This website www.landlordtap.com (the “Landlord Portal”) is operated by Landlord Tap Limited of 5th Floor, 30-31 Furnival Street, London, United Kingdom, EC4A 1JQ, also referred to in this policy as “we” or “us”. For an explanation of other defined terms in this policy, please see the Terms of Use. This policy sets out the basis on which we will process information you provide to us or that we collect from you for the purposes of assisting with billing and collecting water and/or waste water service charges, confirming the addresses of Tenants, carrying out duties and functions as a water and/or sewerage undertaker under the Water Industry Act 1991 and other lawful purposes in accordance with Data Protection Legislation.

Please read the following carefully to understand our views and practices regarding information we collect and how we will treat it.

Information about Tenants ("Tenant Information”)

What information we collect

Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised.

We collect personal data about the occupiers and former occupiers of properties that have been let out to tenants (“Tenants”). Landlords or their authorised agents (“Landlords”) provide us with information that helps companies that supply properties with water and/ or sewerage services ("Water Companies") bill effectively for the services they provide. This information includes name, contact details, date of birth, tenancy start and end dates and meter readings.

Water Companies can also submit information on to the Landlord Portal, for example, the last meter reading, which can assist landlords to identify meters in multi-tenancy properties.

How do we use Tenant Information?

We store tenant information on the Landlord Portal and enable Landlords and Water Companies to access and update that information.

The Landlord Portal enables a Landlord user to:

• enter or update data relating to Tenants and the properties they own, or are responsible for; and
• access data inputted by Water Companies (for example, the last meter reading, which can assist landlords to identify meters in multi-tenancy properties).

Tenant Information will be accessible to Water Companies that are authorised by us to use the Landlord Portal. Water Companies will be able to download Tenant Information provided by Landlords, and additionally run search queries with respect to postcode addresses within the Water Company’s geographical area, and within England and Wales generally.

We use a third party provider, IDenteq Ltd to support our operations and improve the Landlord Portal for users. This includes processing of personal data to remove duplicated data from our records and flag when an occupier or tenancy moves, to improve accuracy and data quality and to rectify errors.

Water Companies use the information to help them with billing and collecting water and/or waste water service charges, confirming the addresses of Tenants, carrying out duties and functions as a water and/or sewerage undertaker under the Water Industry Act 1991 and other lawful purposes in accordance with the UK GDPR.

We do not use meter readings or any of the other information we hold to work out how much water individual Tenants have used.

Landlords using Landlord Tap have agreed that they will give Tenants sufficient notice of such processing that complies with the requirements of Data Protection Legislation.

• Privacy FAQ
• https://ico.org.uk/your-data-matters/
• https://ico.org.uk/for-organisations/

Who do we share Tenant Information with?

We will only share Tenant Information when this is permitted by Data Protection Legislation.

We will make Tenant Information available to Landlords, Water Companies and their authorised contractors as described above, but we will not otherwise share Tenant Information with any third party except:

• with third parties where the Landlord has agreed to us sharing this information;
• with enforcement agencies like a regulator, court or the police where we are under a legal, regulatory or professional obligation to disclose the information or to such organisations in order to protect our contractual or other rights, property or safety, or those of others;
• where we, or substantially all of our assets, are merged or acquired by a third party, in which case this information may form part of the transferred or merged assets;
• to a third party service provider that we use to provide services that involve data processing. For example, we contract with an IT supplier to deliver the Landlord Portal and with IDenteq Ltd to improve our services; and
• with our professional advisers (e.g. lawyers), where this is necessary to seek and obtain professional advice or protect our contractual or other rights; and with our insurers, where this is necessary to make or investigate a claim.

Landlords are able to access information that they have entered about their Tenants and the properties they own. They can also access related information that has been inputted by Water Companies (e.g. meter readings).

How long do we keep Tenant Information for?

Landlord Tap will keep Tenant Information for 3 years after the end date of the tenancy.

The supplying Water Company that has access to the tenant information may keep a copy for a different period, in accordance with its own retention policy.

What UK GDPR conditions does Landlord Tap rely on to process Tenant Information?

Under article 6 of the UK GDPR, processing of personal data shall only be lawful if a 'legal basis' for processing applies. The legal basis for processing general data (that is data that is not categorised as 'special category data' such as health data, racial or ethnic origin, political opinion etc) are:

• consent;
• performance of a contract;
• legal obligation; and
• legitimate interests.

For Tenants served by a Water Company delivering services in England, Landlord Tap relies on the legitimate interests condition (article 6.1(f)). For Tenants who are served by a Water Company delivering services wholly or mainly to Wales, Landlord Tap relies on the public task condition (article 6.1(e)). The legitimate interest/ public task pursued by Landlord Tap is the effective and correct billing of Tenants for water and sewerage services they have used.

You can find out more information about the UK GDPR conditions and why they are important here.

Information about Users of the Landlord Portal (“User Information”) and Landlords

What information we collect

What information we collect about a website user depends on whether they are a “Registered User” of the Landlord Portal. Registered Users, like Landlords and Water Companies, have a Landlord Tap account that enables them to access information held on the Landlord Portal. For users of the Landlord Tap website we will collect:

• for Registered Users only, information provided by the Registered User when they register to use the Landlord Portal, or when they report a problem with the Landlord Portal or otherwise correspond or communicate with us including the Registered Users' name and login details, email address, telephone number and any other contact details provided, and where relevant, the Registered Users' property portfolio details;
• for all users (including website users) technical information, including your Internet protocol (IP) address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• for all users (including website users) information about your visit to and use of the Landlord Portal, including the full Uniform Resource Locators (URL) clickstream to, through and from the Landlord Portal (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page.

We also collect information about individual landlords from their authorised agents (“Individual Landlord Information”). The individual landlord may not access the Landlord Portal themselves, but their personal information will be entered by a Registered User on their behalf. We will collect the landlord's name, property portfolio details and contact information.

How we use User and Landlord Information

We use User Information in the following ways:

• to provide access to and use of the Landlord Portal, including giving Registered Users access to relevant Tenant Information;
• for internal operations including data analysis, audit management, testing, research, statistical and survey purposes and to keep the Landlord Portal safe and secure;
• to improve the Landlord Portal and notify you about changes to the Landlord Portal or our service; and
• to ensure that content from the Landlord Portal is presented in the most effective manner for you and for your computer.

We use Individual Landlord Information in the following ways:

• enter or update data relating to landlords and the property they own; and
• access data inputted by Water Companies.

Who do we share User Information and Individual Landlord Information with?

We will only share User Information and Individual Landlord Information when this is permitted by the UK GDPR and Data Protection Legislation.

We will not share Tenant Information, Individual Landlord Information or User Information with any third party except:

• with Water Companies to facilitate the operation of Landlord TAP and effective billing;
• with enforcement agencies like a regulator, court or the police where we are under a legal, regulatory or professional obligation to disclose the information or to such organisations in order to protect our contractual or other rights, property or safety, or those of others;
• where we have concerns that a Registered User is not using the Landlord Portal appropriately, we may report this to any organisation on whose behalf the Registered User appears to act. This might require us to share certain user information but where possible we will pseudonymise or anonymise the data;
• where we, or substantially all of our assets, are merged or acquired by a third party, in which case this information may form part of the transferred or merged assets;
• to a third party service provider that we use to provide services that involve data processing. For example, we contract with an IT supplier to deliver the Landlord Portal and with IDenteq Ltd to support our operations and improve the portal; and
• with our professional advisers (e.g. lawyers), where this is necessary to seek and obtain professional advice or to protect our contractual or other rights; and with our insurers, where this is necessary to make or investigate a claim.

How long do we keep User Information and Individual Landlord Information for?

User Information will be stored for 7 years from the date of the last activity on the Registered User’s account, after which User Information will be deleted.

What UK GDPR conditions does Landlord Tap rely on to process User Information and Individual Landlord Information?

Registered Users' contact details and login information

Lawful basis for processing: where you provide us with your personal information when accessing and using the Landlord Portal, we rely on your consent as the lawful basis for processing.

In other instances, where you have not given explicit consent, the lawful basis to use your personal information is that it is necessary for the management and administration of your contract with us and to allow us to meet our obligations.

It is also a legitimate interest of ours to keep various information about you which will allow us to respond to your correspondence and engagement, and to improve our service and the Landlord Portal for you and others.

Users' technical information

Lawful basis for processing: it is a legitimate interest of ours to keep various information about you which will allow us to improve the Landlord Portal and ensure that Users' are able to properly access our services.

We will monitor our network and your use of it. It is a legitimate interest of ours to make sure that your use of our network and systems does not compromise our network and systems security.

Information about Users' visit to and use of the Landlord Portal

Lawful basis for processing: it is our legitimate interest to measure the effectiveness of the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). This allows us to ensure the effective running of our business (including our website) and deliver a better service to our users.

We gather data about you which is useful for building a complete view of Users' use of our website, products and services including management of any account created by the customer on our website. This includes understanding our Users' behaviour, activities, preferences and needs. This helps to ensure the effective running of our business through the development, improvement and provision of services which meet User needs and expectations.

Individual Landlord Information

Lawful basis for processing: For landlords with property served by a Water Company delivering services in England, Landlord Tap relies on the legitimate interests condition (article 6.1(f)). For the landlords of properties which are served by a Water Company delivering services wholly or mainly to Wales, Landlord Tap relies on the public task condition (article 6.1(e)). The legitimate interest/ public task pursued by Landlord Tap is the effective billing for water and sewerage services.

Transferring your personal information outside the United Kingdom

We will not transfer your personal information outside the UK unless such transfer is compliant with the UK GDPR. This means that we cannot transfer any of your personal information outside the UK unless:

• the UK government has decided that another country or international organisation ensures an adequate level of protection for your personal information or the data is being transferred to a company in the US which has signed up to the UK-US data bridge; or
• the transfer of your personal information is subject to appropriate safeguards, which may include:
  • binding corporate rules; or
  • the International Data Transfer Agreement or the UK Addendum.
• one of the derogations in the UK GDPR applies (including if you explicitly consent to the proposed transfer).

Links to Third Party Websites

The Landlord Portal may contain links to third party websites. If you follow a link to any third party website, please be aware that these websites have their own privacy policy and that we do not accept any responsibility or liability for their policies.

Changes to Our Policy

This policy may be amended by us at any time. Please check this page periodically to inform yourself of any changes.

Your rights

Under the UK GDPR, you have a number of rights:

• you have the right to request access to the personal data that Landlord Tap holds about you.
• you have the right to request that Landlord Tap correct any personal data it holds about you that is inaccurate or misleading.
• you have the right to request that Landlord Tap delete any personal data it holds about you.
• you have the right to request that the processing of any personal data Landlord Tap holds about you is restricted.
• you have the right to object to Landlord Tap holding any personal data about you.
• you have the right to request a copy of the information that Landlord Tap holds about you in a machine-readable format or for Landlord Tap to provide it to a third party (the right to data portability).

A number of these rights can only be exercised in certain situations. You can find out more about your rights under the UK GDPR and when you can exercise them through the Information Commissioner’s Office (ICO).

Arrangements with the Water Companies

Landlord Tap works with Water Companies to ensure that it provides the information that Water Companies need to help bill Tenants for the services they receive.

Landlord Registered Users are responsible for providing Tenants who they upload information about with sufficient notice of how we and the Water Companies use the Tenant Information held in Landlord Tap. We work with Landlords to ensure that Tenants are provided with this information.

Water Companies are responsible for ensuring that individuals who are the subject of information they upload to Landlord Tap have been given sufficient notice of how we and the Water Companies use the Tenant Information held in Landlord Tap.

Landlord Tap is responsible for responding to any requests to exert rights about information that is held in Landlord Tap.

Water Companies are responsible for responding to requests to exert rights about information they hold on their own systems, including information that has been downloaded from Landlord Tap. Water Companies are responsible for the use of any data they download from Landlord Tap and ensuring this complies with data protection rules.

Queries or requests relating to personal data held on Landlord Tap should be made to Landlord Tap, using the contact details below. Queries or requests relating to personal data held on Water Company systems should be made to the relevant Water Company.

Queries, requests and concerns

If you have any questions, want to exercise your data protection rights or need further information about our privacy practices, or would like to let us know that your details require updating, please contact us at privacy@candc-uk.com.

If you are not happy with the way that we have dealt with your personal data or a request from you to exercise any of the rights listed above, you can lodge a complaint with us and we will review your case. You can do this by writing to Landlord Tap Ltd., Fifth Floor, 30-31 Furnival St, London EC4A 1JQ or by email to paul.allen@landlordtap.co.uk

If you have any issues with our processing of your personal information and would like to make a complaint, you may contact the ICO:
Website: https://www.ico.org.uk/concerns
Tel: 0303 123 1113

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF