Framework Privacy Notice
We collect, store, use and share personal data, and are responsible for the personal data we process about you. When we do so, we are subject to UK data protection laws and regulations including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (“data protection laws”).
For the purposes of data protection laws and regulations, in most circumstances when you create an account, and submit to, or share, your personal data with us on our websites, applications, platforms and systems, we are the ‘data controller’ of the information provided. This means we decide how and why your personal data is processed.
This privacy notice covers our data processing activity as a ‘data controller’. Where a third party such as an estate agent, lettings agent, new home builder, or other similar GSL business customer (GSL customer) is instructed or engaged by you, that GSL customer will become a ‘data controller’ of your personal data that we may provide to that GSL customer or that they provide to us (either directly or via a third party).
GSL may act as a ‘data processor’ of any personal data hosted on our websites, applications, platform and systems that is in the control of a GSL customer, such as where that GSL customer may provide us with processing instructions once you have entered or intend to enter into terms or any agreement with them, so we can assist them in fulfilling the terms of that agreement.
Where GSL processes any personal data on the instructions of a GSL customer, any queries you may have about that processing, including exercising your data subject rights must be directed to the relevant GSL customer. Where we act in response to instructions from a GSL customer, their privacy policy and notices will apply.
We may be a ‘joint data controller’ (where we jointly participate in determining the purposes and manner in which your personal data is processed) together with a GSL customer or other third party. We may introduce you or be required to share your personal data with another ‘data controller’ for the purpose of providing our products and services, third party products and services you have chosen to use, or to promote offerings to you, where permitted under data protection laws.
When you engage with any other ‘data controller’ introduced or made available to you through use of our or their products or services, you must further read, and where required, agree to their terms and privacy notice. This privacy notice details our responsibilities for when we are a ‘data controller’ or ‘joint data controller’ of your personal data. We also may include details of processing and personal data sharing where we act as a ‘data processor’ to help provide you with transparency on how your data is processed.
This privacy notice applies to personal data that relates to you as an individual, it does not apply to information about or related to properties where the information is about the property itself, nor information about the occupants, owners or other interested parties of that property.
If you have any questions about the property information we display, please contact our customer help team at help@GSL.co.uk. If you’re selling or letting a property that’s being advertised on our websites or applications, please direct any questions to your agent.
Questions, comments and requests regarding this privacy notice are welcome and should be addressed to dpo@houseful.co.uk or via our postal address above. Please mark your letter: ‘Houseful Ltd: Data Protection Officer’.
Personal data we collect about you
The personal data we collect about you depends on how you interact with our websites, apps and different products and services. To use your personal data, we must have a valid reason (a “lawful basis”). For example, sometimes we ask for your consent (for example to use certain cookies) and in other cases where you would expect us to use your personal data (for example to provide the product or service you choose to use), then we do not need to ask for consent, and can rely on another lawful reason. Data protection law provides other bases and exemptions for the processing of personal data, and requires us to have an additional reason to process data which is given special protection under data protection laws, such as special category and criminal conviction data, where relevant. For example we will usually ask for explicit consent when processing health data or biometric data. We will only ever process your personal data where we have a lawful reason to do so. Our reason for using your personal data is usually one of the following:
Contract
This is where we need to use your personal data to carry out a contract you are party to or take steps before you enter a contract. When you choose to use a product or service you will need to agree to terms of use which constitutes a contract. We need to process your personal data to provide you with this product or service.
Consent
You have given us, or a party we act jointly with, your consent to use your personal data for a certain reason. We may rely on your consent to send you certain types of electronic mail marketing. See Right to withdraw consent for more information about how you can exercise your data subject rights.
Legal Obligation
We must use your personal data to comply with laws or regulations to which we or a party we act jointly with are subject to.
Legitimate Interests
We may have a legitimate interest in using your personal data. Usually this is to help us run, improve, promote, monetise or protect our products, services and business. You may be able to object to the processing of your personal data when processed for legitimate interests. See Right to object. You are in control of your marketing preferences. If you would like to opt out of electronic mail marketing, you can do so at any time. See Direct Marketing below for more information on the lawful bases we may use to direct market to you.
Examples of legitimate interests, where relevant, may include but are not limited to:
• Sharing data with agents, new home builders or other third parties (“third parties”), so we can help progress an application, lead, quote or other such request.
• Sharing data with third parties, so you do not need to re-enter it.
• Sharing data with third parties to make available to you third party products or services to enhance our, or a third party product or service, or your customer experience in general.
• Third parties sharing your personal information with us, so we can combine personal data we hold on you to produce data insights or information/outcomes/behaviours about you, to help them improve or personalise their products and services they provide to you.
• Sharing and receiving data from third parties to offer and provide you with benefits for choosing to use our or a third party product or service.
• Providing emails concerning status, reminders and outcomes on your use of our, or a third party product or service.
• Collecting personal data from third parties, such as to obtain a status of any payment transaction.
• Receiving data from third parties to speed up and improve the efficiency of a property transaction and to keep all parties, where required, informed.
• Providing emails concerning quote results or confirmation of your use of our or a third party product or services.
• Receiving data from third parties to allow us to understand your engagement with them, and for them to share with us the status of a property transaction to facilitate the accurate receipt of referral or other monies payable to us by third parties, or the payment of monies by us to others, or payment of third parties to other third parties, for products and or services you may have chosen to use or are provided to you as a benefit.
• To allow us to understand your user journey and for us to know where you have taken an action such as making a payment or moving to a different website.
• To allow us to understand more about what is relevant and helpful to you such as when you like or dislike content on our websites, applications, emails and social/digital media platforms.
• Auditing and monitoring our processes, your engagement and feedback to help keep our high standards.
• Market research, statistical analysis, management information, data aggregation and product development for our own purposes, third party purposes or to assist the wider property management industry.
• Using a third party to allow for communication with you such as video conferencing. Training, communications and awareness.
• Securing our services, ensuring personal data is up to date and accurate, and keeping our services online.
• Preventing or prosecuting fraud and other criminal behaviour or activity.
• Transferring personal data for the purposes of developing, migrating and maintaining IT infrastructure and services.
• For direct marketing, personalisation, targeting and data shares for the purposes of marketing, monetisation or promotional activities.
• Showing you personalised content such as properties of interest on our websites, applications, platforms and systems.
• Non targeted marketing on our websites, applications, platforms and systems of either our products or services or products and services of third parties.
• For data insights, services and products improvements and developments based on your use of our or third party offerings on our websites, applications, platforms and systems.
• Recording where applicable of telephone calls and related services.
• For relevant processing by another company, such as by Group Companies.
• We may also process data in aggregated and anonymised form for statistical purposes to improve products and services, including our customer service.
Personal data processes
We have broken down our main offerings below providing you with a useful guide to what personal data we collect, how we collect it, who we share it with and what lawful basis we rely upon to process your personal data. See Direct Marketing for privacy information related to the collection and processing of your personal data for direct marketing purposes.