Privacy policy

Introduction

 

Guarantid Ltd. respects your right to privacy. Your ability to make an informed choice about the use of your information is very important to us.

 

This policy applies where we are acting as a data controller with regard to personal information of our users and visitors. Guarantid’s data controller registration number is ZA523627. You can check our registration on the Data Protection Public Register by visiting https://www.ico.org.uk/esdwebpages/search.

 

Definitions

 

(“We”, “our” or “us”) are references to Guarantid Ltd and any member of our group, which means our ultimate holding company, Homeppl and its subsidiaries.

 

(“The Platform”) provides tenant guarantor services to tenants and their landlords. The Platform is used by individuals seeking rented accommodation and our services for their own use ("Renters"), landlords and their letting or estate agents that are using the Platform in order to review the profiles of Renters ("Landlords") and individuals who will co-sign the agreement between us (“Co-signers).

 

In this Privacy Policy, Renters, Landlords and their agents and Co-signers may be referred to together as ("Users").

 

As used in this Privacy Policy, ("Personal Information") means information that can be directly associated with a specific person or entity including but not limited to an individual's name, address, telephone number, email address, identity document, gender, date of birth, educational details, tenancy agreement, third party reference or evidence of personal finances.

 

Below, we have outlined the following;

 

  • the different purposes for which we process your personal information;

  • the data that we obtain from Credit Reference Agencies on your behalf;

  • our legal grounds for processing personal information;

  • the categories of personal information we receive from third parties about you;

  • which background checks we perform;

  • how we treat sensitive personal information;

  • who we transfer this personal information to and how they use it;

  • your rights in relation to automated decision making;

  • how we protect personal information;

  • how long we store personal information;

  • our use of cookies;

  • how we treat children's personal information;

  • your rights to view or transfer your personal information;

  • when we may change this Privacy Policy;

  • who to contact in case you have questions.

 

Purposes of processing

 

We will use the information you provide to us or we receive from Credit Reference Agencies or other third party providers to:

 

  • Check your eligibility for our guarantor service and provide you with such services where we guarantee rental obligations under an Assured Shorthold Tenancy (AST).

 

  • Perform analysis and profiling of your credit information including but not limited to bankruptcy, county court judgement, anti money laundering, identity verification and bank account verification checks to make an assessment on your eligibility for our services.

 

  • Check your name and date of birth against databases of publicly available information, for example: published newspaper articles, international government sanctions and criminal or terrorist watchlists.

 

  • Establish, exercise or defence of any legal claims, whether in court proceedings or in an administrative or out-of-court procedure where necessary.

 

  • Enable Landlords and their agents to meet their legal obligations, for example to perform due diligence to determine if a User poses a risk of money laundering.

 

  • Process ongoing information relating to bank account transactional data including but not limited to purchase and payment history, balance, account details, accounts, direct debits and standing orders through Open Banking.

 

  • Advertise and introduce Users to appropriate products, including residential, financial and insurance products, or other personalised offers, where we believe this would be relevant or helpful.

 

  • Allow Users to leave comments and reviews for other Users, as well as to verify the information submitted by other Users.

 

  • Provide, update, maintain and protect our services, websites and business which may include presenting site information effectively as well as test and improve our existing services.

 

  • Send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our services, our service offerings, and important service-related notices, such as security and fraud notices, as well as to conduct surveys. These communications are considered part of the services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications, news about Guarantid or to conduct surveys. Please contact us if you would like to stop receiving such emails.

 

  • Help diagnose problems with our servers, and to make the Platform more useful for you and for our other customers. Depending on the circumstances, examples of such data processing may include those that reasonably serve customer relations, compliance and other considerations, auditing, security and fraud prevention, preserving or defending Guarantid's legal rights, or other purposes consistent with the expectations of a reasonable person given the context of the collection.

 

  • Share Statistical Information with our partners. By analysing all information we receive, we may compile statistical information across a variety of Users ("Statistical Information"). Statistical Information helps understand trends and customer needs so that new services can be considered and so the Platform and associated services can be tailored to customer desires. We may share Statistical Information with our partners, pursuant to commercial terms that we determine in our sole discretion. In addition, we may provide any information to third parties, so long as we have removed any information that identified any specific individual or user, such as name, address or contact information.

 

Grounds of processing

 

We may process your Personal Information under the following grounds:

 

  • We may process Personal Information when a User requests to undertake processing in order to enter into a contract. For example, when a Renter enters a contract to rent a property with a Landlord or their Agent and requires our service, Guarantid may need to validate your identity, rental record, and financial abilities. Where this is the case, your provision of data to Guarantid may be required as part of your application for our service, and not supplying such information may mean that you are not able to secure a property.

 

  • We may process your Personal Information where this is necessary for the purposes of the legitimate interests pursued by Guarantid or a User of Guarantid's Platform. Not supplying such information may mean that a User is unable to secure their rental contract.

 

  • If you choose to create a Guarantid application without being required to do so in order to enter a rental agreement, we may process your data in order to fulfil the purposes for which you consented to supply this to us, or those outlined in the Purposes section above.

 

  • We may process Users' data in order to enable our clients to meet a legal obligation. For example, we may process your identity document as part of our identity authentication process.

 

  • We may process your Personal Information in order to provide, update, maintain and protect our online services.


 

Marketing Communications and How to Change your Preference

 

If you choose to receive tailored marketing communications, we may sometimes send emails about:

  • New product features

  • Promotional communications

  • News about guarantid

  • Surveys

 

These communications may be tailored to your User profile.

Please contact us if you would like to stop receiving such emails or whenever you receive direct marketing you will be given an option to unsubscribe.

 

Personal Information received from Users

 

When you create an application with us, you will be required to provide Personal Information. We collect and store Personal Information that you may provide in the course of creating your profile, as well as when you make use of our Platform.

 

Such information may include Personal Information about yourself, including but not limited to details concerning your current and prior addresses, properties, and finances. The information we may request depends on the individual situation of each User and will typically include an identity document, proof of address and proof of income. Please refer to our FAQ section to determine which documents will be needed for your particular application.

 

In addition, we collect any information you provide when you contact us over the phone, by email or by other means.

 

You are not required by law to provide us with any such information, but by using the Platform you agree to provide us with such information.

 

If you provide us with Personal Information about others, or if others give us your Personal Information, we will use that information only for the specific reason that it was provided to us.

 

Background Checks

 

We may share the information you provide to us with Credit Reference Agencies or other databases to:

 

  • Perform background checks to determine if you appear on any global sanctions lists, fraud lists, or other lists of adverse information and use sources such as aggregators of published newspaper articles and government lists of adverse information, including criminal watchlists which includes databases that may reveal criminal convictions.

 

  • Verify the validity of the information provided to us, such as and not limited to your identity document or bank account number, we may cross-reference such information with third party databases. .

 

  • Perform background checks to determine whether you have received any debt-related judgements, bankruptcy orders or have any other debt-related adverse information.

 

  • By using Guarantid’s services you agree to such checks and that we may share any adverse information with your Landlord or their agent, in order that they may assess your suitability to rent a property, as well as to comply with any legal obligations such as the Money Laundering Regulations 2017.

 

For more information on how Credit Reference Agencies may use this information, please click here

 

Sensitive Personal Information

 

We may receive certain kinds of sensitive Personal Information when we process your account. This may include, for example, the current state of your health, racial or ethnic origin, religious or other beliefs or trade union membership.

 

We will only process the above information in accordance with Data Protection Law and only for the specific purpose that the information has been provided to us for. By submitting such Personal Information you consent to our processing of such information.

 

We do not require you to submit such information and if you do so, this will not affect the outcome of your rental application.

Personal Information received from third parties in processing your application

 

To be eligible for our services, we will receive information from our Referencing Partner and other third parties regarding your identity, residential history and financial abilities.

 

We will also receive information from third parties as described in the Background Checks section, above.

 

Information sent to third parties

 

By giving us your personal data, you agree that we may share your Personal Information with other third parties, such as our service providers, subcontractors, internet storage facilities, advertisers, Credit Reference Agencies, Referencing Partners and Fraud Prevention Agencies that may be located in countries other than your own. The purpose of such foreign transfer will be to safely store your personal data. We may share your Personal Information with the following data processors of your Personal Information:

 

​We will not sell your Personal Information to third parties for their own marketing purposes but we may share it with specific third parties such as telecommunications, broadband, energy, insurance, and other related product providers for marketing purposes. We will not share your Personal Information with these third parties for marketing purposes without your express opt-in consent. If you wish to opt out of marketing communications, please contact hello@guarantid.com.

 

We may also transfer your Personal Information abroad through external communication providers such as via secure email and chat communication services. We ensure that EEA standards of protection of personal data will apply to such subcontractors and service providers. The purpose of such transfer will be to communicate internally as well as with third parties and our clients.

 

By using the guarantid Service you agree that the documents you upload and all other Personal Information including references will be transferred to your estate or letting the agent and/or to the Landlord for the property you are applying to.

 

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behaviour of any user suspected to have engaged in illegal behaviour.

 

We may transfer our databases containing information if we sell our business or part of it, and Users will be notified of this change in advance, both by email and through our website.

 

If you provide us with Personal Information about others, or if others give us your Personal Information, we will use that information only for the specific reason that it was provided to us.

 

Experian Rental Exchange Database

 

We have teamed up with Experian to take part in The Rental Exchange. The Rental Exchange is a way to strengthen your credit report without you needing to take on new credit. The scheme enables us to share details about the rent you pay with Experian on a monthly basis. This is then included in your credit report, meaning you will then be recognised for paying your rent on time.

 

Not only will we be able to work with you more closely to manage your tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist us to:

  • Assess and manage any new tenancy agreements you may enter into;

 

  • Assess your financial standing to provide you with suitable products and services;

 

  • Manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;

 

  • Contact you in relation to any accounts you may have and recovering debts that you may owe;

 

  • Verifying your identity, age and address, to help make decisions about the services being offered;

 

  • Help to prevent crime, fraud and money laundering;

 

  • Screen marketing offers to make sure they are appropriate to your circumstances;

 

  • For Experian to undertake statistical analysis, analytics and profiling,  

 

  • For Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.  


 

If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).

 

We will continue to exchange information about you with Experian while you have a relationship with us and inform Experian when your tenancy has ended. Experian will hold your rental data for the time limits explained in CRAIN (section 7). Rental data falls into the Identifiers (e.g. your name, address, date of birth) and financial account categories (i.e. tenancy account, rental payment information).

 

We and Experian will ensure that your information is treated in accordance with UK data protection law, so you can have peace of mind that it will be kept secure and confidential and your information will not be used for prospect marketing purposes.

 

If you would like advice on how to improve your credit history you can access independent and impartial advice from www.moneyadviceservice.org.uk (you can get a copy of your Statutory Credit Report by visiting www.experian.co.uk/consumer/statutory-report).  

 

If you are unhappy with anything relating to Rental Exchange, please contact us on the contact details above. You also have the ability to get in touch with the Information Commissioner’s Office. More information about this can be found using this link here: https://ico.org.uk/concerns/.  

 

Use of information by third party sites and services

 

Your Personal Information may be transferred to Landlords and their agents in order that they may determine your suitability to rent a property.

We are not responsible for the use of any data by third parties, and we cannot vouch for the privacy policies of any third party. The Platform may link to or use web sites or services belonging to third parties. We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. We cannot accept responsibility for the privacy policies of any such sites. We are not responsible for content available by means of such sites or services. We do not endorse any services or offered by third parties and we urge our users to exercise caution in using third-party sites or services.

 

Automated decision making

 

We may perform automated decision making in order to reach a verdict regarding your guarantee application. Where this is the case, you may contest the outcome of such a decision and request Guarantid to use human intervention to review the decision.

 

How we protect information

 

We store your information in encrypted data storage facilities which are backed up in high-security data centres located within the EEA. If data is transferred outside of the EEA, we ensure that the country of transfer has adequate safeguards in place. However, no method of transmission over the Internet, or method of electronic storage is completely secure. Therefore, we cannot guarantee its absolute security.

How long we store information

 

Guarantid respects your legal right to erasure. We will not store your personal data for longer than is necessary for the purposes for which the Personal Information are processed, outlined in the Purposes section above.

 

Cookies

 

A cookie is a small piece of text that is sent to a visitor's browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. A “persistent” cookie may be used to help save your settings and customizations across visits. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Platform may not function properly when cookies are disabled or removed.

 

The Platform may also record certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring or exit pages, operating system, date and time stamp, page response times, download errors, length of visits to certain pages and page interaction information such as scrolling, clicks and mouse-overs. The purpose of collecting this subset of information is to improve the way our website works.

 

Children

 

We do not knowingly collect Personal Information from children under the age of 16. In the event you become aware that an individual under the age of 16 has enrolled without parental permission, please advise us immediately.

Requesting to view or transfer your Personal Information

 

Guarantid will provide you with information regarding the data we hold, as well as a copy of the information, following the receipt of a Subject Access Request. If you would like to make such a request or if you have questions regarding the data we hold, please email us at hello@guarantid.com with the phrase ‘Subject Access Request’ in the email subject line. If you would like to transfer your data to a third party organisation, or if you would like to amend or correct the Personal Information we hold about you, please email us with the phrase ‘Data Transfer Request’ in the email subject line. We will reply to all requests within one month of receipt of a valid request.

 

Please note that we will require to verify your identity before releasing any Personal Information. Guarantid reserves the right to charge a fee for multiple, excessive or unfounded requests.

 

Changes

 

We may update this Privacy Policy from time to time, and we encourage you to review it periodically. We will treat your continued use of the Services following such notice as you acceptance of the changes. However, to the extent required by law, we will seek your consent prior to applying material changes to this Privacy Policy.

 

Comments and questions

 

If you have any comments or questions about this Privacy Policy, please contact us by email at hello@guarantid.com or by phone at: +44(0)2080897709.

 

For further information on the Data Protection Legislation or if your would like to make a complaint, please contact the Information Commissioner’s Office (www.ico.org.uk)

 

Last updated: June 2019

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Guarantid LTD is a limited company registered in England and Wales with registered number 11995176. 

Our registered office and place of business is at Brickfields 37 Cremer Street, Hoxton, London, E2 8HD. Data Protection registration reference: ZA523627.