FLATSNAPP PRIVACY AND COOKIE POLICY

Last Updated: 23 May 2018

Whilst we have not made any material changes to the way we process data about our users, we have updated this policy to make it shorter and easier to read, and to comply with the EU General Data Protection Regulation coming into force on May 25, 2018

     1.        GENERAL

 1.1.        Thank you for using Flatsnapp, a quicker, smarter way to rent. We at Flatsnapp Limited (“Flatsnapp”, “we”, “our” and “us”) respect your privacy and want you to understand how we collect, use, and share data about you.

 1.2.        This Privacy Policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which we collect and process your data, and describes your rights to access, correct, or restrict our use of your personal data. Please read it carefully.

 1.3.        This Privacy Policy applies when you visit or use any of the Flatsnapp websites or their mobile versions, our mobile applications, APIs or related services (the “Sites”). By using the Sites, you are accepting and consenting to the practices described in this policy.

 1.4.        You should not use the Sites if you do not agree with this Privacy Policy or any other agreement that governs your use of the Sites.

  1.5.        All Sites are owned and operated by Flatsnapp Limited, a company registered in England and Wales under number 09939734 with its registered office at 17 Cavendish Road, London, NW6 7XT, United Kingdom. For the purpose of the Data Protection Act 1998 (the “Act”), Flatsnapp Limited is registered as a data controller under number ZA177943.

     2.        INFORMATION WE MAY COLLECT FROM YOU

  2.1.        We need certain personal information to offer you a superior renting experience, deliver our products and services and keep you informed of developments to our products and services. Some information you give to us directly by filling in forms on our Sites, or corresponding with us through phone, email, web chat or otherwise. Some information we receive indirectly from your devices, by recording how you interact with our Sites (e.g. through cookies). We list below the types of information we may collect from you:

  2.2.        When you create a Flatsnapp account, book a viewing, or otherwise interact with our Sites, we collect the following information:

                     2.2.1.        First and Last Name

  2.2.2.        Title (Mr, Mrs etc.);

  2.2.3.        Email address;

  2.2.4.        Mobile number;

  2.2.5.        Social media account information, if you use a social media plugin to register;

  2.2.6.        Your address;

  2.2.7.        Payment and billing information, e.g. bank account or payment card details;

  2.2.8.        Nationality information, e.g. passport, driver’s license details

  2.2.9.        Employment information, e.g. employer name, job title etc

  2.2.10.        Personal details, e.g. children, pets etc;

  2.3.        If you provide feedback in relation to your visit to a property listed on the Sites, we will process such information for analysis and statistical purposes;

  2.4.        If you engage with another user through our Sites, we may keep a record of that correspondence

  2.5.        If you contact us through the Sites or through any other means, we may keep a record of that correspondence;

  2.6.        Where activated and you have agreed to this on your mobile device, we will collect location data

  2.7.        With regard to each of your visits to the Sites we may automatically collect information about your computer and/or your mobile device, including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

  2.8.        We may also receive information from third parties we work with, which are mainly landlords, agents, credit agencies, government bodies, banks and payment processing companies

     3.        USES MADE OF THE INFORMATION

  3.1.        We may use information you give to us, we collect about you and/or we receive from other sources in the following ways:

                       3.1.1.        to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

                       3.1.2.        in the case of location data, to verify and facilitate your transactions and to tailor content to you (this can be changed at any time in your device settings);

                       3.1.3.        to offer you high quality customer support, for instance to diagnose product problems, rectify erroneous transactions, resolve disputes and provide other customer support related services

                       3.1.4.        to communicate with you via email, SMS text or other electronic media on service-related matters (e.g. viewing notifications) and account related matters (e.g. verifying your identity)

                       3.1.5.        to provide you with information about other goods and services we offer that are similar to those that you have already interacted with or enquired about;

                       3.1.6.        to notify you about changes to our service;

                       3.1.7.        to ensure that content from the Sites is presented in the most effective manner for you and for your device.

                       3.1.8.        to administer the Sites and for internal operations, including management reporting, troubleshooting, data analysis, testing, research, statistical and survey purposes;

                       3.1.9.        to improve the Sites to ensure that content is presented in the most effective manner for you and for your device e.g. clicking behaviour and search results in our app can help us to prioritise new product features

                     3.1.10.        to allow you to participate in interactive features of our service, when you choose to do so; and

                     3.1.11.        as part of our efforts to keep the Sites safe and secure.

                     3.1.12.        to fulfil legal obligations e.g to comply with requests from competent authorities, administrative obligations and in cases involving legal disputes

     4.        STORAGE OF YOUR PERSONAL DATA

      4.1.        The data that we collect from you will be stored on our secure servers within the European Economic Area (“EEA”).

      4.2.        Your personal data is mainly processed by our staff in the United Kingdom. For hosting and maintenance purposes your personal data is located in the United Kingdom.

      4.3.        We may also share data with our affiliates in the context of operating our business, providing our services and other processing purposes as outlined in this Privacy Notice. To the extent any other personal data will be transferred to a country outside the European Union or an international organisation, we will make sure that this only happens to such countries and international organisations that ensure an adequate level of protection, have put appropriate safeguards in place to protect your data and your rights in accordance with the EU privacy law (GDPR), or as is otherwise allowed under the GDPR. If you wish to receive more information of the safeguards we have implemented, please contact our Customer Support team.

      4.4.        Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 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 the Sites; 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.

     5.        DISCLOSURE OF YOUR INFORMATION

      5.1.        We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your feedback (anonymised and without reference to your personal data) with agents and landlords to which such feedback refers for the purpose of improving the customer experience at that property.

      5.2.        We may disclose your personal information to third parties:

                               5.2.1.        To the extent necessary to operate our business, to provide you our services, or our partner services (e.g. agent and landlord services), to complete any related transactions and collect related payments, to provide customer care and to communicate with you in connection with our services. For instance, to process payments and transactions.

                               5.2.2.        To verify that you are suitable for a product or service that you request, e.g. entering into a tenancy contract. For that purpose we may also undertake address validation checks with third party agencies to confirm that you are eligible for a product.

                               5.2.3.        In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

                               5.2.4.        If Flatsnapp Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

                               5.2.5.        If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

                               5.2.6.        Where you gave us explicit consent to do so;

                               5.2.7.        If we are legitimately requested or obliged to do so pursuant to law enforcement, e.g. for investigation of illegal activities;

                               5.2.8.        To enforce our agreement with you, for instance in cases of late and overdue payments, we may share your information with a debt collector;

                               5.2.9.        To enforce our rights towards third parties, or to defend ourselves against any third‐party claims or allegations;

                             5.2.10.        To protect the security, integrity or safety of our Sites.

     6.        RETENTION OF YOUR INFORMATION

6.1.        We will retain your personal information only for as long as is necessary for the purposes for which the information was collected, or as long as is required pursuant to law.

6.2.        If you do not use your account for more than 18 months, we will mark it in our database as “inactive”. We will then no longer actively use your account information, e.g. to inform you on our products and services, but will archive the account to be able to easily reactivate it should you wish to use our services again in the future.

6.3.        In case you wish to close your account, please contact our Customer Support team. Upon closure, we will remove your personal information without undue delay except for information that we are obliged to keep pursuant to law. For instance in order to meet statutory administrative retention obligations, we need to keep some of your account related information (e.g. copies of invoices/receipts), for six years. Data may be retained longer in cases where it is used in relation to a legal claim or is used in relation to a valid legal process.

     7.        YOUR RIGHTS

 7.1.        You have the right to ask us not to process your personal data for marketing purposes.

 7.2.        We will usually inform you 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. You may exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You may also exercise the right at any time by contacting us at team@flatsnapp.com

 7.3.        The Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

     8.        ACCESS AND MANAGING YOUR INFORMATION

  8.1.        You can directly view and edit your personal details via your personal account on the Sites. There, depending on which products and services you use, you can also make choices about our collection and use of your data.

 8.2.        If you cannot access, rectify, or erase certain personal data yourselves, if you want a copy of the personal data that we process of you, if you wish to request a restriction of processing of your personal data or to object to processing, please email Customer Care at team@flatsnapp.com. We will respond to such requests within 30 days. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

     9.        CHANGES TO OUR PRIVACY POLICY

 9.1.        Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

   10.        COOKIES

10.1.        In order to improve the Sites, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this policy as a ‘device’) from the Sites and is stored on your device’s hard drive.

10.2.        A cookie records on your device information relating to your internet activity (such as whether you have visited our website before). The cookies we use on the Sites won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.

 10.3.        How can you control the use of cookies from our website? If you don’t want us to use cookies when you use the Sites, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Alternatively, you can find information about how to do this for all the commonly used internet browsers on the website: http://www.aboutcookies.org/default.aspx. This website will also explain how you can delete cookies which are already stored on your device.

 10.4.        We currently set the following cookies:

                             10.4.1.        Google Analytics and Mixpanel. We use Google Analytics and  Mixpanel which are web and mobile analytics services in order to understand how visitors to the Sites use the Sites. Google Analytics and Mixpanel cookies collect information about how people are using the Sites, for example which mobile pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. The cookies do not gather any information that identifies you. The information these cookies collect is grouped together with information from other people’s use of the Sites on an anonymous basis. Overall, these cookies provide us with analytical information about how the Sites are performing and how we can improve them.

11.        CONTACT

 11.1.        Questions, comments and requests regarding this privacy policy should be sent by email to team@flatsnapp.com