Husmus Ltd Privacy Notice

About this Privacy Notice

Effective date: 31 May 2019

Husmus Ltd (“we” or “us”) take the privacy of your information very seriously. This notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our website (husmus.net), app or collected through other means such as by an online form, email, or telephone communication.

This notice applies to personal information provided by our clients (whether as a landlord or tenant), where applicable their staff and any third party suppliers whose data we process, but does not apply to information we hold in relation to our staff and contractors. In this notice “you” refers to any individual whose personal data we hold or process. This Privacy notice is governed by the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation.

In general and in anticipation of the launch of our property rental platform, our services relate to offering a new and simpler way for landlords and tenants to navigate the rental market by making it easier for landlords to rent their properties as well for tenants to find the ideal property. We also provide home management services to landlords, such as managing repairs and maintenance services.

By using the services, you agree to the collection and use of information in accordance with this notice. Unless otherwise defined in this notice, terms used in this notice have the same meanings as in our Website Terms and Conditions.

This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Personal data we collect and how we process this data

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

Contact information for our users who have registered with us such as name, email address, address, telephone number (for authentication), (“Contact Information”) which we will use to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.
Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a payment processor, marketing software provider, credit agency or professional advisor such as a lawyer or accountant) (“Third Party Contact Information”). We process this information when we provide services to our clients on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
Financial information which we hold in the context of providing services to our clients (“Financial Information”) such as rental income, credit history information, bank details. We process this information when we provide services to our clients on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
Demographic information such as postcodes, property search criteria, preferences and requirements, (“Demographic Information”). We process this information when we provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
Cookie Information. A cookie is a small text file which asks permission to be placed on your computer's hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We process Cookie Information in order to improve or communicate with you about services and/or to customise the website according to your personal interests, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.
A record of any correspondence or communication between you and us (“Communication Information”). We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our clients.
User generated content which you post to one of our services such as user comments which may contain personal data (“User Generated Information”) which we may use to display and share comments and other information for our users on the basis of our legitimate interest in providing our services to you;
Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”). We process this information in order to improve or communicate with you about our products and services, for market research purposes or in order to customise our services, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.

We will collect information either from you directly or from a third party (for instance an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this Privacy Notice.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

Contact Information, Financial Information, Communication Information, Third Party Contact Information and records relating to a contract with us – 7 years from either (i) the end of the contract or (ii) the date you last used our services.
Marketing Information and business development records- (where we have not provided services to you and you have not provided information to us) - Up to 3 years from the date on which you last interacted with us.

For any category of personal data not specifically defined in this section or notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.

If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.

Sharing your information

We may disclose information to third parties in the following circumstances:

We may work with other professionals and providers in providing and delivering our services to you, this may include a payment processor, marketing software provider, credit agency or professional advisor such as a lawyer or accountant;
we may disclose information to our group companies (as applicable);
If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
In order to enforce any terms and conditions or agreements for our services that may apply;
as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.

Security

We store your data in our databases and we will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out (including suitable physical, electronic and managerial procedures) in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.

The security measures may include (as necessary):

Protecting our servers with software firewalls;
Locating our data processing storage facilities in secure locations;
Encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
Securely disposing of or deleting your data;
Regularly backing up and encrypting all data we hold.

We will take reasonable steps to ensure that our employees and staff are aware of their privacy and data security obligations.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site's privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

Your privacy rights

With respect to your personal data, you have:

The right to object to processing – the right to request that your personal data will not be processed;
The right to access - the right to request a copy of any personal data that we have about you;
The right to rectification - the right to request a correction of any errors in or update of the personal data that we have about you;
The right to data portability - the right to request that your personal data be transferred or exported to another organisation
The right to erasure – the right to request that your personal data is deleted from our records;
The right to withdraw consent – at any time, you have the right to withdraw any permission you have given us to process your personal data
The right to request that your personal data will not be used to contact you for direct marketing purposes;
The right to request that your personal data will not be used for profiling purposes;
The right to request that your personal data will not be used to contact you at all.

All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below. We will endeavour to comply with such requests as soon as possible but in any event (and to the extent applicable) we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner's Office (ICO) and/or our data protection manager.

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside the EEA

We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (“EEA”) but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:

From time to time, some of our data processors (including server providers), may be based outside of the EEA. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services or communicate with you;
We may communicate with individuals or organisations outside of the EEA in providing our services. Those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by us using the details below:

Email: privacy@husmus.net

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner's Office by visiting http://www.ico.org.uk for further assistance.