PRIVACY POLICY

  1. INTRODUCTION

Housing Partners Limited, an MRI Software Company, are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the General Data Protection Regulation (GDPR) and other UK data protection laws (Data Protection Laws) that apply from time to time, the data controller is Housing Partners Limited of Whittington Hall, Whittington Road, Worcester, Worcestershire WR5 2ZX (company number 04667857).

  1. INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

  • Information You Give Us. You may give us information about you by filling in forms on our site, by registering with us or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, e-mail address, physical address, organisation, phone number, product interest, date of birth, gender, dependents’ names and contact information, financial information, property information and – where relevant to the HomeSwapper service – details about your health (for example because your property contains accommodations for your physical health).
  • Information We Collect About You From You. We may also collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for, 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 and any phone number used to call our customer service team; and
    • information about your use of the HomeSwapper service.
  • Aggregated Data and Statistics. We may use aggregate data and statistics for the purpose of monitoring the site usage in order to help us develop the site and our services.  We may provide such aggregated data to third parties for adverting or other purposes.  The statistics will not include information that can be used to identify any individual.
  1. USES MADE OF THE INFORMATION

We use information held about you in the following ways and on the associated lawful grounds for processing as set out below.  The lawful grounds that we utilise are:

  1. Our processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms (Legitimate Interests). Those legitimate interests are set out below where we indicate that Legitimate Interests is the relevant lawful ground.
  2. You have provided consent for us to process your personal data for a specific purpose including, in relation to any details about your health, your explicit consent (Consent).
  3. Our processing is necessary for the purpose of providing the HomeSwapper service to you, where you have signed up to that service (Contractual Necessity).

Information You Give Us

Purpose

Ground for Processing

To enable us to tell you about products and services that you have asked us to tell you about and to contact you if we need to obtain or provide additional information

Consent

To enable us to provide the HomeSwapper service to you, where you have signed up to that service

Contractual Necessity

 

Information We Collect About You From You

Purpose

Ground for Processing

To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

Legitimate Interests

To improve our site to ensure that content is presented in the most effective manner for you and for your computer

Legitimate Interests

As part of our efforts to keep our site safe and secure

Legitimate Interests

 

  1. COOKIES

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

You can look in detail and adjust your cookie settings on our Cookie Policy page.

  1. DISCLOSURE OF YOUR INFORMATION

We may share your personal data 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 from time to time disclose your information to the following companies or organisations who may support as a partner practitioner in the delivery of our services: National Practitioner Support Service (NPSS).

We disclose your personal data to the following service providers, each of whom is under contractual duties to comply with the law and put in place measures to keep your data safe:

Service Provider

Purpose of Processing

Microsoft (Ireland and the Netherlands)

Used to store your information

Tewkesbury Printing Company (UK)

Used to print resident lists for some MRI customers

Twilio (UK)

SendGrid (a Twilio product) used to provide messaging between HomeSwapper users

Salesforce (EU)

Supports the provision of a help desk/customer service solution for HomeSwapper customers.  If you call or email us, your details will be included in Salesforce so we can keep track of our conversations with you.

Experian (UK)

To process, verify and append data as per the terms of service. To compile credit reports that may be supplied to potential landlords to whom you apply.

Thoughtfocus (the Philippines)

Supports the provision of Housing Partners products to provide telephone and chat-based support for customers.

 

We may transfer or share your personal data with third parties that process your personal data in a country outside the European Economic Area (EEA) and the UK, but we will only do so if:

  • We have a data transfer agreement in place with the third party containing the standard data protection clauses as required by the Data Protection Laws (a copy is available here) (we use this mechanism for transfers to the Philippines for outsourced support); or
  • The relevant country in which the third party recipient is located is subject to a current adequacy decision.

We may share your personal data with selected third parties (on the basis of Legitimate Interest) including:

  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

  • For our Legitimate Interests, 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.
  • For our Legitimate Interests, if Housing Partners 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.
  • Either for our Legitimate Interests or if the sharing is necessary for compliance with a legal obligation to which we are subject: where we are under a duty to disclose to, or it is otherwise desirable to do so in order to preserve the relationship between us and, a regulator, tribunal or local or central government body.
  1. HOW LONG WE KEEP YOUR INFORMATION FOR

We will keep your personal data only for as long as necessary to fulfil the purposes we collected it for. Where you have registered to use HomeSwapper then we will keep your data (unless you request otherwise) for twelve (12) months after you are deactivated for use on the service. This retention enables the HomeSwapper website to re-present a tenant registrant with their information if they decide to try the service again after they have stopped using it. This will avoid a tenant registrant having to complete all their registrant details again.

After the elapse of the retention period, your data will be deleted or anonymised.

  1. YOUR RIGHTS

You have a number of rights relating to your personal data pursuant to the Data Protection Laws including:

  • The right to rectification or erasure of your personal data*;
  • The right to restrict or object to certain processing of your personal data;
  • The right to portability of your personal data;
  • The right to request appropriate copies (which may contain redactions) of any data transfer clauses or certification mechanisms that allow the transfer of your personal data outside of the European Economic Area;
  • Where we are relying on your consent to process your personal data, the right to withdraw consent at any time;
  • The right to lodge a complaint with the Information Commissioner’s Office in the UK (contact details available at https://ico.org.uk/global/contact-us/) or other applicable supervisory authority; and
  • The right to ask for a copy of your personal data.

*If you wish to exercise a right granted to you under the data privacy laws applicable to you (e.g. to request the deletion of your data) please contact dataprotection@housingpartners.co.uk

Our site 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.

  1. CHANGES TO OUR PRIVACY POLICY

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 e-mail. Please check back frequently to see any updates or changes to our privacy policy.

  1. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: The Data Protection Officer, Housing Partners Limited of Whittington Hall, Whittington Road, Worcester, Worcestershire, WR5 2ZX.

Updated July 2023