We are committed to ensuring that your privacy is protected and this Privacy
Policy governs our use of your personal
data. Please read this policy
carefully as it contains important information on who we are, what data we collect, how and why we
collect it, how we
use and share your personal
data and where we store it.
It is important that you read this privacy policy together with any other
privacy policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.
We are Find Home UK Limited, company number 10919136 trading as ‘Let UK Home’. This privacy policy is issued on behalf of the Find Home UK Limited.
Key terms used within this policy:
We, us, our
Find Home UK Limited trading as Let UK Home
Team responsible for data protection compliance
Find Home UK Limited, 71-75 Shelton Street, London, England, WC2H 9JQ
You or Your
Refers to anyone whose personal data we process
Personal data is any information that tells us something about you where you
are directly or indirectly identified or
identifiable as an individual. We
may collect and use the following personal data about you.
●
Identity Data includes first name, maiden name, last name, username or similar identifier,
marital status, title, date
of birth, your image
(be that photographic or video), nationality (purely for the purposes of complying with the
Immigration Act 2014) and
gender.
●
Contact Data includes residential address, property ownership information, relevant contact
addresses, email address and
telephone
numbers.
●
Financial Data includes bank account, payment card details and information to enable us to
undertake Anti Money
Laundering and
Terrorist Financing electronic checks on you.
●
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 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.
●
Call recordings includes recording all calls made and received externally.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data
could be derived from your
personal data but is not considered personal data in law as this data will 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.
This personal data is required to provide our services to you. If you do not
provide the personal data we ask for, it
may delay or prevent us from providing services to you.
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.
3. How do we collect personal data
We use different methods to collect data from and about you including through:
●
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding
with us by post,
phone, email or otherwise.
This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- contact us through social media;
- request marketing to be sent to you;
- walk-in to our branch offices;
- enter a competition;
- promotion or survey;
- give us some feedback;
- speak with us on the telephone and we record the call;
- make a complaint;
●
Automated technologies or interactions. As you interact with our website, we will
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.
We may also receive Technical Data about you if you visit other websites employing our
cookies. Please see our
cookie
policy for further details.
●
Third parties or publicly available sources. We may receive personal data about you from
various third parties
and
public sources as set
out below:
Data directly from a third party:
- sanctions screening providers;
- payment service providers;
- credit and tenant referencing agencies;
- government or police databases or registers;
- customer due diligence providers;
- property portals through which you request our services
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Google based outside the EU; and
- search information providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services who may be based
outside the EU.
Identity and Contact Data from data brokers or aggregators who may be based
outside the EU such as Rightmove, Zoopla
(based inside the EU) or
Facebook (based outside the EU).
Identity and Contact Data from publicly available sources such as social media
sites, including Facebook, YouTube and
LinkedIn (based outside the
EU), Companies House, HM Land Registry and the Electoral Register (based inside the EU).
4. How we use personal 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:
●
Where we need to perform the contract we are about to enter into or have entered into with
you.
●
Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights
do not override
those interests.
●
Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely
on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your
consent before sending third party
direct marketing communications to you via email or text message. You have the right to withdraw
consent to marketing at
any time by contacting
us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan
to use your personal data, and which of
the legal bases we rely on to
do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which
we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process
your personal data
where more than one ground
has been set out in the table below.
Purpose/Activity
Lawful basis for processing including basis of
legitimate interest
To register you as a new customer and provide services to you.
For the performance of our contract with you or to take steps at your
request before entering into a contract.
To prevent and detect fraud against you or us
For our legitimate interest or those of a third party, i.e. to minimise
fraud that could be damaging to you and us.
To manage our relationship with you which will include:
●
Updating and enhancing customer records
- Notifying you about changes to our terms or privacy policy
- Asking you to leave a review or take a survey
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use
our
products/services)
Conducting checks to identify our customer and verify their identity.
Screening for financial and other sanctions or
embargoes. Other processing necessary to comply with professional, legal and regulatory obligations
that apply
to our business, e.g. under health and safety regulation or rules issued by our
professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits,
enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and
internet use
For our legitimate interests or those of a third party, i.e. to make
sure we are following our own internal procedures so we can
deliver the best service to you
Statistical analysis to help us manage our business, e.g. in relation to our
financial performance, customer base, range of services or other efficiency
measures
For our legitimate interests or those of a third party, i.e. to be as
efficient as we can so we can deliver the best service for you
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations. For our
legitimate interests or those of a third party, e.g. to make sure we
are following our own internal procedures and working efficiently so we can deliver the best
service to you
To record telephone calls both incoming and outgoing
Performance of a contract with you
Necessary for our legitimate interests (to train staff and maintain
high levels of services)
To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system
maintenance, support, reporting and
hosting of data)
Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or
group restructuring exercise)
Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey
Performance of a contract with you
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them and grow our business)
To deliver relevant website content and advertisements to you and measure
or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business and to inform our marketing
strategy)
To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our
products and services, to keep our website
updated
and relevant, to develop our business and to inform our marketing strategy)
Marketing our services to:
— existing and former customers;
— third parties who have previously registered with us or expressed an interest in our services;
— third parties with whom we have had no previous dealings
Necessary for our legitimate interests (to develop our products/-
services and grow our business)
We will hold your personal data on our client management systems and use this
to provide you with marketing information
about similar services
offered by us to those which you have engaged us to provide which we feel you might find useful from
time to time. You
have the opportunity to opt
out of receiving this information at any time.
5. Who we share your personal data with
We only allow our service providers to handle your personal information if we
are satisfied they take appropriate
measures to protect your personal
information. We also impose contractual obligations on service providers (where possible) to ensure
they can only use
your personal information to
provide services to us and to you. These will include but will not be limited to:
●
If we sell any part of our business and/or integrate it with another organisation, your
details may be disclosed to our
advisers and to
prospective purchasers or joint venture partners and their adviser. If this occurs, the new
owners of the business will
only be permitted
to use your information in the same or similar way as set out in the privacy policy.
●
We will share personal data with our regulators, governmental or quasi-governmental
organisations, law enforcement
authorities and
with courts, tribunals and arbitrators as may be required from time to time in order to
comply with our regulatory and
legal obligations.
●
We may share a anonymised version of your personal data to third parties such as Facebook
and google to enable these
third parties
to display Let UK Home ads when you visit their websites.
●
We may share your personal information with any person working within the Find Home UK Limited on a need
to know
basis to ensure we are able to perform our obligations to you.
●
We routinely share personal data with:
- Third parties we use to help deliver our services to you, e.g. payment service providers,
referencing companies,
electronic AML due
diligence providers, utility concierge services, maintenance contractor, inventory companies
etc.;
- Other third parties we use to help us run our business, e.g. website suppliers, online
tenancy progression platforms,
case management system providers etc.;
- Third parties approved by you, e.g. social media sites you choose to link your account to
or third party payment
providers;
- Credit reference agencies;
- Our banks.
We will get your express opt-in consent before we share your personal data with
any third party for marketing purposes.
We do not disclose information about identifiable individuals to our
advertisers, but we may provide them with aggregate
information about our
users (for example, we may inform then that 500 men aged under 30 have clicked on their
advertisement on any given day).
We may also use aggregate information to help advertisers reach the kind of audience they want to
target (for example,
women in SW1). We may make use of the personal
data we have collected from you to enable us to comply with our advertiser’s wishes by displaying
their advertisement to
that target audience. Analytics and search engine providers that assist us in the improvement and
optimisation of our
site. Credit reference agencies for the purpose of assessing your credit score where this is a
condition of us entering
into a contract with you or for the purposes of completing an anti-money laundering
identity check, in accordance with our legal obligations.
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.
We use online advertising to keep you aware of what we’re up to and to help you
find our products. Like many companies,
we may target Let UK Home banners and ads to you when you use other websites and apps, based on
your Contact,
Technical, Usage and Profile Data. We do this using a
variety of digital marketing networks and ad exchanges, and a range of advertising technologies such
as web beacons,
pixels, ad tags, cookies, and
mobile identifiers, as well as specific services offered by some sites and social networks, such as
Facebook’s Custom
Audience Service.
Our use of analytics and targeted advertising tools
We use a range of analytics and targeted advertising tools to display relevant
website content on our website and online
advertisements on other
websites and apps (as described above) to you, deliver relevant content to you in marketing
communications (where
applicable), and to measure
the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to
analyse Google’s
interest-based advertising data
and/or third-party audience data (such as age, marital status, life event, gender and interests) to
target and improve
our marketing campaigns, marketing strategies and website content. We may also use tools provided
by other third
parties, such as Facebook to perform similar tasks, using your
Contact, Technical, Usage and Profile Data.
In order to opt out of targeted advertising you need to disable your ‘cookies’
in your browser settings or opt-out of
the relevant third-party Ad Settings. For example, you can opt-out of the Google Display
Advertising Features. As an
added privacy measure, you can also use the The Digital Advertising Alliance (which includes
companies such as Google
and Facebook), who provides a tool called WebChoices that can perform a quick scan of
your computer or mobile devices, find out which participating companies have enabled customised ads
for your browser,
and adjust your browser
preferences accordingly.
6. Where we keep your data
The security of your data is very important to us and we have measures in
place, which are designed to prevent
unauthorised access to your personal data including but not limited to:
●
Our client files are stored on our secure client management systems. Access is restricted on
our client systems to those
within the business who are required to have access to your information for legitimate
business purposes.
●
Hard copy documentation is stored in locked cabinets within our offices.
All data is hosted in datacentres which have systems and protections in place
to protect against both unauthorised
access, and other external factors
that could cause damage to, your personal data. There are strict access requirements in place and
access is restricted
to those absolutely necessary.
7. Overseas transfers of your personal data
We may transfer your personal data to an external third party which is based outside the 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. For further details, see
European Commission:
Adequacy of the protection
of personal data in non-EU countries .
Please contact us if you want further information on the specific mechanism
used by us when transferring your personal
data out of the EEA.
8. For how long we keep your data
We will not keep your personal data for longer than we need to, the period for
which we will keep your personal data
will depend on the type of service you have requested from us. The retention period may be longer
than the period for
which we are providing services to you where we have statutory or regulatory obligations to retain
personal data for a
longer period, or where we may need to retain information in case of legal claim.
In some circumstances we will anonymise your personal data (so that it can no
longer be associated with you) for
research or statistical purposes, in
which case we may use this information indefinitely without further notice to you.
9. Your rights in relation to your personal information
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please click
on the links below to find out
more about these rights:
●
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 your personal data. - 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 your personal data. - This enables you to ask us to
suspend the processing of your
personal data in
the following scenarios:
1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. 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.
4. You have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use
it.
●
Request transfer of your personal data. - 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.
●
Right to withdraw consent. - 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.
Please note that we will keep a record of the fact that you have made a request
to exercise your rights, and our
response to your request, in order to
demonstrate compliance with our data protection obligations and so that we can handle any queries,
complaints or claims
in relation to your
request. This record will be kept in accordance with our retention policies at section 8 above.
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 could refuse to comply with
your request in
these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it
could take us longer than a month if your
request is particularly complex or you have made a number of requests. In this case, we will notify
you and keep you
updated.
10. Complaints and contact details
If you have any complaints about the way we use your personal data please
contact the data protection officer at
info@letukhome.co.uk who will
try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the
Information Commissioner
Office (ICO). If you need more
information about how to contact the ICO please let us know.
If you have any questions, comments or requests regarding any aspect of this
Privacy Policy, please do not hesitate to
contact us by sending an email
to info@letukhome.co.uk or writing to the Find Home UK Limited, 71-75 Shelton Street, London, England, WC2H 9JQ
11. Updates to this notice
From time to time we may need to make changes to this notice, for example, as
the result of changes to law,
technologies, or other developments.
We will provide you with the most up-to-date notice and you can check our website here to review the
previous version.
This notice was last updated February 2024