privacy policy…

1 INTRODUCTION

1.1 Important information and who we are

Welcome to Leaseholders Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At Leaseholders Limited (“we”, “us”, or “our”) we are committed to protecting and

respecting your privacy and Personal Data in compliance with the United Kingdom General

Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory

laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy

Policy will tell you about your privacy rights, how the law protects you, and inform our

employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

Customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data

processed at any time by us.

1.2 Who is Your Data Controller

Leaseholders Limited is your Data Controller and responsible for your Personal Data. We

are not obliged by the GDPR to appoint a data protection officer and have not voluntarily

appointed one at this time. Therefore, any inquiries about your data should either be sent

to us on email at privacy@leaseholders.co.uk or sent in a letter to Charles House 4th Floor,

Charles House, 108-110 Finchley Road, London, NW3 5JJ, United Kingdom.

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.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal

with your data on our behalf (known as “Processors”). Therefore, the responsibilities

described below may be assigned to an individual, or may be taken to apply to the

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organisation as a whole. The Data Controller and our Processors have the following

responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases

laid out in the GDPR (see 2.2 below for more information on those bases);

Ensure that Processors authorised to process Personal Data have committed

themselves to confidentiality or are under an appropriate statutory obligation of

confidentiality;

Implement appropriate technical and organisational measures to ensure a level of

security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging

another Processor;

Assist the Controller in the fulfilment of the Controller's obligation to respond to

requests for exercising the data subject's rights;

Make available to the Controller all information necessary to demonstrate

compliance with the obligations laid down in the GDPR and allow for and contribute

to audits, including inspections, conducted by the Controller or another auditor

mandated by the Controller;

Maintain a record of all categories of processing activities carried out on behalf of a

Controller;

Cooperate, on request, with the supervisory authority in the performance of its

tasks;

Ensure that any person acting under the authority of the Processor who has access

to Personal Data does not process Personal Data except on instructions from the

Controller; and

Notify the Controller without undue delay after becoming aware of a Personal Data

Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be

collected from you but this is the full scope of data that we collect and when we collect it

from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date

of birth.

Contact Data: This is data relating to your phone number, addresses, email

addresses, phone numbers.

Marketing and Communications Data: This is your preferences in receiving

marketing information and other information from us.

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Billing Data: This is information relating to your debit and credit card information

such as the name attached to your payment details and your billing address.

Financial Data: These are your banking details e.g. your account number and sort

code.

Transactional Data: This is information of details and records of all payments you

have made for our services or products.

Customer Support Data: This includes feedback and survey responses.

We also collect, use and share Aggregated Data such as Benchmarking service charges in

leasehold properties by location.. Aggregated Data could be derived from your Personal

Data but is not considered Personal Data in law as this data will not directly or indirectly

reveal your identity. 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 Policy.

We may also aggregate data to enable research or analysis so that we can better

understand and serve you and others. For example, we may conduct research on your

demographics and usage. Although this aggregated data may be based in part on Personal

Data, it does not identify you personally. We may share this type of anonymous data with

others, including service providers, our affiliates, agents and current and prospective

business partners.

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

and biometric data). Nor do we collect any information about criminal convictions and

offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and

processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when

you tick a box that confirms you are happy to receive email newsletters from us, or

‘opt in’ to a service.

“Contractual Obligations”: We may require certain information from you in order

to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of

data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be

able to meet our legitimate interests - this covers aspects that can be reasonably

expected as part of running our business, that will not have a material impact on

your rights, freedom or interests. Examples could be your address, so that we know

where to deliver something to, or your name, so that we have a record of who to

contact moving forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

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We will only use your Personal Data when the law allows us to. Set out below is a table

containing the different types of Personal Data we collect and the lawful basis for

processing that data. Please refer to section 2.2 for more information on the lawful basis

listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which

we use your data may be broader than described but we will never process your data

without a legal basis for doing so and it is for a related purpose. For further inquiries

please contact us.

Activity Type of data Legal Justification Lawful basis for processing data when a person

signs up: Profile/Identity, Data, Contact Data, Consent, Legitimate Interest; We need to process this data

so we know who you are and so you can access our platform.

When a person sends us their invoices: Profile/Identity, Data, Contact Data, Consent,

Legitimate Interest, Explicit Consent, Necessity; We need to process this data so we can

provide recommendations, benchmark information, and provide services back to you.

When a person completes our survey: Profile/Identity, Data,

Contact Data, Marketing and Communications, Support Data, Other Data, Consent, Legitimate Interest,

Necessity, Research; We need to process this data so we know what preferences you have in the services we provide.

3.2 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.

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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.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 What Control Do I Have Over Leaseholders Limited’s Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our

systems and our related software.

We guarantee this will delete all stored data.

Your account information will be protected by a password for your privacy and security.

You need to prevent unauthorized access to your account and personal information by

selecting and protecting your password appropriately and limiting access to your

computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into your account you

created with us.

Your account information will be protected by a password for your privacy and security.

You need to prevent unauthorized access to your account and personal information by

selecting and protecting your password appropriately and limiting access to your

computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California

residents are entitled to ask us for a notice identifying the categories of personal customer

information which we share with our affiliates and/or third parties for marketing purposes,

and providing contact information for such affiliates and/or third parties. If you are a

California resident and would like a copy of this notice, please submit a written request to

privacy@leaseholders.co.uk.

4.2 How Does Leaseholders Limited Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate

disclosure. Any Personal Data collected by us is only accessible by a limited number of

employees who have special access rights to such systems and are bound by obligations

of confidentiality. If and when we use subcontractors to store your data, we will not

relinquish control of your Personal Data or expose it to security risks that would not have

arisen had the data remained in our possession. However, unfortunately no transmission

of data over the internet is guaranteed to be completely secure. It may be possible for

third parties not under the control of Leaseholders Limited to intercept or access

transmissions or private communications unlawfully. While we strive to protect your

Personal Data, we cannot ensure or warrant the security of any Personal Data you

transmit to us. Any such transmission is done at your own risk. If you believe that your

interaction with us is no longer secure, please contact us.

4.3 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, if your request is clearly unfounded, we could refuse to comply with your

request.

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We may need to request specific information from you to help us confirm your identity

and ensure you have the 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.

5 YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data

with subcontractors or affiliates (subject to confidentiality obligations to use it only for the

purposes for which we disclose it to them and pursuant to our instructions).

We may also share Personal Data with interested parties in the event that Leaseholders

Limited anticipates a change in control or the acquisition of all or part of our business or

assets or with interested parties in connection with the licensing of our technology.

If Leaseholders Limited is sold or makes a sale or transfer, we may, in our sole discretion,

transfer, sell or assign your Personal Data to a third party as part of or in connection with

that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern

the further use of your Personal Data. In all other situations your data will still remain

protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to

enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site 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 Site, we encourage you to read the privacy policy

of every website you visit.

6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes

we collected it for. We may retain your Personal Data for a longer period than usual in the event

of a complaint or if we reasonably believe there is a prospect of litigation in respect to our

relationship with you.

7 AGE LIMIT FOR OUR USERS

You must not use Leaseholders Limited unless you are aged 18 or older. If you are under 18 and

you access Leaseholders Limited by lying about your age, you must immediately stop using

Leaseholders Limited.

This website is not intended for children and we do not knowingly collect data relating to children.

8 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions

outside the US where Leaseholders Limited has facilities. We are currently storing data in the EU

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and so, by using Leaseholders Limited, you are permitting and consenting to the transfer of

information, including Personal Data, outside of the US.

9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This

version is dated 27 July 2022. By using Leaseholders Limited, you consent to the collection and

use of data by us as set out in this Privacy Policy. Continued access or use of Leaseholders

Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10 INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated

examples are not intended to in any way limit the term which they serve to illustrate. Any email

addresses set out in this policy may be used solely for the purpose for which they are stated to

be provided, and any unrelated correspondence will be ignored. Unless otherwise required by

law, we reserve the right to not respond to emails, even if they relate to a legitimate subject

matter for which we have provided an email address. As a matter of common sense, you are

more likely to get a reply if your request or question is polite, reasonable and there is no

relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other

areas of our website etc.).

Our staff are not authorised to contract on behalf of Leaseholders Limited, waive rights or make

representations (whether contractual or otherwise). If anything contained in an email from a

Leaseholders Limited address contradicts anything in this policy, our terms or any official public

announcement on our website, or is inconsistent with or amounts to a waiver of any

Leaseholders Limited rights, the email content will be read down to grant precedence to the

latter. The only exception to this is genuine correspondence expressed to be from the

Leaseholders Limited legal department.