1. IMPORTANT INFORMATION AND WHO WE ARE
CONTROLLER
Homie is the controller and responsible for your personal data (collectively referred to as “Homie”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.

CONTACT DETAILS
Our full details are: Data Protection Officer, Homie Management Limited
Email address: contact@hello-homie.com
Postal address: 10 Brook Street, London, W1S 1BG

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in October 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together, follows:
• Identity Data includes first name, maiden name, last name, title, date of birth, gender, photo ID, facial biometric data, your place of study, your student identification number and proof of address together with any ‘know your customer’ data we hold about our landlord clients and ID verification data and immigration status data we hold about tenants or prospective tenants.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Property Data includes information relating to a property which you may occupy as a tenant or own as a landlord.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes email address and password, (where applicable), purchases or orders made by you, your interests, preferences, information provided in comments on our website, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

During our online registration process, you may be directed to Concurrent, an external property management system, to sign up to rent any of the properties in our listings. Within the Concurrent platform:

(a) you may be required to verify your identity by Trust ID, for the purposes of checking your eligibility to rent the property in question; and

(b) your guarantor (if any) may be required to verify their identity by Canopy, for the purposes of credit reference checks.

For the identity checks referred to above, you (and your guarantor, where applicable) will be asked to provide a digital photographic image of your (and their face). Such image(s) will be processed via an automated verification tool which will use your (and your guarantor’s) biometric facial data, together with any required scanned proof of identity and proof of address documents provided by you (and your guarantor), to confirm your (and your guarantor’s) identity automatically. Biometric facial data is a Special Category of Personal Data. Where you have chosen to use this automated process, in the event that you (or your guarantor) do not pass the automated checks, you (and/or your guarantor) will be referred to a member of our staff who will undertake additional manual checks in order to verify your/your guarantor’s identity. You (and/or your guarantor) do not need to use the automated check process or to provide your biometric facial data if you (and/or your guarantor) do not want to. If you (and/or your guarantor) do not want to use the automated check process, we can undertake manual checks instead. If you and/or your guarantor have any concerns about this, please contact us.

Our full details are:

Data Protection Officer, Homie Management Limited

Email address: contact@hello-homie.com

Postal address: 10 Brook Street, London, W1S 1BG

The biometric facial data mentioned above, for the automated checks is collected by Concurrent; we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with lettings and management services). If you are a tenant or prospective tenant then we will need to obtain data from you in order to facilitate a letting or other arrangements.

We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• contact us directly through our website;
• when you contact us directly by telephone, email or letter;
• [when you interact with us on social media;];
• when you apply to become a tenant of a property we manage;
• when you ask us to manage or arrange lettings for a property you own or manage;
• when you provide comments on our website (when you provide such comments you are expected not to include any personal data about any other individuals, unless you have their consent);
• request marketing to be sent to you;
• when you meet and register with us at the event;
• when you provide us with information in order for us to complete required immigration status checks and undertake credit reference or other checks for tenants or. prospective tenants or guarantors; and
• when you provide us with information in order for us to complete our required identity and anti-money laundering checks; and
• when we contact you during our relationship with you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below
• Technical Data from the following parties:
(a) analytics providers to carry out analysis of our customer data and your interaction with our website;
(b) advertising networks to allow us to target relevant advertising to previous customers and similar audiences; and
(c) search information providers to locate individuals in respect of anti-money laundering checks.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity, Contact and Property Data from publicly availably sources such as Companies House, Land Registry and the Electoral Register as well as private credit reference agencies and ID verification services.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or where we obtain your explicit consent for processing your facial biometric data if you choose to use our automated identity verification process. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a prospective tenant or tenant (a) Identity
(b) Contact
(c) Property
(d) Financial (a) necessary for our legitimate interests (to provide services to our clients)
(b) consent, in the case of biometric Identity data
To register you as a new client (a) Identity
(b) Contact
(c) Property
(d) Financial (a) performance of a contract with our client
(b) consent, in the case of biometric Identity data
To deliver our property related services to you as a client (a) Identity
(b) Contact
(c) Property
(d) Financial (a) Performance of a contract with our client
(b) necessary for our legitimate interests (to provide services to our clients);

To process and deliver our services including:
(a) Providing residential property lettings and management services
(b)Manage payments, fees and charges
(b) Collect and recover money owed to us (a) Identity
(b) Contact
(c) Property
(d) Financial
(e) Transaction
(f) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide services to our clients)
(c) Consent, in the case of biometric Identity data
To manage our relationship with our clients which will include:
(a) Notifying you about changes to our terms of business or privacy policy
(b) Asking you to leave a review or take a survey
(c) Giving you an opportunity to provide your comments and feedback (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications (a) Performance of a contract with our clients
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to study how clients use our products/services, to generate client interest in our services and to better understand client and customer reactions and feedback)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical Necessary for our legitimate interests (to study how clients use our products/services, to collate client and customer feedback and reactions, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)
To undertake our required identity verification, immigration status and anti-money laundering checks (a) Identity
(b) Contact
(c) Property (a) Performance of a contract with our clients
(b) Necessary to comply with a legal obligation (including anti-money laundering and immigration legislation)
(c) where you choose to provide us with your biometric facial data to use our automated identity verification process, explicit consent. You are not obligated to use the automated identity verification process or provide your biometric facial data. Where you would prefer not to do this, you will be given the option to use our manual identity verification check process instead.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage, Property and Profile Data 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 (we call this marketing). You will receive marketing communications from us if you have requested information from us, registered on our website or purchased services from us and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside the Homie group of companies for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties as set out in the glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

There may be circumstances in which certain personal information is transferred outside of the UK or European Economic Area (together the “European Area”).
• For instance some companies that provide services to us run their services from outside the UK or the European Area.
• We may communicate with individuals or organisations outside of the European Area 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 European Area (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the European Area, 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.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
• Records relating to a tenancy, letting or contract with us – 7 years from either the end of the contract or letting or the date you last used our services, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.
• Marketing records – 3 years from the last date on which you have interacted with us.
For any category of personal data not specifically defined in this 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 or if later, the date on which we last interacted with you.
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).

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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.

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES
EXTERNAL THIRD PARTIES
• Marketing third parties acting as processors who provide marketing support.
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who may provide us with consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Credit Reference Agencies.
• Debt collection agencies.
• Agencies and third party providers who assist Homie in complying with immigration status legislation and Anti-Money Laundering Regulations (including, for example, the provision of an automated identity verification tool).