1. IMPORTANT INFORMATION AND WHO WE ARE
OFF THE PATCH LIMITED (OTP, we, our or us) is a company registered in England and Wales (company number 11680229) with registered office at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX.
When you use our service, you’ll be required to share information with us. We want to be upfront about the personal data we collect, how we use it, who we share it with and the choices we give you to control, access and update your personal data. For the purposes of data protection legislation, we are the data controller of your personal data. We are registered with the Information Commissions Office in the UK with reference number ZA483848.
• we keep the personal data we hold about you to a minimum;
• we use your personal data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our business;
• we delete your personal data when it is no longer necessary for the purposes for which it was obtained;
• generally, we do not give your information to third parties, but there are some exceptions as set out in clause 6;
• you have lots of privacy rights;
• we take our security obligations seriously; and
3. THE PERSONAL DATA WE COLLECT
Personal data means any information about an individual from which that individual can be identified.
Identity data: your first and last name, marital status, title, gender, date of birth and information relating to your right to rent in the United Kingdom, including passport information.
Contact data: your email address, current home address, phone number and your affiliation to the United Kingdom Armed Forces.
Employment data: details relating to your employment with the United Kingdom Armed Forces or other organisations operating in the Defence Industry including: a copy of your military ID card or employee ID card (as applicable); and your service number (if applicable).
Financial data: if you use our service as either a Landlord or Tenant, we require you to provide your bank and financial details including your name, address and financial data corresponding to your selected method of payment (e.g. a bank account number) in order to arrange payment or collection of rent (as applicable). If you are a Tenant, we will also need to you provide certain financial data in order for us to carry out credit and reference checks on your behalf. Financial data is stored securely, details of which are available upon request.
Profile data: includes your username and password, transactions made by you, any interests communicated to us to enable the personalisation of services and any feedback.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communications preferences.
4. HOW WE USE YOUR PERSONAL DATA
We must have a legal basis for processing your personal data. We consider that we have a legal basis where:
• you have given us consent to do so for the specific purposes which we have told you about;
• it is necessary for us to do so to enable us to provide you with the services that you have requested from us (e.g. to communicate with you about your property);
• to pursue our legitimate interests of providing our services and improving the services we offer and developing new service features;
• to comply with our legal obligations; or
• the law otherwise permits or requires it.
We have set out below a list of all the ways we may 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.
In some cases we may use more than one legal basis for processing your personal data; this will depend on the specific purpose for which we are using your personal data. Please contact us if you have any queries about the specific legal basis that we rely on for processing your personal data.
This section is to explain how we will ensure that you only receive communications that you wish to receive.
We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. A ‘legitimate interest’ is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
The personal data we have for you is made up of: what you tell us and the data we collect about you when you use our services; or data provided to us from third parties we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel or by contacting us at firstname.lastname@example.org. If you choose not to receive this information, we will be unable to keep you informed of new services and promotions that may interest you.
Whatever you choose, you'll still receive appointment/viewing confirmations and other important information, for example communications about your tenancy or property (if applicable).
As detailed in the table at section 4, we may send you communications such as those which relate to any service updates (e.g. appointment/viewing confirmations) or provide customer satisfaction surveys. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.
6. SHARING AND TRANSFERRING YOUR PERSONAL INFORMATION
• undertake tenant reference checks in order to verify your right and suitability to rent a property;
• undertake maintenance and repair work at the property that you are letting or any property that we manage on your behalf (as applicable);
• suppliers, and sub-contractors for the performance of any contract we enter into with them or you;
• agents we engage to perform functions on our behalf including sending customer communications, analysing data, providing marketing assistance, processing payments, etc;
• if you are a Landlord, we may share your information with HMRC if we are required to do by law;
• we may share your data with other regulatory bodies if we are required to do so by law or to help settle a dispute between a Landlord and a Tenant (for example, the Deposit Protection Scheme, Property Redress Scheme or Scottish Lettings Agency).
They have access to personal data needed to perform their functions, but may not use it for other purposes.
We also have to share information or data in order to:
• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable policies, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues; and
• protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.
If you would like further information about who we share your personal information with, please contact us at email@example.com.
7. RETAINING YOUR PERSONAL INFORMATION
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data are as follows:
1) we will retain your personal data in a form that permits identification only for as long as:
a) we maintain an ongoing relationship with you; or
b) your personal data is necessary in connection with the lawful purposes set out in this policy for which we have a valid legal basis. If you are a Landlord, we are required to retain certain information about you for a minimum of six years for tax purposes.
2) the duration of:
a) any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant); or
b) an additional reasonable period following the end of such applicable limitation period,
3) in addition, if any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.
During the periods in paragraphs 2)a) and 2)b) above, we will restrict our processing of your personal data to the storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim or obligation under applicable law.
After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.
Any third parties that we engage will keep your data stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third party providers, we will make sure that they securely delete or return your personal data to us.
We may retain personal data about you for statistical purposes (for example, to help us better advertise our services). Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.
8. KEEPING YOUR PERSONAL INFORMATION SECURE
We take your privacy seriously and have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
9. CONTROL OVER YOUR PERSONAL INFORMATION
Under the General Data Protection Regulation, you have a number of important rights available to you. In summary, you have the right to:
• be provided with a copy of the personal information we hold about you;
• request that we correct any mistakes in the information which we hold about you;
• request the that we delete or remove your personal information in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured format;
• request that your personal data is transferred to a third party;
• object to decisions being taken by automated means concerning you or significantly affect you.
For further information on each of these rights, including the circumstances in which they apply, see: 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 these rights, please email us at firstname.lastname@example.org with the following information:
• provide us with the relevant information to be able to identify you and ensure your right to access your personal data (or exercise any other you other rights);
• provide us with proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.
10. HOW TO COMPLAIN
We hope that we can resolve any query or concern you have about our use of your information. If you are not happy with how we manage your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). The ICO is the authority in the UK tasked with the protection of personal data and privacy.
Any changes we make to this notice will be posted on this page.
12. HOW TO CONTACT US