Tipi takes your privacy seriously where we deal with your personal information. This means information that identifies you personally such as your name, credit card information, photo and contact details or data that can be linked with such information in order to identify you directly or indirectly (“Information”).
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References to ‘Tipi’ ‘we’, ‘our’ or ‘us’ in this Policy are to Tipi Homes Ltd of 180 Great Portland Street, London W1W 5QZ.
HOW DOES TIPI COLLECT YOUR INFORMATION?
We collect your information in the context of offering and providing our services to you, and when you interact with us. We collect your information in a number of ways, being either information you give to us, information we collect automatically, information we receive from third parties or information you provide about other people.
Information you give us
We collect information on you where you:
- register to receive any kind of marketing communications from us;
- contact us over the phone, via email, post, live chat or social media messaging;
- interact with our social media profiles;
- enquire about renting a property with us or book a viewing for a property;
- create an account with us when making an online application to rent any of our properties;
- complete an application to rent any of our properties;
- provide any additional information we request to process your application or confirm your lease;
- enter any information into or interact with us via the resident portal;
- complete a release form to allow us use photo or video footage of you or attend any of our events or programmes with our official photographer present;
- act as a guarantor for a lease and complete our guarantor form and declaration;
- enter into a supplier agreement or relationship with us or are a representative of a supplier; and
- voluntarily provide us with information for any other reason.
Information from third parties:
- Such as Rightmove, Zoopla, Spare Room, Idealflatmate, Findaroommate, HomeLet, Canopy, University of London Housing Services, LSE, Imperial College, Knight Frank, CBRE, Houzen, Savills, Movebubble, Wembley Park Residential and any other associated/affiliated groups
- Where you are provided as either a reference, a previous landlord or a guarantor, we collect information on you from the relevant individual who has identified you as such. This generally includes name, relationship with tenant or prospective tenant, contact details and salary details (for guarantors);
- We collect information on you from individuals who you provide as either references, previous landlords or guarantors when you wish to rent a property from us. This is generally a description of the relationship between you and the referee along with any merits (or demerits) in relation to you as concerns the renting of a relevant property; and
- We collect information on you from referencing companies we engage to carry out pre-tenancy checks on you to ensure you are who you say you are and from. This is generally information that confirms or refutes the information you have provided to us.
Information we collect automatically
- We collect certain information by automated means, such as cookies and web beacons, whenever you visit our website. This could include IP address, browser type, operating system, referring URLs, information on actions taken on our website, and dates and times of website visits. See cookie section below.
HOW DOES TIPI USE YOUR INFORMATION?
The information we hold on you is generally used to find you a suitable property with us where you are a prospective tenant and to manage our relationship with you and provide services to you where you are a resident.
Where we rely on legitimate interest as a ground for processing your information, our legitimate interest is necessary for promoting our business, improving the services we offer to you and your experience when you interact with us, and ensuring effective operational management and internal administration of our business and the exercise of our rights.
To provide you with services requested or where we have a contract
- To register you as a new resident when you rent a property with us;
- To manage and provide you with the services under a lease agreement, or any other agreement you enter into with us. This includes managing rent, aftercare and maintenance services (including dealing with your queries); and
- To raise sales invoices, to confirm the success of payments you make to us as rent, and to issue you with refunds where applicable.
Where we have your consent
- To send you direct marketing communications relating to our available properties or services, according to your marketing preferences where we do not have a legitimate interest grounds for sending these communications; and
Where we have a legal obligation
- To protect, investigate, deter and report fraudulent, unauthorised or illegal activity. Where you are interested in renting a property, this includes carrying out KYC checks, money laundering checks and sanction checks against you and/or the business you represent.
Where we have a legitimate interest
- To verify that the details you have provided us are true and accurate, and to carry out insolvency and credit checks on you. This is to ensure you are suitable to be able to proceed with renting a chosen property and can finance it;
- To ascertain the kind of property you may be interested in from your enquiries/ information requests and to contact you in relation to such property where you have expressed a desire to be contacted;
- To send you marketing communications where we have a commercial relationship with you or where you have made enquiries in relation to any of our properties and you have not objected to receiving such communications from us;
- To raise sales invoices and to confirm any payments other than rent you make to us;
- To continue ongoing communications with you during the course of your tenancy;
- To manage security and access controls during your tenancy;
- To contact you to enquire about the prospective tenant who provided your information, where you are either a referee, a previous landlord or a guarantor of a prospective tenant;
- To contact you in relation to material issues such as non-payment of rent and disciplinary action where you are a guarantor for a tenant;
- To contact you and process payments for services provided where you are a supplier or a supplier’s representative;
- To respond to any enquiries, information requests or complaints you make to us;
- To assist with marketing research, processing sales and for statistical purposes;
- To use photographs and video footage which identify you for our marketing, advertising and research campaigns where you have completed a release form and we do not have a contract with you or another legitimate interest ground for using this information;
- To use photographs and video footage which may identify you, for our marketing, advertising and research campaigns where you attend an event or programme with our official photographer in attendance and we have given prior notice of the presence and purpose of such photographer or placed prominent notices at the relevant event to that effect. You are able to object to us taking a picture of you or request we delete this picture at the time;
- To contact you with public relations and marketing information, including planning information and information on upcoming events, where you are a representative of a stakeholder company;
- To tailor content that we display to you on our website;
- To assist with internal record keeping;
- To improve the properties and services we offer to you;
- To provide you with, and maintain the quality of, our website and to analyse the use of our website in order to help guide improvements; and
- To contact you for your views and feedback on our services and to notify you if there are any important changes or developments to our services.
We may also use aggregate anonymised information in order to help us develop our services and may provide such information to third parties. This information cannot identify you.
Where we rely on legitimate interest as a ground for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request, and can find out more by contacting us using the details below.
HOW LONG DOES TIPI KEEP YOUR INFORMATION?
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘How does Tipi use your information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws. For example, we generally keep your information for 6.5 years after termination of a lease agreement with you, in our legitimate interest, to be able to bring claims or defend against potential legal action.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information above);
(potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase or anonymise your information where we no longer require your information for the purposes collected.
DOES TIPI TRANSFER YOUR INFORMATION ABROAD?
Your information is stored within the EU but in very limited circumstances may be transferred to India or the US; this is only the case where you have provided your name and email address details in looking for a rental apartment and we email you of relevant offers or new building information using through our industry-leasing US email software MailChimp. We ensure that any of your information processed outside the EEA is protected in the same way, as it would be, if it were processed within the EEA by putting appropriate security measures and safeguards in place. For the transfer to India, we have EU Model Clauses in place as a safeguard. To find out more about how we safeguard your information as related to transfers and to obtain a copy of such safeguard, contact us using the contact details below.
MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework. It subjects all Personal Information received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view MailChimp’s certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome.
WHAT ARE YOUR PRIVACY RIGHTS?
By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our details below.
|Rights||What does this mean?|
|The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).|
|The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.|
|The right of access||You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.|
|The right to rectifications||You are entitled to have your information corrected if it is inaccurate or incomplete.|
|The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.|
|The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|The right to data portability||You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See details of the UK data protection regulator in the contact us section below.|
|The right to withdraw consent||If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your information for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
CHANGES TO THIS POLICY
We may periodically make changes to this Policy. We will notify you of any significant changes where we have a relationship with you and otherwise post updated documents on our website.
If you have any questions, comments and requests regarding this Policy, please get in touch with us: The Tipi Team at our Tipi HQ, Exhibition Way, Wembley HA9 0FA, or via phone 0203 151 1961, or email email@example.com
If you are not satisfied with our response to a complaint you have made, or think we aren’t complying with data protection law, you can make a complaint to the UK data protection regulator – the Information Commissioner’s Office:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Phone number: 0303 123 1113