Last modified: 12.04.2021
This website is administered and the service(s) through the website are provided to you by TenantPass OÜ (Estonian registry no. 16126418) (“TenantPass”, “we” or “us”). Here at TenantPass we take privacy and the security of your data seriously and therefore, we kindly ask you to go through this policy carefully so you can better understand how exactly we use your data.
When visiting our website at https://tenantpass.eu (our “Website”) or using any of the services offered via the Website, you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this policy.
Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.
2. Information we may Collect
We may collect and process the following data about you:
Information that you provide to us. You will be asked to provide us with your information when you:
- fill in forms on our Website, or correspond with us;
- register to use our Services, subscribe to our newsletter, promotional emails or other marketing materials;
- use the Services;
- report a problem with our Services; or
- complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
The information you will be asked to provide to us as required for these purposes may include your name, address, previous addresses (up to three years), date of birth, nationality, e-mail address, income, pay slips, references from landlords, phone number, national insurance number, passport number, credit records, personal description and photograph, payment details and banking and open banking information (which includes, but is not limited to, the name, account ID, type, time stamp and amount transacted of your bank transactions), or further information required to verify your identity, rent affordability assessment, provide access to financial and non-financial products.
Information we collect about you. With regard to each of your visits to our Website or our App we may automatically collect the following information; however, this information cannot be used to identify you:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes;
- details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website and App (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs); and
Information we receive from other sources. When using our Services, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services.
If when using our Services you input any personal data of a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
3. How we use Your Information and Justification of Use
We use information held about you (and information about others that you have provided us with) in the following ways depending on whether you are simply visiting our website or ave registered to use our Services as a Tenant or Landlord:
- To provide you with access to our Website any other information which you request from us.
- For marketing products and services that we believe will be of interest to you.
- To notify you about changes to our Services.
- To provide you with the Services, specifically to provide you our Tenant Screening services based on the information you provide to us. This includes using an artificially defined algorithm in order to create your score.
- To administer our Services including payment processing services where necessary and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.
- To administer our Services including Tenant Screening services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.
We will not sell your personal data (or any other data you provide us with) to third-parties, however, we reserve the right to share any data, which has been anonymised and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.
We may use information for marketing products and services to you in the following ways:
- Newsletters and marketing emails relating to our own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.
- To send you details about unrelated services or products or special offers and discounts which are being provided by our selected business partners. Where required by law, we will ask your consent at the time we collect your data to conduct any of these types of marketing.
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.
5. Where we Store your Personal Information
The personal data that we collect from you (including email addresses that form part of our prospective marketing database) is processed in the European Economic Area (“EEA”) and stored on Amazon Web Services Cloud Servers. A full list of our third party sub-processors and details of their privacy policies can be requested. Countries outside the EEA may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the European Commission; or (ii) any organisation which ensures an adequate level of protection in accordance with applicable data protection laws.
We do not disclose your account details. It is your responsibility to keep your password secure. Once we have received your information, we will try to prevent any unauthorised access.
6. Disclosure of your Information
We may also disclose your personal information to third parties in the following circumstances:
- We may disclose your personal information to our service providers and business partners, including payments processors, database tool providers, analytics providers, (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries.
- We also share your personal information with third party payment processor Stripe which manages payment.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of TenantPass, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
- Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies.
- As a Tenant we will share your following personal information with Letting Agents and Landlords: name, email address, previous and current addresses (up to three years), nationality and generated screening reports.
As a Landlord we will share your following personal information with Tenants and Letting Agents: name, email address, bank account information for payments.
As a Letting Agent, we will share your following personal information with Tenants and Landlords: name, email address, bank account information for payments.
7. How Long we retain your Personal Data
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data upon your request. Some personal data may need to be retained for longer to ensure TenantPass can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
8. Changes to this Policy