Upad, a trading name of Howsy Limited ("Upad", "we", "us" and "our" in this policy) respects your privacy and is committed to protecting your personal data.
This privacy policy tells you how Upad ,uses and handles your personal data when you visit our website www.upad.co.uk (our “website”) or use our services and your privacy rights in relation to it.
It is important that you read this privacy policy together with any notice we may provide on specific occasions when we collect or process personal data about you, so you are fully aware how and why we are using your data.
1. THE DATA WE COLLECT ABOUT YOU
1.1 We may collect, use, store and transfer different kinds of personal data about you depending on whether you are a landlord, tenant or a guarantor as set out below:
1.2 We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered to be personal data under data protection laws as it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.
1.3 We collect the data listed in section 1.1 above in different ways, including through:
1.4 If you fail to provide personal data
If we need to collect personal data in order to comply with law or in order to provide the services you have requested,
and you fail to provide this data when requested, we may not be able to provide you with our services or access to membership functions.
In this situation, we may need to cancel the contract for services, but we will tell you if this is the case
2. HOW WE USE YOUR PERSONAL DATA
2.1 We will only use your personal data for specific purposes as detailed below. In order to use your personal data for these purposes, we must have a legal basis for doing so. will only use your personal information where it is necessary:
Where none of the above applies, we will request your consent (which we will ask for before we process the personal data).
2.2 The table below sets out all the ways in which we will use your personal data, which of the legal bases we rely on to do so and, where relevant, what the legitimate business interests are. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us [email protected] if you want to know which specific legal ground we are relying on where more than one ground is set out in the table below.
| Purpose/activity | Type of data | Lawful basis for processing, including legitimate interest |
| To register you as a member | Identity and contact data | Performing a contract with you Our legitimate business interests to |
To provide services to you if you are a landlord, such as:
|
Identity and transaction data |
Performing a contract with you Our legitimate business interests (to assist with renting your property) |
To provide services to you if you are a tenant:
|
Identity, contact, financial, transaction and account data |
Performing a contract with you Our legitimate business interests (to assist with your property interest) |
| In support of a tenant’s application if you are a guarantor | Identity, contact, financial, transaction and account data | Our legitimate business interests (to process the tenant’s application) |
To manage our relationship with you, including:
|
Identity, contact, account and marketing and communications data |
Performing a contract with you Complying with our legal or regulatory obligations Our legitimate business interests (keeping our records up-to-date, studying how customers use our services) |
| To enable you to participate in a prize draw, competition or survey | Identity, contact, account, usage and marketing and communications data |
With your consent Our legitimate business interests (studying how customers use our services, develop our services, and grow our business) |
| To send you newsletters, publications or other marketing communications | Identity, contact, account, usage and marketing and communications data |
With your consent Our legitimate business interest to send you marketing and promotional materials from time to time or with your consent. If we send you a marketing email, it will include details on how to unsubscribe from receiving similar marketing messages in the future. You can also manage your information and update your marketing preferences by sending an email to [email protected]. |
| Third party data processors who may contact you by email or telephone. | Identity, contact |
With your consent
Your data may be shared with third party data processors who may contact you by email or telephone depending on the level of consent you have given. |
| To administer, organise and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data) | Identity, contact, transaction and technical data |
Our legitimate business interests (running our business, providing administrative and IT services, network security, preventing fraud, for a business reorganisation or group restructuring)
Complying with our legal or regulatory obligations |
| To conduct data analytics to improve this website and our services | Technical and usage data | Our legitimate interests (keeping our website up-to date and relevant, developing our business and informing our marketing strategy) |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you of this and seek your consent if necessary.
3. SHARING YOUR PERSONAL DATA
3.1 We may share your personal data with the parties set out below for the purposes set out above:
3.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Except as set out in clause 5.1 that the third party may use your data as a controller, we only disclose the personal data to each of these third parties to the extent they need it in order to provide or perform the specified purposes, and do not allow any of our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
4. DATA SECURITY
We implement appropriate technical and organisational measures to protect personal data that we hold from unauthorised disclosure, use, alteration or destruction. Our servers are encrypted and any payments which we take or manage will be made on PayPal secure servers or Barclays Merchant Account which use Secure Socket Layer (SSL) encryption technology to protect payment information. We also require our service providers to comply with strict data privacy requirements.
5. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
5.1 The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for legal or regulatory compliance). We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected.
5.2 In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
6. YOUR LEGAL RIGHTS
6.1 Your rights - practicalities
In certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below. If you wish to exercise any of these rights, please contact us [email protected].
We may need to ask you for specific information to help us confirm your identity and to ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure your personal data is not disclosed to anyone who is not entitled to receive it. We may also ask you for further information in relation to your request, in order to assist with our response.
We try to respond to all requests within one month. Occasionally it may take us longer than a month to respond, if your request is particularly complex or you have made a number of requests; we will let you know within a month if this is the case, and will keep you updated on the status of our response.
6.2 Rights
You may have some or all of the following rights in respect of the personal data about you that we process:
6.3 Changes to this privacy policy
This version was last updated on 15 June 2018. Earlier versions can be obtained by contacting us.
We may change this privacy policy from time to time and any changes will be posted on this page and, where appropriate, notified to you by email.
6.4 Third party links
This website 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 parties or their websites, and are not responsible for their privacy policies. When you leave our website, we recommend that you read the privacy policy of every website you visit and every plug-in or application you use.
6.5 Contact details
Upad, a trading name of Howsy Limited
Email address: [email protected]
Postal address: 27-33 Bethnal Green Road, London, E1 6LA
[Telephone: 0333 240 1220]
You have the right to complain at any time to the Information Commissioner’s Office (ICO), which is the UK’s supervisory authority for data protection issues (www.ico.org.uk). You also have the right to seek redress from a court. We would however appreciate the chance to deal with your concerns before you approach the ICO, please do contact us in the first instance.