Privacy Policy
Houso Limited
We take your privacy very seriously. This privacy notice will inform you as to how we look after your personal data when you visit our website www.houso.co.uk (“our Website”) (regardless of where you visit us from), when you use the Houso App, and when you correspond with us by email or otherwise. It tells you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Houso Limited collects and processes your personal data when you use the Houso App, and when you correspond with us by email or otherwise.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
Houso Limited (“we”, “us”, “our”) is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. You will find our contact details at the end of this privacy notice (see below: “How to contact us”).
PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is any information relating to an identified or identifiable individual.
We collect, use, store and transfer different kinds of personal data about you, depending on our relationship with you. This may include:
• full name;
• date of birth/age;
• postal address;
• email address;
• financial status – i.e. whether you are a cash buyer, you have a mortgage approved or pending or you are just browsing;
• telephone numbers (mobile or landline);
• a unique identification number for you;
• your property status – i.e. whether your property is on or off the market;
• the address and price of the property you are selling and any other information about the property to the extent that it is your personal data;
• information about the property you would like to buy, such as location and price and any other information to the extent that it is your personal data;
• legal documentation and other documentation that you volunteer about the property you currently own, such as Land Registry documents to the extent that it is your personal data;
• land Registry property ownership confirmation;
• properties you add to your favourites list;
• your viewing availability and viewing appointments you have made or received;
• messages between you and other buyers and sellers;
• offers to buy properties you have made or received;
• number and location of properties you have visited;
• your photograph;
• your transaction information;
• feedback/reports from other customers;
• technical information from when you use the Houso App, including your location and IP address;
• job title;
• business name;
• name of your employer or the organisation you represent;
• marketing and communications information; and
• information that you volunteer to us when you correspond with us by email or otherwise.
We also collect, use and share aggregated data, such as property search parameters applied by you, any property you book to view, feedback you provide on properties and any offers you make. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
If you do not provide personal data
For individual customers or suppliers, where we need to collect personal data to enter into a contract with you and you fail to provide that data when requested, we may not be able to enter the contract with you. This data may include your name, email address and contact number. For individual customers, if you thereafter do not provide the personal data we ask for, this may limit the functionality of the Houso App. For example, if you do not provide your email address, you will not be able to view properties.
HOW YOUR PERSONAL DATA IS COLLECTED
Depending on the circumstances, we use different methods to collect personal data from and about you including:
• Directly from you. You may give us your personal data by corresponding with us by email or otherwise, or when you use the Houso App;
• Automated technologies or interactions. As you interact with the Houso App, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using technology such as website cookies and those similar to website cookies.
• Other sources. We may receive personal data about you from various sources as set out below:
• technical data from analytics providers;
• transaction data from providers of technical and payment services; and
• from an employee or representative of the organisation for whom you work.
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we or a third party have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and our lawful basis for doing so.
What we use your personal data for Our lawful basis for processing data
For individual customers with whom we have contracts – to provide our products and services to you
Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you.
For individual suppliers with whom we have contracts e.g. for corresponding with you about the products or services you offer, to obtain a price quote and to take steps under the contract with you
Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you
For individuals who work for or represent our corporate suppliers (or prospective corporate suppliers) e.g. for corresponding with you about the products or services your organisation offers, to obtain a price quote and to manage the contract with the organisation you work for or represent
Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues and to manage the contract with the organisation you work for or represent
To manage our relationship with you, or the organisation which you work for or represent, which will include (where appropriate) notifying you about changes to our terms of business or privacy notice or dealing with complaints
Necessary to comply with our legal obligations
Necessary for our legitimate interests i.e. to manage our relationship with you or the organisation you work for or represent, and to analyse and improve the products or services we offer
To prevent and detect fraud against you or us Necessary for our legitimate interests or those of a third party i.e. to minimise fraud that could be damaging for us and for you
Other processing necessary to comply with legal and regulatory obligations that apply to our business or as otherwise permitted or required by law
Necessary to comply with our legal obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
Necessary to comply with our legal obligations
Ensuring business policies are adhered to e.g. policies covering data security
Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures so we can deliver the best service to you or the organisation you work for or represent
Operational reasons, such as improving efficiency, training and quality control
Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price
Ensuring the confidentiality of commercially sensitive information Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party i.e. to protect commercially valuable information
Statistical analysis to help us manage our business e.g. in relation to our financial performance, customer base or other efficiency measures
Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price
Preventing unauthorised access and modifications to systems Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to prevent and detect criminal activity that could be damaging for us and for you or the organisation you work for or represent
Updating and maintaining customer and supplier records Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to make sure we can keep in touch with our customers and other contacts
Staff management and administration Necessary for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service we are able to
External audits for the audit of our accounts
Necessary to comply with our legal obligations
To make suggestions and recommendations to you about third parties who may be able to assist you in buying or selling your home or moving house
Necessary for our legitimate interests or those of a third party e.g. to assist our customers
To enforce or apply our App terms and conditions or any other agreements
Necessary for our legitimate interests or those of a third party e.g. to enforce our legal rights and protect our business
To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests e.g. for running our business, provision of administration and IT services, network security and to prevent fraud
Necessary to comply with our legal obligations
To use data analytics to improve our products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests e.g. to define types of customers for our products and services, to develop our business and inform our marketing strategy
To enable the Houso App to e.g. provide relevant property listings, auto-complete address suggestions and location lookups based on distance parameters, enable customers to arrange viewing appointments and confirm property ownership Your consent
For security reasons (photographs) Necessary for our legitimate interests or those of a third party e.g. to ensure potential sellers have a photograph of potential buyers attending viewings
Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please email or write to us (see below: “How to contact us”).
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Marketing communications
We may use your personal data to send you periodic communications by email, post and text about our products and services.
We have a legitimate interest in processing your personal data for marketing purposes. This means we do not usually need your consent to send you information about our products and services. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• emailing info@houso.co.uk;
• writing to us at Houso Limited, Windover House, St Anne Street, Salisbury, SP1 2DR;
• using the ‘unsubscribe’ link in our emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.
Third party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
App technology
The Houso App stores a unique user token on your device that is used by our server to authenticate that it is you who is using the Houso App.
The Houso App may request access to:
• the camera/photograph library on your device for adding a profile picture and property images and videos;
• your current location when performing a search for property listings; and
• the calendar on your device in order to add viewing appointments.
You will need to provide your consent to allow the Houso App access to your device. However, if you do not allow the App access to your device, then you should be aware that this will limit the functionality of the Houso App.
Cookies used on our site
Cookie – Universal
Analytics (latest
version) What we use them for
_ga This is used by Analytics to calculate visitors, session, campaign data, etc. Expiration time is set to two (2) years and it resets each time when a visitor hits a page. No personal information or data is stored. Used to distinguish users. This cookie enables us to estimate our audience size and usage pattern
See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_gat Described by Google as “Used to throttle request rate”(no more information is available about this cookie). Expires in one (1) minute. This cookie enables us to limit the number of times information is recorded.
See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_gid This is used to distinguish users but has a 24 hours expiration time.
See weblink below:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
How to manage cookies
Our cookies do not store financial information, or information which is capable of directly identifying you (such as your name or address). Cookies simply allow our website to retrieve this information in order to personalise and improve your experience of our website.
However, if you wish to restrict, block or delete cookies provided by our site, or any other website, you can use your browser to do this. Each browser is different so check the “Help” menu of your particular browser to learn how to change your cookie preferences, or use the following weblinks:
Microsoft Internet Explorer
Help: http://support.microsoft.com/?ln=en-gb
How to manage Cookies in IE 11:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox
Help: http://support.mozilla.org/en-US/home?as=u
Cookies: http://support.mozilla.org/en-US/kb/Cookies?s=manage+cookies&r=0&e=es&as=s
Google Chrome
Help: http://support.google.com/chrome/?hl=en-GB
Manage Cookies: http://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
Our analytics partner also provides the ability for users to opt-out using the following links:
Google Analytics:
https://tools.google.com/dlpage/gaoptout
Further information on cookies is available online at: www.aboutcookies.org
Please bear in mind that if you do this, certain personalised features of this website and others cannot
be provided to you.
Third Party Cookies
To help improve your experience of our site we use content from other sites to help users and improve usability for example Google Maps for store locators. We also use social sites such as Facebook and Twitter to allow businesses to communicate with their clients along with analytics to help improve user experience. We do not control these social media websites and we suggest you read their cookie policy to see which ones they use and how to manage them.
Third-party cookies What their cookies are used for
Google We use Google Maps to show our location.
Googles privacy policy:
http://www.google.co.uk/intl/en/policies/privacy/
Social Tools We take advantage of social networks and like to share our content with friends across these networks, such as twitter, you may receive cookies from these websites. We are not in control of these third-party cookies, if you’d like to learn more about them – visit their websites.
Facebook https://www.facebook.com/privacy/explanation
Twitter https://twitter.com/en/privacy
YouTube https://www.youtube.com/static?gl=GB&template=terms
WHO DO WE SHARE YOUR PERSONAL DATA WITH
Depending on the circumstances, we may share your personal data with:
• External service providers we use to help run our business e.g. email service provider and IT providers;
• Professional advisers including lawyers, bankers, insurers, auditors, technical consultants and experts;
• SendGrid (https://sendgrid.com/) to provide delivery of transactional emails;
• OneSignal (https://onesignal.com/) to provide delivery/reporting of in-App notifications;
• Google (https://developers.google.com/maps/documentation/geocoding/start) to geocode property locations;
• GetAddress (https://getaddress.io/) to provide autocomplete address suggestions;
• The Land Registry to confirm property ownership; and
• If you are one of our referral partners who may be able to assist our customers with, for example, moving house, we may share your personal data with our customers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.
TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Some of organisations with whom we share your personal data are based outside the European Economic Area (EEA) (which comprises the countries in the European Union and Iceland, Liechtenstein and Norway) so their processing of your personal data will involve a transfer outside of the EEA.
These transfers are subject to special rules under European and UK data protection law.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to your data by ensuring one of the following (or one of the other grounds set out in data protection law) applies:
• your data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• the transfer is necessary for the performance of a contract between you and us;
• the transfer is necessary to establish, exercise or defend legal claims;
• there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of European Commission approved contractual terms); or
• you have provided explicit consent to the proposed transfer after being informed of any potential risks.
Please contact us (see below: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?
Data protection law gives you certain rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your data:
Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
To be forgotten In certain situations, the right to require us to delete your personal data
Restriction of processing In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data
Data portability In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation
To object The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests
We do not use personal data for automated decision making.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email or write to us (see below: “How to contact us”) and let us have enough information to identify you e.g. your full name and address and unique identification number as well as what right you want to exercise and the personal data to which your request relates.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including;
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records of products registered by you; and
• to keep records required by law to comply with our legal obligations.
We will not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.
KEEPING YOUR PERSONAL DATA SECURE
We have put in place reasonable and appropriate security measures to endeavour to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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 Houso App; any transmission is at your own risk.
The Houso App 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 policies. When you leave the Houso App, we encourage you to read the privacy notice of every website you visit.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email or write to us (see below: “How to contact us”). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the UK’s supervisory authority, the Information Commissioner’s Office (ICO). Further information about how to make a complaint to the ICO can be found on the ICO website www.ico.org.uk.
The EU General Data Protection Regulation also gives you right to lodge a complaint with the supervisory authority in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred.
CHANGES TO THE PRIVACY NOTICE
This version was last updated in July 2019.
We may change this privacy notice from time to time and when we do so, we will inform you via the Houso App and our Website. If any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable endeavours to notify you of the changes in advance by email or by alternative means.
CHANGES TO YOUR PERSONAL DATA
Please let us know if you change your name, address or any other personal detail (see below: “How to contact us”).
HOW TO CONTACT US
If you have any queries about this privacy notice or how we use your personal data, you can contact us by post or email as follows:
Houso Ltd
Windover House,
St Anne Street
Salisbury
SP1 2DR
info@houso.co.uk
Do you need extra help?
If you would like this notice in another format (for example large print) please contact us (see above: “How to contact us”).