Privacy Statement
Introduction
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As part of everyday business activities that we carry out, we need to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
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This privacy notice sets out how we will process personal data we collect from or about you, or which you provide to us. Please read this notice carefully to understand why data is being collected and what we do with that data. We may also update the privacy notice from time to time by amending this page.
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Our website and services may contain links to independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies.
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For the purpose of the Data Protection Act 1998 and General Data Protection Regulation EU 2016/679, the data controller is Kinden Limited (We), a company registered in England & Wales under company number 12587609. Our registered address is 30 Circus Mews, Bath, BA1 2PW, and We are registered with the Information Commissioner's Office (ICO) as follows:
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Organisation name: Kinden Limited
ICO Registration Reference: ZA250244
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Our Data Protection Officer is Tina Liu, tina@kindenproperty.com. Any questions relating to this notice and our privacy practices should be sent to tina@kindenproperty.com
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What type of information will we collect from you?
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CLIENTS
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The personal information we collect from our clients or potential clients will typically include the following:
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Full name and contact details (this includes your contact number, email and postal address)
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Information relating to your identity where we are required by law to collect this to comply with the Money Laundering Regulations 2017 and the Immigration Act
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Information on your close connections where we are required to conduct conflicts of interests under regulatory obligations
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Your banking details where required if you engage us to carry out property management activities and we help you to let out a property, for example, so we can set up an approved tenancy deposit account for you and pass on rental payments collected on your behalf
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Details about your areas of interest and requirements of desired property if you engage us in sourcing or finding a property for you
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Your communications with us, including a record of the email or telephone correspondence created when you contact us as part of a product or service query
Where we need to collect personal data by law (for example to meet our obligations to prevent fraud and money laundering) 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 our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case.
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TENANTS & GUARANTORS
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The personal information we collect from prospective or existing tenants:
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From your application for accommodation (also referred to as “offer form”)
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Via emails in support of your application for accommodation
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From information supplied directly or indirectly to us as part of the referencing process
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The information we collect about you includes:
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Prospective tenants, tenants and guarantor names, email address, mobile number, date of birth, address (including any previous addresses, relationship to other prospective tenants, nationality, current or previous passport, driving licence, next of kin, emergency contact, employment status, name of university or college where you are studying (if applicable));
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The employment status of prospective tenants, tenants and guarantors, address, contact details (including email, phone and fax numbers) of the employer/accountant, payroll numbers, length of employment, salary/income information (including any regular overtime or commission), previous HMRC SA302 (if applicable) and any other income received;
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Bank statements of prospective tenants and guarantors to prove income level if unable to verify via employer
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Bank account details of the tenant and prospective tenants, including account number and sort code, to enable us to process any overpaid rent; and
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Any student maintenance loan or grant that prospective tenant or tenant may be eligible for, or are currently receiving.
Unless required to do so by law, we will not share, sell or distribute any of the information you provide to us without your consent.
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Why do we need this information & how it will be used
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CLIENTS
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We will hold and use personal information about you for the following reasons:
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To fulfil our obligations to you when providing you with our property related services
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To share your information with others where necessary to fulfil our property services for you or where acting as agent for a third party on your behalf
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To comply with our statutory and regulatory obligations, including verifying your identity, prevention of fraud and money laundering and to assess your creditworthiness
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To communicate with you during the course of providing our services, for example, in response toyour enquiries and requests
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Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future
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To notify you about changes to our service
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TENANTS & GUARANTORS
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We will hold and use personal information about you for the following reasons:
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to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
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to carry out and perform obligations on behalf of the landlord acting as their property management company
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to enable us to supply you with the services and information which you have requested
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to help you manage your tenancy
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to carry out due diligence on any prospective tenant and/or guarantor, including affordability check, whether there are any money judgments against them, or any history of bankruptcy or insolvency
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to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer
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to contact you in order to send you details of any changes to our suppliers which may affect you
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for all other purposes consistent with the proper performance of our operations and business
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How long we keep your data for
We will retain your personal data for different periods depending on the service you have chosen to use us for. Data may be retained electronically or physically.
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Vendors – clients for whom we have sourced or attempt to source property for, or clients that we manage renovations for. Individual’s data is retained for as long as we have a live service with the vendor, or for 3 years after the termination date of the last service.
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Tenant Applicants - people who have registered their details to become tenants. Individuals’ data is retained for up to 3 years from the last date of communication.
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Landlords – clients for whom we carry out property management which may include the letting of property or attempted letting of a property. Individual’s data is retained for as long as we have a live service with the vendor, or for 6 years after the termination date of the last service.
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Tenants - people that have entered into a rental agreement where we act as the Landlord’s property management company. Individual’s data is retained for up to 6 years after the tenancy end date, this is for the purposes of responding to redress any claims from the tenant or landlord should they materialise later.
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Guarantor of Tenants - emails are retained for up to 6 years after the tenancy end date.
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Sensitive personal information like payslips, bank statements etc. will be retained for 90 days after the end of the tenancy if the tenant has not breached terms of the tenancy agreement. Otherwise, such information is retained until 90 days after the dispute (for example unpaid rent from the tenancy or damages to property during tenancy) is resolved.
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Newsletter subscribers - Data is retained for as long as the individual wishes to be on the newsletter list, until the individual changes their preferences to not receive any further emails. They will be subsequently deleted unless we have a contractual or legal obligation to retain their data. If we have a contractual or legal obligation to retain data, that data will be retained until the legal obligation no longer applies (generally after 6years).
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Who do we share your information with
We will pass your details to the following organisations who carry out certain activities on our behalf as part of us providing our services.
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Name of Third Party
Purposes for Carrying out Processing
Prospective tenants referencing process. We only pass on your name, contact number & email address. All other personal information Vouch holds will be provided directly from you. Please see more at
https://vouch.co.uk/privacy
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Rent payment software provider. We only pass on your name, phone number, email address and bank account details (applicable for certain tenants where overpaid rent is being refunded and for all landlords). We need to pass on this information to be able to collect rent/pay out rent.
https://lettspay.co.uk/privacy
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E-signing service provider. Only name and email address are shared to enable electronic signing of documents.
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Website host and online web chat provider, personal contact information is collected only when you provide through this channel.
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Newsletter subscription management, personal contact information is collected only when you provide through this channel.
Vouch
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LettsPay
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Signable
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Wix
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Mailchimp
We will also pass your details where necessary to your property solicitors and those of the other party to your transaction. We will also disclose your personal information to third parties:
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In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
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If our company or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
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If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
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We do not share your information with third parties for marketing purposes.
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Your rights
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You have the right at any time to:
· ask for a copy of the information about you held by us in our systems;
· require us to correct any inaccuracies in your information;
· make a request to us to delete what personal data of you that we hold; and
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If you would like to exercise any of your rights above please contact us at tina@kindenproperty.com. Please note, 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.
The accuracy of your information is important to us - please help us keep our records updated by informing us of any changes to your email address and other contact details.
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If you signed up to receive content from us or our newsletter via our website, you have the right to unsubscribe at any time or update your information via the links included in every email communication.
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How you can access and update your information
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You have a right to request a copy of the personal information we hold about you, known as a data subject access request. These requests are free of charge and can be sent to tina@kindenproperty.com
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If you signed up to receive contents from us or our newsletter via our website, you have the right to unsubscribe any time or update your information via the links included in every email communication.
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Complaints about the use of your personal data
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If you wish to raise a complaint on how we have handled your personal data, you can contact us at tina@kindenproperty.com
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If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.
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