Privacy Policy
BACKGROUND:
Property118 Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website,
www.property118.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site
. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” |
means an account required to access and/or use certain areas and features of Our Site; |
“Cookie” |
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below; |
“Cookie Law” |
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
“personal data” |
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and |
“We/Us/Our” |
Means Property118 Ltd , a limited company registered in England under company number 10295964, whose registered address is 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB. |
- Information About Us
- Our Site is owned and operated by Property118 Ltd, a limited company registered in England under company number 10295964, whose registered address is 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB.
- Our VAT number is 990 0332 34.
- Our Data Protection Officer is Neil Patterson, and can be contacted by email at npatterson@property118.com, by telephone on 01603 489118, or by post at 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB.
- What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
- Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see section 13 on Our use of Cookies and similar technologies):
- Name;
- Date of birth;
- Address and post code;
- Business/company name and trading status;
- Number of properties owned;
- Accountants details;
- Contact information such as email addresses and telephone numbers;
- Proof of residence and ID;
- Financial information such as income and tax status;
- Landlords insurance renewal dates;
- Property Portfolio details such as value and mortgage outstanding;
- How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- Providing and managing your access to Our Site;
- Supplying our products and or services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring our products and or services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by the unsubscribe link at the bottom of all emails;
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
- Provide information to our partner service and product suppliers at your request.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and or telephone with information, news and offers on our products and or We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Member profile information is collected with your consent and can be amended or deleted at any time by you;
- Anti-Money Laundering information and tax consultancy records are to be kept as required by law for up to seven years.
- How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to Us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Do We Share Your Data?
- We may share your data with other partner companies in for the purpose of supplying products or services you have requested.
- We may sometimes contract with third parties to supply products and services to you on Our behalf. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
- What Happens If Our Business Changes Hands?
- We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
- How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, we aim to give you strong controls on Our use of your data for direct marketing purposes including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.
- Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- You may restrict Our use of Cookies. For more information, see section 13.
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at info@property118.com, or using the contact details below in section 14.
- Our Use of Cookies
- Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- Before Cookies are placed on your computer or device, you will be shown a cookie prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
- Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
- The following first party Cookies may be placed on your computer or device:
Name of Cookie |
Purpose |
Strictly Necessary |
JSESSIONID |
Used only to collect performance data, with any identifiable data obfuscated |
No |
__cfduid |
This cookie is strictly necessary for Cloudflare's security features and cannot be turned off. |
Yes |
- Our Site uses analytics services provided by Google Analytics and Facebook. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products AND/OR services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
- The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
- The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie |
First / Third Party |
Provider |
Purpose |
__utma, __utmb, __utmc, __utmt, __utmz |
First |
Google |
Helps to understand how their visitors engage with our website |
_fbp |
First |
Facebook |
Helps to understand how their visitors engage with our website |
- In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
- You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@property118.com, by telephone on 01603 489118, or by post at 1st Floor, Woburn House, 84 St Benedicts Street, Norwich, NR2 4AB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
- Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
Neil Patterson
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Sign Up11:33 AM, 23rd April 2018, About 7 years ago
Hi Robert,
I agree we keep going round in circles on this. My gut feeling is it is not the intention for all small landlords to register with the ICO, but I can't seem to find conclusive evidence.
See our last article on the same subject - Do we landlords have to register with the Information Commissioner’s Office >> https://www.property118.com/landlords-register-information-commissioners-office/
"An email used and stored is electronic processing if it contains Data that can identify an individual.
"What are the exemptions from notification?
Most organisations that process personal data must notify the ICO of certain details about that processing. However, the Act provides exemptions from notification for:
organisations that process personal data only for:
staff administration (including payroll);
advertising, marketing and public relations (in connection with their own business activity); and
accounts and records;
some not-for-profit organisations;
organisations that process personal data only for maintaining a public register;
organisations that do not process personal information on computer.
Organisations and individuals can use our online self-assessment tool to check whether they need to register with (“notify”) the ICO."
The online checking tool would insinuate if you go through it for many landlords that they do not need to register
Chris Clare
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Sign Up13:43 PM, 23rd April 2018, About 7 years ago
I have just done the self assessment and tried to answer the questions in a manner that could have meant I did not need to register, they are as follows:
1. Do you use CCTV for the purposes of crime prevention?
No
2. Are you processing personal information?
Yes
3. Do you process the information electronically?
Yes
4. Is your organisation responsible for deciding how the information is processed?
Yes
5. Do you only process information for one of the following purposes?
No
6. Are you a not-for-profit organisation that qualifies for an exemption?
No
7. Are you processing information for any of the following purposes?
Property management - including the selling and/ or letting of property
Yes
You need to register
I did notice that canvassing for political parties was on the exemption list.
I would expect a LL who self manages property needs to register. If they have an agent and never deal with the tenants data then they would not need to register.
If a LL does references and/or credit checks and even if they supply references on past tenants then they do need to register as all that data comes from somewhere.
I deal with many companies and more over the last 3 months, they are getting very concerned about being ready for the 35th of May but they are working towards it.
The fact is registration is a negligible cost and one that makes you look yet more professional. (which is needed in these times of S24 and trying to demonstrate we are professionals).
Getting compliant is also relatively simple if you follow the excellent guidance on the ICO's website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
Don't forget the majority of what a LL does in relation to data is classed as "Legal Obligation" or "Contract" very rarely would a landlord rely on the "Consent" class, hence my reasoning behind saying it will be relatively easy to comply.
Mick Roberts
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Sign Up14:33 PM, 23rd April 2018, About 7 years ago
Country is going more nuts on data protection
Universal Credit and DWP won't talk to us as it is. When they do talk to us, us Landlords solve claims.
After this comes in, less claims solved equals more homelessness.
I han't had a problem in 20 years. Why do I need to register for something where there is no problem?
Oh I see, let's bring in more red tape and bureaucracy to make small businesses and Ooh hang on it's a Landlord. YES YES YES. WE don't like Landlords Ooh they must register.
Even less houses for the vulnerable soon.
Chris Clare
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Sign Up14:36 PM, 23rd April 2018, About 7 years ago
Reply to the comment left by Mick Roberts at 23/04/2018 - 14:33
This is a blanket approach to a whole country not just LL's.
Whilst it feels like a personal attack, it is not trust me this applies to everyone. LL's make up a really small percentage of the people swept up and equally irritated by this regulation.
Robert M
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Sign Up16:34 PM, 23rd April 2018, About 7 years ago
I can see that the GDPR is well intentioned, it is meant to help stop the abuse of data, but it is clearly designed for (and worded for) very large companies/organisations, and when applied at the micro business level it becomes unworkable. For example, if I ask my handyman to ring tenant A and arrange access to put up a new curtain rail, I would be passing on personal data to the handyman (tenant name, address, and phone number), so the handyman has to be GDPR compliant, but they just want to go and put up the curtain rail and get paid for their time and effort. Can the handyman really be expected to document and record what they do with every bit of data, record how it is processed and stored, how long they keep it for, how they destroy the data, how they ensure that the data subject has seen their privacy notice, what policies they have for handling the data, carrying out a regular data audit, etc, etc, etc.?
Mick Roberts
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Sign Up17:19 PM, 23rd April 2018, About 7 years ago
Reply to the comment left by Robert Mellors at 23/04/2018 - 16:34
Yeah that's what I heard Rob. How far do we go! It's nuts. Tenant wants a job doing, they got to know and presume builder is gonna be having their name number address.
How else is society gonna function.
Prosecute me then. For what? Trying to get your roof fixed and builder ringing u?
I reckon some greedy tenant WILL try and sue Landlord with some unscrupulous solicitor. And hopefully sensible judge will make landmark case and say Hang on We've gone too far.
Chris Clare
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Sign Up9:05 AM, 24th April 2018, About 7 years ago
Reply to the comment left by Mick Roberts at 23/04/2018 - 17:19This is why everyone needs to understand the legislation.
Most of the work a LL does falls under the "Contract" class of data processing. If the Data Subject has been appropriately informed, it allows for the LL to pass data to third parties in order for them to comply with their contractual obligations. Maintaining the property is a contract obligation on the part of the LL. As such any tenant looking to game the system will fall squarely on their arse before it even gets in front of a judge.
I cannot stress enough, that it is well worth reading the ICO website, all the information is there in an easy to digest format. I have had to learn it back to front for my day job but it really is not hard.
Chris Amis
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Sign Up22:28 PM, 24th April 2018, About 7 years ago
Reply to the comment left by Chris Clare at 24/04/2018 - 09:05
I get that I have a contractual right to pass on contact details to a plumber say, but does the plumber need to be registered etc.
I can see all this GDPR stuff becoming another hurdle to S.21 evictions.
Robert M
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Sign Up22:48 PM, 24th April 2018, About 7 years ago
Reply to the comment left by Chris Amis at 24/04/2018 - 22:28
I've tried reading some of the guidance on the ICO website and it is not easy to understand, there are examples of exemptions but the wording is open to interpretation and it is not always easy to understand how it applies to a given situation. For example, I run a "not-for-profit" housing association so I think I fall within an exemption and do not need to register, but my bookkeeper thinks I do need to register, and the RLA lady said all landlords would need to register, and two week before that a GDPR consultant said organisations do not need to register they just need to be compliant. - Four different interpretations of the same ICO "guidance"!!!!
In relation to the plumber, as they will be a "data controller" then I guess they do need to register unless they are in some way exempt, and even if they do not need to register, I believe that they still have to be GDPR compliant.
Chris Amis
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Sign Up22:52 PM, 24th April 2018, About 7 years ago
Reply to the comment left by Robert Mellors at 24/04/2018 - 22:48
I guess the answer in all cases is to tell the tenant to contact the tradesman.
The only thing more forgetful than a plumber is a tenant, I will have to keep chasing them to get the gas cert done 🙂