Effective from : Mar 15, 2023

This notice describes how this mobile application (‘LTF Lettings, Portsmouth App’) collects, stores, transfers and uses your personal data.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

1.How we obtain personal data

The information we process about you includes information you have directly provided to us, whether through using the App or through one of our other services; and information we obtain as a result of monitoring how you use the App.

2.Types of personal data we collect directly

Information you might provide directly to us might include personal identifiers, such as your first and last names, and contact information, such as your email address, your telephone number and postal addresses.

We also process your preferences to receive marketing from us and how you wish to communicate with us; and responses and actions in relation to your use of the App and our services.

3.Types of personal data we collect from your use of the App

We may collect information about your device, including your device type, operating system, and unique device identifiers, as well as information about how you use the App, such as the features you use, the content you view, and the actions you take.

The App allows you to upload images, and some of those images may contain personal data.

As examples:

You may upload photographs of the interior and exterior of any property you manage for prospective and current tenants. Information within those images may include personal data, for example, of yourself in a reflection of a mirror or a window.

You may choose to use a photograph of yourself as a profile image in your account.

We may collect photos or videos for better user experience and the instances are listed below

Reported Repairs,

We collect photos of reported repairs which helps us to identify the damage caused and is essential to identify this to provide repair services efficiently. Also this is an optional field NOT mandatory

Profile Picture:

We may require a profile picture of the users as there could be people with similar names, this helps us individually identify each contact.

Add Quote:

We require the option to Add a quote as the estimation of the prices is to be displayed and be available for the parties involved in the payments

Add Invoice:

We may require the option to add an invoice as this eases the process and its essential for account management to have track of the expenses.

4.Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of the App is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

5.If you do not provide personal data we need

Where we need to collect personal data to enable you to use features of the App, and you fail to provide that data when requested, the App may not function for you.

6.Information we process under our contract with you

When you first install the App, you agree to our terms and conditions and a contract is formed between you and us. There may also be other contracts in place between us already.

Because there is a contract in place, all personal data that is required to be processed by or through the App is done so on the basis of ‘contract’.

This basis remains in place while you use the App.

7.Information we process for the purposes of legitimate interests

We may process personal data on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• Whether the same objective could be achieved through other means
• Whether processing (or not processing) might cause you harm
• Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• Improving the performance of the App on certain devices;
• Exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property; and
• Protecting your interests where we believe we have a duty to do so.

8.Information we process because we have a legal obligation

Sometimes, we must process your personal data in order to comply with a legal obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a court order.

9.Service providers and business partners

We may share your personal data with third-party service providers, such as those who provide hosting, analytics, and customer support.

If we do so, then our contracts with those service providers and partners contain data protection clauses that ensure that your personal data is treated with as much care as we do.

10.Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

11.Data may be processed outside the UK

We may also use outsourced services in countries outside the UK from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the UK.

We safeguard your personal data by ensuring that the data protection clauses in our contracts with data processors include standardised transfer clauses written by or approved by a supervisory authority.

12.Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may use the App to access, or contact us to request that we provide you with, the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

13.Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/ We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

14.Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• To provide you with the services you have requested;
• To comply with other law, including for the period demanded by our tax authorities; and
• To support a claim or defence in court

15.Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

16.Review of this privacy policy

We shall update this privacy notice from time to time as necessary.