Homeppl Privacy Policy

Verified, Respected, Secure.

Homeppl respects your right to privacy. Your ability to make an informed choice about the use of your information is very important to us.

Below, we have outlined the purposes for which we process your data, the data we receive from third parties and the background checks that we perform, as well other important information concerning you, including:

  • the different purposes for which we process your personal information;
  • our legal grounds for processing personal information;
  • which background checks we perform;
  • how we treat sensitive personal information;
  • the categories of personal information we receive from third parties about you;
  • who we transfer this personal information to and how they use it;
  • your rights in relation to automated decision making;
  • how we protect personal information;
  • how long we store personal information;
  • our use of cookies;
  • how we treat children's personal information;
  • your rights to view or transfer your personal information;
  • when we may change this Privacy Policy;
  • who to contact in case you have questions.

Please note that your use of our website is governed by our terms of use which you may find through the following link: www.homeppl.com

Definitions

Homeppl Ltd. ("Homeppl", or "us", "our", "we") provides an Internet Platform for creating and sharing profiles for the property rental market (the "Platform").

The Platform is used by individuals seeking rental units for their own use, ("Renters"), individuals seeking to guarantee Renters' rental payments, ("Guarantors") as well as individuals, landlords and their letting or estate agents that are using the Platform in order to review the profiles of Renters ("Landlords"). In this Privacy Policy, Renters, Gurantors, Landlords and their agents may be referred to together as "Users".

As used in this Privacy Policy, "Personal Information" means information that can be directly associated with a a specific person or entity including but not limited to an individual's name, address, telephone number, e-mail address, identity document, tenancy agreement, third party reference or evidence of personal finances.

Purposes of processing

To enable Users to share their verified data with future Landlords and their agents. Once Renters or Guarantors have created a Homeppl account, they will be able to share their verified data with Landlords and their agents the next time they apply to rent a property.

To provide rental referencing services to Landlords and their agents by verifying the Personal Information submitted by Users, and making an assessment regarding a Renter or Guarantor's suitability to rent or guarantee a property. Such services may be performed for Landlords and their agents to meet their legal obligations.

To enable Landlords and their agents to meet their legal obligations, for example to determine a User's right to rent in the UK or to perform due diligence to determine if a User poses a risk of money laundering.

To allow us to advertise and introduce Users to appropriate products, including residential, financial and insurance products, or other personalised offers, where we believe this would be relevant or helpful.

To allow Users to leave comments and reviews for other Users, as well as to verify the information submitted by other Users.

To provide, update, maintain and protect our services, websites and business which may include presenting site information effectively as well as test and improve our existing services. Please refer to our Terms of Use for further detail.

To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our services, our service offerings, and important service-related notices, such as secruity and fraud notices, as well as to conduct surveys. These communications are considered part of the services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications, news about Homeppl or to conduct surveys. Please contact us if you would like to stop receiving such emails.

To help diagnose problems with our servers, and to make the Platform more useful for you and for our other customers. Depending on the circumstances, examples of such data processing may include those that reasonably serve customer relations, compliance and other considerations, auditing, security and fraud prevention, preserving or defending Homeppl's legal rights, or other purposes consistent with the expectations of a reasonable person given the context of the collection.

To share Statistical Information with our partners. By analysing all information we receive, we may compile statistical information across a variety of Users ("Statistical Information"). Statistical Information helps understand trends and customer neeeds so that new services can be considered and so the Platform and associated services can be tailored to customer desires. We may share Statistical Information with our partners, pursuant to commercial terms that we determine in our sole discretion. In addition, we may provide any information to third parties, so long as we have removred any information that identified any specific individual or User, such as name, address or contact information.

Grounds for processing

We may process your Personal Information under the following grounds:

We may process Personal Information when a User requests to undertake processing in order to enter into a contract. For example, when a Renter enters a contract to rent a prorety with a Landlord or their Agent, the Landlord or Agent may request for Homeppl to complete the referencing. Where this is the case, your provision of data to Homeppl may be a contractual requirement as part of your application to rent a property, and not supplying such information may mean that you are not able to secure a property.

We may process your Personal Information where this is necessary for the purposes of the legitimate interests pursued by Homeppl or a User of Homeppl's Platform. For example if you are a User's previous Landlord or their agent and you have provided a rental reference for the User, we may process your personal information in order that the User may enter into a rental agreement. Not supplying such information may mean that a User is unable to secure their rental contract.

If you choose to create a Homeppl account without being required to do so in order to enter a rental agreement, we may process your data in order to fulfil the purposes for which you consented to supply this to us, or those outlined in the Purposes section above.

If you choose to receive tailored marketing communications, we may sometimes send emails about new product features, promotional communications, news about Homeppl or to conduct surveys. These communications may be tailored to your user profile. Please contact us if you would like to stop receiving such emails.

We may process Users' data in order to enable our clients to meet a legal obligation. For example, we may process your identity documetn to pre-determine whether you have the Right to Rent in the UK under the Immigration Act 2004. We may also perform background checks of publicly available information, including Sanctions, Politically Exposed Person, financial Crime and Anti-Money Laundering checks, in order that your Estate Agent may comply with the Money Laundering Regulations 2017.

We may process your Personal Information in order to provide, update, maintain and protect our online services, use of which is subject to our Terms of Use.

Personal Information received from Users

When you create an account with us, you will be required to provide Personal Information in order to use the Platform. We collect and store Personal Information that you may provide in the course of creating your profile, as well as when you make use of the Platform.

Such information may include Personal Information about yourself, including but not limited to details concerning your current and prior addresses, properties, and finances. The information we may request depends on the individual situation of each User and will typically include an identity document, proof of address and proof of income. Please refer to our FAQ section to determine which documents will be needed for your particular application.

In addition, we collect any information you provide when you contact us over their phone, by email or by other means.

You are not required by law to provide us with any such information, but by using the Platform and agreeing to the Term of Use you agree to provide us with such information.

If you provide us with Personal Information about others, or if others give us your Personal Information, we will use that information only for the specific reason that it was provided to us.

Background Checks

We may perform background checks to determine if you appear on any global sanctions lists, fraud lists, or other lists of adverse information. We use sources such as aggregators of published newspaper articles and government lists of adverse information, including criminal watchlists which includes databases that may reveal criminal convictions.

We may perform background checks with databases including Credit Reference Agencies to determine whether you have received any debt-related judgements, bankruptcy orders or have any other debt-related adverse information.

We may also verify the validity of your identity document or bank account number by cross-referencing such information with third party databases.

By using Homeppl’s services you agree to such checks and that we may share any adverse information with your Landlord, in order that they may assess your suitability to rent a property, as well as to comply with any legal obligations such as the Money Laundering Regulations 2017.

Sensitive Personal Information

We may receive certain kinds of sensitive Personal Information when we process your account. This may include, for example, the current state of your health, racial or ethnic origin, religious or other beliefs or trade union membership.

We will only process the above information in accordance with Data Protection Law and only for the specific purpose that the information has been provided to us for. By submitting such Personal Information you consent to our processing of such information.

We do not require you to submit such information and if you do so, this will not affect the outcome of your rental application.

Personal Information received from third parties in processing your application

When completing your application you will be asked to enter the contact details of your current or previous employers, accountants, landlords and housemates, as appropriate according to your individual profile. We will then contact such parties to confirm the information you have provided in your rental application.

For example, we will ask your employer or accountant to confirm your income, dates of employment and contract status in order to assess your ability to afford your desired property. We will also ask your Landlord or their agent to provide a reference regarding whether or not you were previously paid rent on time, maintained the property, and whether or not they would recommend you as a tenant.

In order to use the Platform, you may choose to log in through a social network or third party platform such as Facebook or LinkedIn. We will receive such Personal Information about you as is provided by such social network for the purposes of identity verification, to display your social media account profile photo on you referencing report, for the creation of metadata used in User analytics, and for the retrieval of employment and educational information. Please check the policies of such social network in order to understand what information we receive.

We will also receive information from third parties as described in the Background Checks section, above.

Information sent to third parties

When completing your application, we will contact the individuals whose contact details you provide on the form, and transfer limited personal information to them.

For example, we will contact your employer or accountant to confirm the income and employment details you provide on the form, as well as your full name and date of birth. We may ask such individuals to provide a document confirming your employment status such as an employment letter or your tax return. Where you have provided us with information regarding yourself we may also transfer such a document to your nominated third party for verification. For example, if you submit a tax return we may transfer this to your accountant for their verification, or we may ask your employer to provide a letter confirming your employment details with them.

Once we have received your name and address, we may share Personal Information with Credit Bureaus to perform searches including but not limited to bankruptcy, county court judgement, anti money laundering, passport verification and bank account verification checks. We may also check your name and date of birth against databases of publicly available information, for example published newspaper articles, international government sanctions and criminal or terrorist watchlists.

By giving us your personal data, you agree that we may use subcontractors, service providers and internet storage facilities, such as Amazon Web Services, that may be located in countries other than your own, and send them information we receive. The purpose of such foreign transfer will be to safely store your personal data.

We may also transfer your Personal Information abroad through external communication providers such as via secure email and chat communication services. We ensure that EEA standards of protection of personal data will apply to such subcontractors and service providers. The purpose of such transfer will be to communicate internally as well as with third parties and our clients.

By using the Homeppl Platform you agree that the documents you upload and all other Personal Information including references will be transferred to your letting agent and subsequently to the Landlord for the property you are applying to.

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behavior of any user suspected to have engaged in illegal behaviour.

We may transfer our databases containing information if we sell our business or part of it, and Users will be notified of this changed in advance, both by email and through our website.

If you provide us with Personal Information about others, or if others give us your Personal Information, we will use that information only for the specific reason that it was provided to us.

Use of information by third party sites and services

Your Personal Information may be transferred to Landlords and their agents in order that they may determine your suitability to rent a property.

We are not responsible for the use of any data by third parties, and we cannot vouch for the privacy policies of any third party. The Platform may link to or use web sites or services belonging to third parties. We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. We cannot accept responsibility for the privacy policies of any such sites. We are not responsible for content available by means of such sites or services. We do not endorse any services or offered by third parties and we urge our users to exercise caution in using third-party sites or services.

Automated decision making

We may perform automated decision making in order to reach a verdict regarding your rental application. Where this is the case, you may contest the outcome of such a decision and request Homeppl to use human intervention to review the decision.

How we protect information

We store your information in encrypted data storage facilities which are backed up in high-security data centres. However, no method of transmission over the Internet, or method of electronic storage is completely secure. Therefore, we cannot guarantee its absolute security.

How long we store information

Homeppl respects your legal right to erasure. We will not store your personal data for longer than is necessary for the purposes for which the Personal Data are processed, outlined in the Purposes section above.

Cookies

A cookie is a small piece of text that is sent to a visitor's browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. A “persistent” cookie may be used to help save your settings and customizations across visits. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Platform may not function properly when cookies are disabled or removed.

The Platform may also record certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring or exit pages, operating system, date and time stamp, page response times, download errors, length of visits to certain pages and page interaction information such as scrolling, clicks and mouse-overs. The purpose of collecting this subset of information is to improve the way our website works.

Children

We do not knowingly collect Personal Information from children under the age of 16. In the event you become aware that an individual under the age of 16 has enrolled without parental permission, please advise us immediately.

Requesting to view or transfer your Personal Information

Homeppl will provide you with information regarding the data we hold, as well as a copy of the information, following the receipt of a Subject Access Request. If you would like make such a request or if you have questions regarding the data we hold, please email us at support@homeppl.com with the phrase ‘Subject Access Request’ in the email subject line. If you would like to transfer your data to a third party organisation, or if you would like to amend or correct the Personal Information we hold about you, please email us with the phrase ‘Data Transfer Request’ in the email subject line. We will reply to all requests within one month.

Please note that we will require you to submit a utility bill or bank statement as a proof of address, as well as a national identity document before releasing any Personal Information. Homeppl reserves the right to charge a fee for multiple, excessive or unfounded requests.

Changes

We may update this Privacy Policy from time to time, and we encourage you to review it periodically. We will treat your continued use of the Services following such notice as you acceptance of the changes. However, to the extent required by law, we will seek your consent prior to applying material changes to this Privacy Policy.

Comments and questions

If you have any comments or questions about this Privacy Policy, please contact us by email at support@homeppl.com or by phone at: +44(0)2038720664.

For further information on the Data Protection Legislation or if your would like to make a complaint, please contact the Information Commissioner’s Office (www.ico.org.uk)

Last updated: May 2018