Privacy Policy

This version effective from 1 May 2021.

OPTUS HOMES values your trust, particularly when it comes to your personal data.

This policy explains what data, including personal data, we collect from and about you when you use:

• The Optus Tenant App mobile application software provided by Optus (the App) on behalf of the person or company with whom you have a tenancy agreement (the Landlord). 
• Any of the services accessible through the App (Services).

We appreciate there’s a lot of detail, but it’s important that you read this policy to ensure you’re fully informed about how we use your personal data and your rights.

We may need to make changes to this policy occasionally, to reflect any changes to our services or legal requirements. We’ll notify you of any important changes via the App or by email before they take effect.

If you’ve got any questions about this policy, please email us at info@optus-homes.com

Who we are

We are Optus Homes Ltd, a limited company registered in England and Wales under company number 12429269. Our registered address is 56 Ashleigh Avenue, Egham, England, TW20 8LA.

Under UK data protection law, we are acting as a ‘processor’ of your personal data on behalf of your Landlord, who will be acting as a ‘controller’ of your personal data.

The personal data we collect

When we talk about ‘personal data’, we mean any data that identifies or can be used to identify you. This doesn’t include data where your identity has been removed (anonymous data). The types of personal data collected by and about you through our Website and App include:

Biographic data: When you first use the app, you may be asked for information such as your first and last name, month and year of birth, gender, profile image (optional) and email address.

Contact data: We ask you for your name and email address when signing up to use the App

Survey data: When you use the App, you may be asked to complete questionnaires or surveys related to the Services by us, or by your Landlord

Communications data: This includes any emails that you send to us and the information you communicate to, and receive from, your Landlord whilst using the Services

Transactions data: We don’t store or have any access to your credit or debit card details when you use the App to carry out any transactions using the Services, however we can see details of your transactions

Technical data: Our App uses cookies (see below) which collect the IP address assigned to you or someone who provides you with Internet access (although this is anonymised at the earliest possible opportunity), information about your device (including type, operating system, browser, resolution and time zone setting), which country you’re based in, and how you interacted with the content on our App and the Services

Where we get your personal data from

As long as you are using our App or the Services, we will only collect your personal data from you, or your Landlord.

What we use your personal data for

This section is really important as it explains what we’ll use your personal data for, and the legal grounds relied on by us for those purposes.

Under UK and EU data protection law there are six legal grounds that we may rely upon, the most relevant being where:

• you’ve given your consent to us using your personal data for specific purposes
• use of your personal data is necessary for us to enter into and perform our contract with you
• use of your personal data is necessary to comply with any legal obligation on us
• use of your personal data is necessary to pursue our legitimate interests and those interests are not outweighed by your fundamental rights and interests

We collect the following types of personal data, for the following purposes, using the following lawful grounds for processing the personal data:

• To install the App and register you as a new App user – we may collect Identity, Contact, Financial and Device data, based on the following lawful basis for processing: your consent.
• To deliver Services including communicating with your Landlord – we may collect Identity, Contact, Financial, Transaction, Device, Marketing and Communications, and Location data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to recover debts due to us).
• To manage our relationship with you including notifying you of changes to the App or any Services – we may collect Identity, Contact, Financial, Profile, and Marketing and Communications data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services; necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
• To enable you complete a survey – we may collect Identity, Contact, Device, Profile, and Marketing and Communications data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business).
• To administer and protect our business and this App including troubleshooting, data analysis and system testing – we may collect Identity, Contact and data – based on the following lawful bases for processing: necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).
• To deliver content and advertisements to you; To make recommendations to you about goods or services which may interest you; To measure and analyse the effectiveness of the advertising we serve you; To monitor trends so we can improve the App – we may collect Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, and Location data – based on the following lawful bases for processing: your consent; necessary for our legitimate interests (to develop our products/Services and grow our business).

We may use your personal data for purposes which are closely related to any of the above purposes. If we want to use your personal data for any unrelated purposes, we’ll let you know about this in advance.

Who we share your personal data with

We don’t sell your personal data for marketing purposes and we never will.

We share your personal data with your Landlord. Your Landlord will collect, use and process your data in accordance with the Landlord’s own privacy policy, which you should also read.

The only people that will have access to your personal data include:

• your Landlord
• our staff (who are either employed by us or engaged by us under contracts which include strict confidentiality and data protection obligations on them)
• our technical service providers, such as our developers, hosting providers, email marketing tools and analytics providers (all of which will only have the access they need to make our Website and App work and provide their services to us and will have entered into contacts which include strict confidentiality and data protection obligations on them)
• any regulatory authorities such as HM Revenue & Customs (the UK tax authority)
• any actual or potential buyer of our business

In the very rare situation where we’re asked to disclose personal data in response to any legal request or court order, we’ll take legal advice before making any disclosure to ensure that your rights and interests are considered before responding to such requests.

Where your personal data are stored

We will not transfer your personal data outside of the UK or the European Economic Area (EEA).

How we keep your personal data secure

We’ve put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We also limit access to your personal data to those of our staff and technical service providers that have a need to access it (based on the principle of ‘least privilege’). They’ll only use your personal data based on our instructions and are required to keep your personal data confidential.

We’ve put in place procedures to deal with any suspected personal data breach and will notify you and the UK Information Commissioner’s Office or any other relevant regulator where we’re legally required to do so.

How long we keep your data for

We’ll only keep your personal data for as long as necessary in connection with the purposes we collected it for and to comply with any legal, accounting or reporting requirements. To determine how long we keep your personal data for, we consider the amount, nature and sensitivity of the personal data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.

We’ll retain any personal data linked to your account for as long as you use the Services and for 12 months after you’ve ended your subscription (in case you decide to re-activate it within that time).

We’ll retain any analytical data collected about your use of our App and Services which identifies you for a period of 12 months.

We may retain any data that does not identify you indefinitely.

Cookies

Our Website and App may use small text files, called cookies, which are stored on your device when you access and use our App. Apart from those cookies which are strictly necessary for us to provide you with access to any features of the App that you’ve requested, we’ll only store cookies on your device if you’ve consented to this when you first access our website and every 90 days thereafter.

As cookies are unique, we can use them to distinguish you from other users for the purposes described above, however we will configure any analytical cookies so that your IP address is anonymised. To find out more about cookies, how to refuse them and how to change your device’s cookie settings, you should visit the ICO Cookie Guidance.

Our App may use the following types of cookies:

• Strictly necessary cookies: these are cookies which are required for the operation of our App (we don’t need your consent for these cookies – but if you delete them, the App may not function as it should)
• Analytical cookies: these cookies allow us to recognise new and returning visitors to our App and see how users engage with our App
• Functionality cookies: these cookies are used to remember your preferences or customise your experience
• Advertising cookies: these cookies are used by advertising networks to customise the advertising you see online based on your interests (you can agree to analytics cookies without agreeing to these cookies)

Currently, the App does not use any cookies. We will let you know if this changes in future

Your rights

Under UK and EU data protection laws, you have the following rights in relation to your personal data:

Access: You’ve the right to be informed if your personal data is being used and the right to request a copy of the personal data held about you together with certain information about the processing of such personal data to check that we are holding it lawfully

Correction: You’ve the right to ask us to correct any inaccurate or incomplete personal data held about you

Deletion: You’ve the right to ask us to delete or remove any personal data held about you where there is no good reason for us to continue holding it or where you have exercised your right to object

Restriction: You’ve the right to ask us to restrict how we hold your personal data, for example, to confirm its accuracy or our reasons for holding it

Objection: You’ve the right to object to our holding of any personal data about you which is based on our legitimate interests or those of a third party based on your particular circumstances. You’ve also the right to object to our holding your personal data for direct marketing purposes

Portability: You’ve the right to receive or request that we transfer a copy of the personal data we hold about you in an electronic format where the basis of our holding such information is your consent or the performance of a contract and the information is processed by automated means

Complaints: You’ve the right to complain to the UK Information Commissioner’s Office (ICO) or any other EU supervisory authority in relation to how we collect and use your personal data

You won’t have to pay any fee to exercise any of the above rights, although we may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, we’ll let you know.

To protect the confidentiality of your personal data and other members of our community, we may need to ask you to verify your identity before fulfilling any request in relation to your personal data.

Questions or comments

If you’ve got any questions or comments regarding this policy, please email us at info@optus-homes.com