We take your privacy very seriously. This privacy notice will inform you as to how we look after your personal data when you use the Houso App, and when you correspond with us by telephone, email or otherwise. It tells you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Houso Limited collects and processes your personal data when you use the Houso App, and when you correspond with us by telephone, email or otherwise.
It is important that you read this privacy notice together with any other privacy 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 notice supplements the other notices and is not intended to override them.
Who we are
Houso Limited (“we”, “us”, “our”) is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. You will find our contact details at the end of this privacy notice (see below: “How to contact us”).
PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is any information relating to an identified or identifiable individual.
We collect, use, store and transfer different kinds of personal data about you, depending on our relationship with you. This may include:
- Full name;
- Date of birth/age;
- Email address
- Financial Status – cash, mortgage approved, mortgage pending, just browsing,
- Telephone numbers (mobile or landline)
- A unique identification number for you;
- Your property status – On or Off Market
- Information about the property you are selling e.g. address, photographs, videos, floor plans, EPC, property description, price, type, tenure, parking, key features, HomeVault document storag
- Information about the property you would like to buy, location, type, price, bedrooms,
- Legal documentation and other documentation that you volunteer about the property you currently own e.g. property information questionnaire, transfers, white goods appliance warranties
- Properties you add to your favourites list
- Viewing availability and appointments on properties, made or received;
- Messages sent between buyers and sellers
- Offers to buy properties made or received;
- Your photograph;
- Feedback/reports from other customers;
- Information that you volunteer to us when you correspond with us by telephone, email or otherwise.
The App stores a unique user token to the users device that is used by the server to authenticate/determine that the user is who they say they are.
The following require direct interaction/consent from you, the user:
- The App requests access to your camera/photo library on their device for adding a profile picture and adding property images/videos
- The App may request access to your current location when performing a search for property listings.
- The App may request access to your calendar in order to add viewing appointments
- The App may send your postcode to a third party (https://getaddress.io/) in order provide auto-complete address suggestions
- The App may send your full address to a Geocoding service (https://cloud.google.com/maps-platform/terms/?&sign=1) to get the latitude and longitude, enabling the app to perform location lookups based on distance/display the property on a map
- The App may send your personal details to the Land Registry to confirm property ownership
If you do not provide personal data
For individual customers or suppliers, where we need to collect personal data to enter into a contract with you and you fail to provide that data when requested, we may not be able to enter the contract with you. This data may include your name, address, email address and phone. For individual customers, if you thereafter do not provide the personal data we ask for which may include Name, Email address, contact number this may delay or prevent us from providing our products or services to you.
HOW YOUR PERSONAL DATA IS COLLECTED
Depending on the circumstances, we use different methods to collect personal data from and about you including:
- Directly from you. You may give us your personal data by corresponding with us by email, telephone or otherwise, or when you use the Houso App;
- Other sources. We may receive personal data about you from various sources as set out below
- Contact, financial and transaction data from providers of technical and payment and delivery services;
- From an employee or representative of the organisation for whom you work;
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we or a third party have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and our lawful basis for doing so.
|What we use your personal data for||Our lawful basis for processing data
|For individual customers with whom we have contracts – to provide our products and services to you
|Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you.
|For individual suppliers with whom we have contracts e.g. for corresponding with you about the products or services you offer, to obtain a price quote and to take steps under the contract with you
|Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you|
|For individuals who work for or represent our corporate suppliers (or prospective corporate suppliers) e.g. for corresponding with you about the products or services your organisation offers, to obtain a price quote and to manage the contract with the organisation you work for or represent
|Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues and to manage the contract with the organisation you work for or represent|
|To manage our relationship with you, or the organisation which you work for or represent, which will include (where appropriate) notifying you about changes to our terms of business or privacy notice or dealing with complaints
|Necessary to comply with our legal obligations
Necessary for our legitimate interests i.e. to manage our relationship with you or the organisation you work for or represent, and to analyse and improve the products or services we offer
|To prevent and detect fraud against you or us||Necessary for our legitimate interests or those of a third party i.e. to minimise fraud that could be damaging for us and for you
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
|Necessary to comply with our legal obligations|
|Ensuring business policies are adhered to e.g. policies covering data security
|Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures so we can deliver the best service to you or the organisation you work for or represent
|Operational reasons, such as improving efficiency, training and quality control
|Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price
|Ensuring the confidentiality of commercially sensitive information||Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party i.e. to protect commercially valuable information
|Statistical analysis to help us manage our business e.g. in relation to our financial performance, customer base or other efficiency measures
|Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price|
|Preventing unauthorised access and modifications to systems||Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to prevent and detect criminal activity that could be damaging for us and for you or the organisation you work for or represent
|Updating and maintaining customer and supplier records||Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to make sure we can keep in touch with our customers and other contacts
|External audits for the audit of our accounts
|Necessary to comply with our legal obligations|
|To make suggestions and recommendations to you about products or services that may be of interest to you or the organisation you work for or represent||Necessary for our legitimate interests e.g. to develop our products/services and grow our business
|To enforce or apply our App terms and conditions or any other agreements
|Necessary for our legitimate interests or those of a third party e.g. to enforce our legal rights and protect our business|
|To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|Necessary for our legitimate interests e.g. for running our business, provision of administration and IT services, network security and to prevent fraud
Necessary to comply with our legal obligations
|To use data analytics to improve our products/services, marketing, customer relationships and experiences||Necessary for our legitimate interests e.g. to define types of customers for our products and services, to develop our business and inform our marketing strategy|
|For security reasons (photographs)||Necessary for our legitimate interests or those of a third party e.g. to ensure potential sellers have a photograph of potential buyers attending viewings
Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please telephone, email or write to us (see below: “How to contact us”).
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Houso will be undertaking a substantial marketing campaign, launching in Salisbury but with the intention of moving it out nationwide. All of our referral partners will have the ability to advertise on our platform, as would any other interested party who wished to do so.
We may use your personal data to send you periodic communications by email, post and text about our products and services.
We have a legitimate interest in processing your personal data for marketing purposes. This means we do not usually need your consent to send you information about our products and services. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- emailing; email@example.com
- using the ‘unsubscribe’ link in our emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.
Third party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
Depending on the circumstances, we may share your personal data with:
- External service providers we use to help run our business e.g. email service provider, IT providers, banks and payment card providers; and
- Professional advisers including lawyers, bankers, insurers, auditors, technical consultants and experts;
- Solicitors acting for you on your sale or purchase;
- SendGrid (https://sendgrid.com/) to provide delivery of transactional emails
- OneSignal (https://onesignal.com/) to provide delivery/reporting of in-App notifications
- Google (https://developers.google.com/maps/documentation/geocoding/start) to geocode property locations
- GetAddress (https://getaddress.io/) to provide autocomplete address suggestions
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.
TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Some of organisations with whom we share your personal data are based outside the European Economic Area (EEA) (which comprises the countries in the European Union and Iceland, Liechtenstein and Norway) so their processing of your personal data will involve a transfer outside of the EEA.
These transfers are subject to special rules under European and UK data protection law.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to your data by ensuring one of the following (or one of the other grounds set out in data protection law) applies:
- your data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- the transfer is necessary for the performance of a contract between you and us;
- the transfer is necessary to establish, exercise or defend legal claims;
- there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of European Commission approved contractual terms); or
- you have provided explicit consent to the proposed transfer after being informed of any potential risks.
Please contact us (see below: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?
Data protection law gives you certain rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your data:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||In certain situations, the right to require us to delete your personal data|
|Restriction of processing||In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data|
|Data portability||In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation|
|To object||The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests|
We do not use personal data for automated decision making.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email or write to us (see below: “How to contact us”) and let us have enough information to identify you e.g. your full name and address and email address as well as what right you want to exercise and the personal data to which your request relates.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including;
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records of products registered by you; and
- to keep records required by law to comply with our legal obligations.
We will not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.
KEEPING YOUR PERSONAL DATA SECURE
We have put in place reasonable and appropriate security measures to endeavour to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Houso App; any transmission is at your own risk.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email or write to us (see below: “How to contact us”). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the UK’s supervisory authority, the Information Commissioner’s Office (ICO). Further information about how to make a complaint to the ICO can be found on the ICO website www.ico.org.uk.
The EU General Data Protection Regulation also gives you right to lodge a complaint with the supervisory authority in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred.
CHANGES TO THE PRIVACY NOTICE
This version was last updated in July 2019.
We may change this privacy notice from time to time and when we do so, we will inform you via email and in-app notifications. If any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable endeavours to notify you of the changes in advance by email or by alternative means.
CHANGES TO YOUR PERSONAL DATA
Please let us know if you change your name, address or any other personal detail (see below: “How to contact us”).
HOW TO CONTACT US
If you have any queries about this privacy notice or how we use your personal data, you can contact us by telephone, post or email as follows:
St Anne Street
Do you need extra help?
If you would like this notice in another format (for example large print) please contact us (see above: “How to contact us”).