Last Updated 23/04/2020
Who we are
We are Letting Cloud Limited (company number SC621233) and our address is 101 Rose Street South Lane, Edinburgh, EH2 3JG (referred to as “we” or “us” or “our”). We are not an Estate agency or Lettings agency. We are the providers of the Site www.lettingcloud.co.uk . It is our members (which include estate agents, commercial agent’s, lettings agents and landlords and are referred to as “members”) that display property details for you to view.
We provide this Site for our members so that they can advertise properties online. “Our members” include: estate agents, commercial agents, letting agents and landlords. We are not an estate or letting agency.
A reference to “you” or “your” is a reference to a user of the Site or any of our services.
If you have a query about information relating to your property on the Site, please contact your estate agent or lettings agent directly or alternatively contact us on [email protected]
If you would like to stop receiving marketing and communications from us please contact us via email at [email protected] REF: CST or please write to the Customer Services Team at the above address.
If you have any questions about this Policy or our use of your personal information or would like to submit a subject access request or exercise your other data subject rights, please contact our Data Protection Officer via email at [email protected] REF: DPO or please write to The Data Protection Officer, at the above address.
DATA PROTECTION LEGISLATION
We comply with:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
|PROPERTIES ADVERTISED ON THE SITE|
|What we collect and where it comes from||In the course of providing our services, we collect property data such as images of properties, property asking prices, rental figures history and periods of rent occupied, historical rental prices, property addresses, property locations and property descriptions.The property data is provided to us by our members or other third parties on behalf of those members.|
|Why we collect it||We will use this information for a number of reasons including: to provide the Letting Cloud Site;to enable our members to advertise their properties to the largest online audience available;to enable potential purchasers or tenants to see detailed descriptions and images of properties that they may be interested in;to allow users to see current property trends such as the prices of houses for sale in their local area; andfor our own commercial purposes such as to identify trends in the property market, automated survey and valuation tools, and to build property databases.|
|Our lawful basis for processing this personal data||We have a legitimate interest to process this information. These legitimate interests are:providing a service to our members by helping them to market properties;providing a service to our members by advertising properties to potential purchasers or tenants;providing a service to potential purchasers and tenants so that they know what properties are currently on the market and the price of those properties; andto provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.|
|How long we will keep it for||We will stop advertising a property when we are instructed to do so by our members.However, the property information will remain available on the Site as historical property information to allow users to benefit from services such as identifying previous for sale or sold prices (please see the historical property data section below for further information).|
|HISTORICAL PROPERTY DATA|
|What we collect and where it comes from||If a property has previously been actively marketed on the Site, we will continue to display it on the Site as historical property information. If you have any concerns about any historical property information available on the Site, please see the section of this Policy entitled “Removing Property Data from the Site” (below).We also have data that relates to historical property listings on the Site which we collect from other third parties. For example, we obtain the sold prices of the properties from the Land Registry (or the Land Register of Scotland) and display those sold prices on the Site|
|Why we collect it||We will use this information:to assist potential purchasers and tenants when forming a view about historical market trends and potential property values;to assist vendors when researching the approximate value of their property;to enable users to see detailed property descriptions and images of properties in areas that they may be interested in;to allow users to see property trends that they may be interested in, such as the previous sale and sold prices of houses in their local area; andfor our other commercial purposes, such as to identify trends in the property market and automated survey and valuation tools, and to build property databases.|
|Our lawful basis for processing this personal data||We have a legitimate interest to process this information. These legitimate interests are:to enhance the service that we provide on the Site and providing a service that benefits our members, Site users, vendors, landlords, potential purchasers and tenants;to provide a service to our members by assisting them to more accurately value other properties;to provide a service to vendors and landlords to form a view about the value of their properties;providing a service to potential purchasers and tenants in understanding what properties have been on the market and the prices of those properties; andto provide data services to third parties such as banks, building societies, insurance companies and other financial institutions so that they can process this historic property data for their purposes, including using the data in services such as property valuation models or surveyor comparison software.|
|How long we will keep it for||To the extent that property data is also personal data, it is generally the case that it ceases to be personal data over time. The historic property data is retained by us in accordance with our property database and remains necessary in order for us to provide the services summarised in the “why we collect it” box.|
|INFORMATION YOU GIVE TO US|
|What we collect and where it comes from||We will collect the information that you give to us when using our Site or services:Enquiries to our members:if you choose to access a particular search feature or to fill in a form on the Site you may be asked to provide information about yourself, such as your name and contact details. We may also collect other information about you at the same time, such as details of the sort of property you are interested in, the cost and location of the property, and your current residential address;if you choose to contact us or a member using the member telephone number on Site, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.Registered Users and Property Alerts:information that you provide to us when you register as a Letting Cloud user and/or request property email updates such as Property Alerts about when a property is placed on the market in your chosen postcode and meeting your search parameters;General Site Use:information that you provide when participating in discussion boards or other social media functions on our Site and enter into competitions, promotions or surveys available on the Site;Communications:information that you provide to us by corresponding with us by phone, e-mail or otherwise; and|
|Our lawful basis for processing this personal data||We have a legitimate interest to process this information. These legitimate interests are:Enquiries to our members:to provide a service to our members and/or to provide a service to you;Registered User and Property Alerts:to provide you with our services;General Site Use:to gain information about the use of our Site and any improvements that can be made as well as providing advertising space to our members and third parties;Communications:to ensure that your queries are addressed; andInvestor Relations:to allow you to access Letting Cloud regulatory alerts and to ensure that your queries are addressed.|
|How long we will keep it for||We will store the information summarised above for the following periods:Enquiries to our membersall enquiry data will be kept for two years from the date on which you last used our Site or our services. After that it will be erased or anonymised so that the data no longer identifies you.Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted.profiling data will be kept for a shorter time period, as described in “Lead Profiling” below.Registered Users and Property Alerts:information that you provide to us when you register as a Letting Cloud user will be kept for as long as you have an account setup on Letting Cloud. The personal data relating to your account will be deleted when you delete your account.General Site Use:information that you provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years.information that is provided when you interact with us through social media functions will only be retained on the social media platforms which you use to contact us – we will not copy or store it separately. This data will be retained for as long as you keep it on your social media accounts.Communications:information that you provide to us by corresponding with us by phone, e-mail or otherwise will be retained for the later of 18 months from the date of communication or until your query is resolved.|
|INFORMATION WE RECEIVE FROM THIRD PARTIES (OTHER THAN OUR MEMBERS)|
|What we collect and where it comes from||We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you, when we collected the data, that it may be shared internally and combined with data collected on this Site.|
|Our lawful basis for processing this personal data||We have a legitimate business interest to process this information. These legitimate interests are:enhancing the service that you receive on the Site;to provide a service to our members so they can respond to enquiries; andproviding information necessary to enable us to provide a competitive, cost effective services.|
|How long we will keep it for||We will store this personal data for two years from the date on which you last used our Site or Services at which point it will be erased or anonymised so that the data no longer identifies you.|
|INFORMATION WE COLLECT ABOUT YOU|
|What we collect and where it comes from||This is different to “information you give us” because it relates to technical data that we collect. We may:collect technical information that has the potential to identify you, such as the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;collect information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page; andwe may combine technical information with other information that we have about you to help us with our processing of your information as set out in this Policy.|
|Why we collect it||We will use the information summarised above:to provide the Site to you;to conduct reviews that assist us in the improvement and optimisation of our Site;to ensure that content from our Site is presented in the most effective manner for you and for your device;to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical a survey purposes;as part of our efforts to keep our Site safe and secure; andto customise and enrich your experience on our Site.|
|Our lawful basis for processing this personal data||We have a legitimate interest to process this information. These legitimate interests are:to help ensure the on-going security of the Site;enhancing the service that you receive on the Site; andproviding information necessary to enable us to provide a competitive, cost effective services.|
|How long we will keep it for||We will store this personal data for two years in order to allow us to review and monitor normal traffic patterns and trends on Site. After two years this data will be kept in an anonymous form.|
We may from time to time profile your activity when using our services or our Site. This profiling is limited in its scope to telephone and email enquiries you send to our members. It only takes place to help us and our members understand what sort of properties you may be interested in and to categorise your activity to help us and our members determine how likely you are to require services from our members. Members may then contact you to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing your personal data). You can always object to our profiling by emailing us here [email protected] REF: DPO. Any profiling data that we hold about you will only be kept for a period of 12 months from the date of the last telephone or email you have sent to a Letting Cloud member.
USE OF YOUR DATA FOR MARKETING AND COMMUNICATIONS
Sometimes we may use your personal information to provide marketing messages to you. You can opt out of marketing and other communications at any time by contacting [email protected] . You can always make use of the Site without having to agree to marketing. The types of things that we may do include:
providing direct marketing advertisements and communications to you via email, text, post or telephone;
making suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them;
communicating with you on third party social media platforms; and
monitoring the effectiveness of our direct marketing communications and your responses to it.
REMOVING PROPERTY DATA FROM THE SITE
If you have any concerns about the property data on the Site, please contact us at [email protected] and we will endeavour to resolve the issue promptly.
If you are a vendor or landlord of a property that is being actively marketed on the Site, please contact your estate agent or lettings agent directly.
If you have concerns about historical property information about a property featured on our Site and you can prove to us that you have a valid association to that property, please contact us at [email protected] .
WHO HAS ACCESS TO YOUR PERSONAL DATA?
We retain access to all personal information that we have collected from you or about you. Once your information has been passed to one of our members in the course of providing our services (most typically when you communicate with an estate agent through our Site) then that Letting Cloud member will have a copy of the information that you have provided within your enquiry and your contact details which they will use to get in touch with you. In relation to property data, it is provided to us by our members (or third parties that act on their behalf). Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of your information by any of our members.
When our service is available via the websites of our partners, those partners may have access to your information. We may also have links to other websites from our Site. We are not responsible for the content, security, privacy policies and practices of any other websites, even if you access them using links from this Site or if you can access this Site or use our services from them. We recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
If our business is sold or merged, or if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.
If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your information to them in order to deliver the service. The categories of third parties (who are acting as a data processors) include: telephone call recording and our support ticketing systems. We may also use third parties to provide services on our behalf which may include processing (but not using themselves) your information e.g. to complete partial addresses or to augment the information we hold about you. In either case, we will not pass your information to anyone who is not also subject to adequate privacy commitments in our contract with them.
We will not otherwise disclose, sell or distribute your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.
WHERE DO WE STORE YOUR PERSONAL DATA?
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.
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 our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We follow strict security procedures to ensure that your personal information is not damaged, destroyed or disclosed to a third party without your permission and to prevent unauthorised access to it. The computers that store the information are kept in a secure facility with restricted physical access and we use secure firewalls and other measures to restrict electronic access. If we are working with third parties, we will require them to have in place similar measures to protect your information.
Only employees who need access to your information to perform a specific job are granted access to personally identifiable information. We may require you to co-operate with our security checks before we disclose information to you. If you are a registered user, you can update the personal information that you give us at any time by viewing your Letting Cloud account.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
You have the right to ask us not to process your personal data at any time.
You have the right to use our Site without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We always use the most recently submitted form to be your current consent status. If you are a registered user, but not signed in when you submit a form, we will not be able to use your saved settings so will deem your consent choice to be as per the form you submit at the time. You can exercise your right to prevent such processing by selecting the specific options in the fields or forms when you become a registered user.
You have a right to request access to or rectification of your personal data which we hold about you. You also have a right to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us, the right to object to our processing of your personal data and a right to request that we transmit your personal data to another data controller.
Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.
To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this policy.
You have the right to complain to the Information Commissioner’s Office if you feel unhappy with the way we process your data. Please visit www.ico.org.uk for more information.
COOKIES AND TRACKING
CHANGES TO THIS POLICY
Any changes we may make to this Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Policy.