cookie-policy

11.2 CHANGE OF PURPOSE  
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.

12. INTERNATIONAL TRANSFERS  
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

13. DATA SECURITY
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.

14. GENERAL
14.1 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18/06/19, previous versions can be obtained by contacting us.
We may change this privacy policy from time to time. If so, we will notify you by website update.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

14.2 THIRD-PARTY LINKS
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

14.3 NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

14.4 WHAT WE MAY NEED FROM YOU
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. 

14.5 TIME LIMIT TO RESPOND
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.

14.6 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.