Privacy policy

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Last updated: 28 January 2021

1. INTRODUCTION

  • This Privacy Notice ("Notice") sets out how Oh Goodlord Limited ("Goodlord", "we", "us", "our"), whose registered office is at Huguenot Place, Heneage Street E1 5LN, collects, shares and uses personal information about you and how you can exercise your privacy rights. This Notice applies to personal information that we process when you use any of our websites ("Websites") and/or our online platform and any services we provide through it ("Service").

2. UPDATES TO THIS PRIVACY NOTICE

  • We may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
  • You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

3. CONTACTING US

  • If you have any queries or concerns in relation to this Notice or the Service, please contact us using the following details:

4. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The personal information that we may collect about you broadly falls into the following categories:

Information you provide voluntarily.

  • You may be asked to provide voluntarily personal information about yourself when you use our Service. As a user of our Service (whether a tenant, landlord, estate agent, guarantor or referee), you create an account ("Account") with us. The personal information that you provide when setting up your Account may include your name, email address, postal address, bank account details, and telephone number. You may also provide us with your credit or debit card number, security code and expiry date, when using our Service. Furthermore, you may provide us with personal information in your correspondence with us and in the content you upload through the Service. If you register to hold an Account with us, you will also have a unique identifier and password which enables you to access your Account.
  • In your capacity as a tenant or guarantor you may also provide us information about your employment such as the name of your employer, your role and salary together with the name and contact details of your referees.
  • Alternatively, you may be an estate agent who is setting up Accounts on behalf of a landlord and/or tenant. If that is the case, you will ensure that you communicate this Notice to the landlord and/or tenant. You confirm that you have been authorised by the landlord and/or the tenant to provide their details to us via our Websites or Service. In your capacity as an estate agent you may also be asked to provide us personal information, including your name, email address, telephone number and name of your employer.
  • We will use the personal information you provide us: (1) to facilitate the contract between you and the relevant tenant /landlord and/or agent as appropriate; (2) to create your Account and provide you with our Service; (3) to process debit and credit card payments; (4) to verify your identity; (5) to prevent, detect and investigate potentially illegal activities; (6) to send you information about the Service; (7) to provide customer service in relation to your use of the Service, to contact you, to deal with enquiries and complaints relating to the use of the Service and to notify you of any changes to the Service; (8) to provide you with marketing communications by post and/or phone unless you have told us you do not want to receive such communications; and (9) to provide you with marketing communications via electronic means (such as email, SMS and/or MMS) about our products, services, events and offers, which you have requested to be sent or which we think may be of interest to you.

Information we collect automatically

  • When you visit our Websites, we may automatically collect information from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
  • Specifically, the information we collect automatically may include information like your IP address, log-in information, broad geographical location (e.g. country or city-level location), browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our Websites, download errors, length of visits to certain pages, page interaction, referral source and similar information. This information may be collected by a third party website analytics service provider on our behalf and may be collected using cookies. For more information on our use of cookies please refer to the ''Cookies and similar tracking technologies'' section below, please find our cookie notice here.
  • We use the information we collect automatically: (1) to administer our Website for internal operations including troubleshooting purposes; (2) as part of our effort to keep our Websites safe and secure; (3) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; (4) to develop, improve and personalise the Service so as to improve your experience; and (5) to provide third parties with anonymised statistical information about our users.

Information provided by third parties

  • Third parties who use our Service may provide us with your name and contact details in relation to their use of our Service. We will use such data to ask you to create an Account with us so that we can provide our Service to you and such third parties.

5. SHARING AND DISCLOSING YOUR PERSONAL INFORMATION

  • Other than as expressly set out in this Notice or as otherwise required or permitted by law, we will not share, sell or distribute any of your personal information without your consent.
  • We may disclose your personal information to the following categories of recipients:
    • to the relevant tenant, landlord and/or agent, as appropriate, who you contract with, you refer or you guarantee for via the Service;
    • third party providers of services you request via the Service such as insurance providers (for rent protection insurance and contents insurance services), utility providers (for utility switching services). These service providers shall act as a controller of your personal information and you should consult their privacy policies for details regarding how they will process your personal information;
    • where you are a tenant, to local authorities in relation to change of occupancy services provided on behalf of the agent responsible for the property you are renting;
    • third party service providers and partners who provide data processing services to us (including operating this Website and in relation to our Service, e.g. to verify your identity, to contact you on our behalf), or who otherwise process personal information on our behalf for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
    • our third party analytics partners to analyse Website traffic and understand customer needs and trends;
    • our third party advertising partners to advertise products to you on third party sites which are tailored to meet your preferences and likely interests;
    • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii ) to exercise, establish or defend our legal rights, (iii) to protect your vital interests or those of any other person; or (iv) as otherwise required or allowed under applicable law;
    • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of a business unit, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
    • to any other person with your consent to the disclosure.

  • Please refer to the table below for further details on who we disclose your information to:
Recipient Type Reason
Oh Goodlord Ltd Group Companies We may share your information with our affiliates and subsidiaries to enable you to benefit from services offered by them.
Original introducing parties If you have been indirectly introduced to the Goodlord platform, we may need to report back to the original introducer to provide them with an update on the outcome of your use of our service.
External suppliers Where specialist firms are employed by Goodlord to facilitate provision of our services, it may be necessary to share your personal information for example an email address in order to respond to your queries.
Insurance Partners Where insurance is purchased as part of a tenancy processed by us, it may be necessary to share information with our insurance partners in order to meet eligibility criteria and facilitate setting up of policies.
Property Management Software Partners We may share information with the property management software suppliers of lettings agents to enable integration between Goodlord and these platforms.
Utility Suppliers and Local Councils If we assist you with switching utilities or council tax, we will need to share your contact details and details about your new property to facilitate processing of applications or set-up of relevant accounts with utilities providers (including our preferred energy supplier, Scottish Power) and local councils.
Tenant Offer Providers If you enquire about/purchase additional services such as broadband, gadget rental, or removal services during your tenant journey, we will need to share your information with the relevant providers
Credit reference and Fraud Prevention agencies When providing our referencing service, we will need to approach credit reference agencies to gather information on your credit history in order to provide a referencing report.
Deposit Protection Schemes Where we facilitate registration of security deposits for tenancies, we may share your information required by Deposit Protection Schemes to do this.
Regulators and Ombudsman Services Sharing information with regulatory/law enforcement bodies and ombudsman services may be a requirement if requested and required to fulfil any legal obligation we have. This may include the ICO, FCA, and Financial Ombudsman Service.

6. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

  • Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
  • However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
  • If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
  • If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Service and communicating with you as necessary to provide our Service to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Service, or undertaking marketing. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
  • If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting us” heading above.
  • Please refer to the table below for further details on the legal basis of our processing activities:
Subjects Purpose or Activity Data Category Legal Basis Of Processing Our responsibility
Agents Customer Account Management
  • Identity data
  • Contact data
  • Financial data
  • Platform Activity data
  • Transaction data
Performance of a contract Controller
All users Analytics
  • Identity data
  • Contact data
  • Transaction data
  • Platform Activity data
  • Financial data
Performance of a contract Controller
Agents New business activities
  • Identity data
  • Contact data
  • Financial data
  • Platform Activity data
  • Transaction data
  • Marketing and Communications data
Performance of a contract Controller
All users Digital Marketing
  • Identity data
  • Contact data
Consent Controller
Tenants Providing Switching and Change of Occupancy Service
  • Identity data
  • Contact data
  • Financial data
  • Transaction data
Legitimate interests Controller
All users Providing tenancy referencing, insurance, tenancy services and other services
  • Identity data
  • Contact data
  • Financial data
  • Platform Activity data
  • Transaction data
Performance of a contract Controller
All users Internal Accounting
  • Identity data
  • Contact data
  • Financial data
  • Transaction data
Performance of a contract Controller
All users Facilitating completion of tenancy agreements
  • Identity data
  • Contact data
  • Technical data
  • Financial data
  • Transaction data
Performance of a contract Processor
All users Communicating with law enforcement and regulatory bodies
  • Identity data
  • Contact data
  • Platform Activity data
  • Financial data
  • Transaction data
Performance of a contract Controller

7. COOKIES AND SIMILAR TRACKING TECHNOLOGY

  • We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice here.

8. SECURITY

  • We employ appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
  • Data transmission over the internet is inherently insecure, and although we employ appropriate technical and organisational security measures to protect your personal information from unauthorised access we cannot guarantee the security of any personal information sent over the internet.
  • You are responsible for keeping your password and user details confidential. Nobody at Goodlord will ever ask you for your password, be careful not to share this with anyone.

9. DATA RETENTION

  • We will retain your personal information only for as long as is necessary to fulfil the purposes it was collected for (for example, to provide you with a service you have requested or to comply with applicable legal tax or accounting obligations).
  • When we no longer need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. INTERNATIONAL DATA TRANSFERS

  • Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
  • Our servers are situated in Dublin, Ireland; however we collect data from wherever users are situated. Our third party service providers operate in countries around the world, including US. This means that we may process the personal information we collect in any of these countries.
  • However, we have taken appropriate safeguards as required by law to ensure that your personal information will remain protected in accordance with this Privacy Notice.

11. YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact information provided under the ''Contacting us'' heading above. We may also require you to provide us with appropriate identification before we comply with this request. Note, however, that we may not always be able to comply with your request to delete personal information for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • In addition, in certain circumstances you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting us” heading above.
  • You have the right to opt-out of marketing communications we send you at any time by following any “unsubscribe” link included in the marketing emails which we send to you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contacting us” heading above.
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you withdraw your consent, we may not be able to provide certain services to you.
  • We will advise you if this is the case at the time you withdraw your consent.
  • Our team (privacy@goodlord.co) is on hand to address any queries and concerns you may have. If for some reason you are not satisfied with the way these have been handled, you have the right to complain to the Information Commissioner’s Office (www.ico.org.uk) about our collection and use of your personal information.
  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. THIRD-PARTY WEBSITES

  • Our Websites and Service may contain links to other websites belonging to or operated by third parties. By making these links available, we are not endorsing third-party websites, their content, products, services or the owners of these third-party websites. It is your responsibility to make sure that you obtain any information which may be relevant to making a decision, and that you read the privacy and security policy on such third-party websites.