Client Privacy Notice

Last updated June 20, 2024

Privacy Notice for Clients (Hosts) of Pass the Keys Limited

Who we are

All references to ‘we’, ‘us’ or ‘the company’ in this Privacy Notice refer to the following organisation:

Pass the Keys Limited
85 Great Portland Street,
First Floor,
W1W 7LT London,
United Kingdom

Telephone: +44 (0)208 0502 818
Email: privacy@passthekeys.com
Web: https://www.passthekeys.com

Who this Privacy Notice applies to

This Privacy Notice sets out how we use personal data for the following individuals:

Our clients (Hosts) who are individuals, as well as representatives or contact persons of our clients who are legal entities (collectively referred to as ‘clients’ in this Privacy Notice for ease of reference).
For the avoidance of doubt, clients refer to customers of our property management service, not any other parties, including guests staying within our properties, or franchise partners.

Our role in the processing of your personal data

Where we choose, or assess whether to choose, to enter into a business relationship with a client, we are the controller of any personal data that you give to us for the purpose of enabling that business relationship. This means that we are responsible for deciding how we collect, use, and store information about you regarding our relationship.

How to contact our data protection officer

The contact details of our designated data protection officer are as follows:

For clients residing in the United Kingdom or non-EU member states:

DataCo International UK Limited
Suite 1,3rd Floor Suite 1, 11 - 12 St James's Square,
London, United Kingdom
SW1Y 4LB

Telephone: +442035146557
Email: privacy@dataguard.co.uk

For clients residing in the EU member states:

EDPO (European Data Protection Office)
Calle de Manzanares, 4, 28005 Madrid, Spain

Web: https://edpo.com/gdpr-data-request/
Email: privacy@edpo.com

Your personal data that we process

Within the scope of the client relationship, we collect the following personal data directly from you:

Personal Identification and Contact Information

We collect this data to help you set up your Pass the Keys account and to (when required) create an Airbnb account on your behalf. In some jurisdictions, we may be required to hold this information as part of our regulatory compliance.

Personal Identification Information:First name, last name, title, date of birth, photo ID and, in some locations, Identity Number.
Contact Information:Address, email address, and phone numbers.

Demographic Information

We may collect this information during the sales process to help us understand who our customers are so that we can better tailor our services.

Gender: Gender category
Employment Status: Category of employment status
Age Category: Approximate Age

Existing Airbnb Account Information

Where you already have an existing Airbnb account, we have access to this data when you delegate the management of the account to us.

Existing Personal Identification Information:First name, last name, title, date of birth, photo ID.
Financial History:Records of previous bookings and transactions.

Managed Property Information

We collect this data so that we can advertise your property on short term rental marketplaces, and where required to register the property with local authorities.

Address: Address of properties being managed on behalf of the client.
Licence Number: Any property licence number relating to local property rental laws.
Property Documentation: Depending on where your property is located, we may capture Property Deed, First Occupancy License, Energy Efficiency Certificate, or other property documentation required by local authorities.
Police Registration Access Details: In jurisdictions where the property is required to be registered with local police authorities, we will capture or request your access details (login information) to allow us to administer your property.
Property Registry Details: Cadastral Reference

Financial Information

We collect this data for accounting purposes, and so that we can collect our fees for managing your property or pay you any monies owed.

Bank Account Details: Including account numbers and sort codes for transaction purposes.
Payment History and Details: Records of transactions, payments made, and amounts owed.

Business Information

If your property is registered to a business we collect this data for accounting purposes.

Business Details: Business Name, Registered Address (for individuals whose property arrangements are linked to business entities).

Legal and Regulatory Information

We collect this data to protect both you and us in case there is any dispute around our service.

Contracts and Agreement Details: Documentation of the terms of our financial arrangements with you.
Legal Claims or Proceedings: Information related to any legal actions involving you that might affect our relationship.

Transactional Data

We collect this data for accounting purposes, which includes giving you an itemised breakdown of revenue and costs relating to the management of your property.

Account Transactions: Detailed records of transactions related to the client arrangements, including dates, amounts, and descriptions.
Invoices and Statements: Copies of billing documents sent to or received from you.

Communication Records

We collect this data for training purposes, to help us provide you with clear and accurate information about the service we are providing you, and to protect both you and us in case of any dispute around our service.

Correspondence: Copies of communications between you and us, including emails, letters, and notes from phone calls.
Customer Service Records: Details of interactions with our customer service teams, including inquiries, complaints, and feedback.

Purposes and legal bases of the data processing

We only process your personal data when we have a lawful basis and a legitimate purpose for doing so. In particular, we process your personal data for the following purposes and under the following legal bases:

Data Category	Purpose of Processing	Lawful Basis
Personal Identification and Contact	To set up Pass the Keys account, create Airbnb accounts, maintain regulatory compliance	Contractual necessity EU GDPR Art. 6(1)(b) UK GDPR Art. 6(1)(b)
Demographic Information	To tailor services to customer demographics	Legitimate interest EU GDPR Art. 6(1)(f) UK GDPR Art. 6(1)(f) Tailoring services to enhance customer satisfaction and service personalization
Existing Airbnb Account Information	To manage client’s existing Airbnb account	Contractual necessity EU GDPR Art. 6(1)(b) UK GDPR Art. 6(1)(b)
Managed Property Information	To advertise properties, register with local authorities, comply with rental laws	Legal obligation & Contractual necessity EU GDPR Art. 6(1)(b) & (c) UK GDPR Art. 6(1)(b) & (c)
Financial Information	For accounting, fee collection, and payments to clients	Contractual necessity EU GDPR Art. 6(1)(b) UK GDPR Art. 6(1)(b)
Business Information	To manage property related business arrangements, accounting	Contractual necessity EU GDPR Art. 6(1)(b) UK GDPR Art. 6(1)(b)
Legal and Regulatory Information	To comply with legal requirements, protect legal rights in disputes	Legal obligation EU GDPR Art. 6(1)(c) UK GDPR Art. 6(1)(c)
Transactional Data	For accounting, providing detailed financial records to clients	Contractual necessity EU GDPR Art. 6(1)(b) UK GDPR Art. 6(1)(b)
Communication Records	To train staff, provide service information, protect legal rights in disputes	Legitimate interest EU GDPR Art. 6(1)(f) UK GDPR Art. 6(1)(f) Improving service delivery, ensuring accurate communication, dispute resolution

Please note that in the context of our relationship with you as a client, if you fail to provide personal data when requested which is necessary for us to manage our relationship with you or the legal entity you are representing as a client (e.g. personal data which is necessary to conclude, implement, or manage our contractual relationship, regulatory and legal obligations), we may not be able to continue our business relationship.

Sources of your personal data

Most of the personal data that we process is sourced directly from you.

In addition, in some circumstances we will collect personal data from third-party agencies or publicly available sources in order to fulfil the purposes for processing your personal data outlined in this Privacy Notice.

Who we share your personal data with

We only transfer your personal data to external recipients if you have consented or if this is permitted by law.

Local franchise partner

In order to manage your property effectively, it may be necessary to share your personal information with our franchise partners who act on our behalf in delivering these services to you, our client. We disclose only the information that is necessary for the fulfilment of the service and our franchise partners are obligated to protect your information and use it solely for the purposes of providing the services you have requested.

Service providers

As with most organisations, we use service providers which help us to manage our relationship with you. When we use these service providers, it is necessary for us to share your personal data with them.

We use the following service providers:

Service	Provider	Reason why your data is shared	Location of data processing
Airbnb	Airbnb Inc. Privacy Policy	To manage your properties on your behalf we create or update an Airbnb account with your personal and/or business details.	US
Amazon Web Services (AWS)	Amazon Web Services Inc. GDPR Center	Hosting of our internal Property Management System to coordinate the service activities we provide you.	London, UK
BigQuery	Google Cloud EMEA Limited Privacy Notice	We use BigQuery for data analysis. This allows us to constantly improve our service to you.	London, UK
Check-in Scan	Check-in Scan SL Privacy Policy	We use Check-in Scan in some countries to comply with local requirements to register Guest stay information.	EU
Facebook	Meta Inc. Privacy Policy	We use Facebook to advertise our property management services. If you completed a form on Facebook for more information your data will have been processed here.	USA
Freshdesk, Freshcaller	Freshworks Inc. Privacy Notice	We use Freshdesk to manage email communication with you, and Freshdesk when speaking to you on the phone.	USA
GoCardless	GoCardless Ltd GDPR Statement	We use GoCardless to collect payments from you for our services.	EU
Google Workspace	Google Cloud EMEA Limited Privacy Notice	We use GMail, Google Chat, Google Drive (collectively Google Workspace) for communicating with you and internally to manage your property.	US EU
Holistics	Holistics Software Pte Ltd. Privacy Policy	Holistics is a business intelligence tool we use to analyse our service usage and improve our quality and efficiency.	Singapore
Hubspot	Hubspot Inc. Privacy Policy	We use Hubspot to collect information about your request for our property management services, to manage communication throughout the sales process, and update you of our services.	USA
Just Call	SaaS Labs US Inc. Privacy Policy	Telephony provider used by our internal sales team.	USA
Opinyin	Essencient Ltd. Privacy Policy	We use Opinyin to send you surveys about your experience with our service.	USA
Superhog	Superhog Ltd. Privacy Policy	We use Superhog to provide Guest Verification for bookings not taken through Airbnb, and to support damage protection for those bookings.	UK, USA
TypeForm	Typeform S.L. GDPR Statement	We use TypeForm to ask you about why you chose us. This helps us better understand our customers and improve our services.	USA
Xero	Xero Ltd. GDPR Statement	Managing financial accounting information, including records of your payments.	USA
Zapier	Zapier Inc. Privacy Notice	We use Zapier to move information collected on Facebook into Hubspot so that we can contact you.	USA

We have agreements in place with all our service providers that we share your data with that oblige them to protect your data.

Affiliated Group Entities

In addition to service providers, we may share your personal data with affiliated entities within our corporate group for internal administrative purposes, including for centralised business operations.

Other recipients

In the course of processing your personal data, we may also disclose your personal data to the following recipients.

Operational Service Providers (e.g. Cleaners, Photographers, Maintenance Providers)
Credit reference agencies
Debt collection agencies
Legal and professional advisors
Regulatory bodies and law enforcement
Banks and financial institutions
Insolvency practitioners
Other creditors

The data is transferred to the above recipients for accounting purposes, to contractual and legal obligations, and to assert, exercise or defend our legal interests (if necessary).

International Data Transfers

Where your data is transferred outside of the UK, we make sure that your data is the given the same level of protection, either because that country have a comparable data protection standard (Adequacy), or by using another safeguard such as an enhanced contractual agreement (i.e. International Data Transfer Agreement). Please contact us for more information about which transfer mechanism we rely on in specific cases.

How long we keep your personal data for

We will delete your personal data as soon as the purposes for storing it mentioned in the ‘Purposes of data processing’ section above no longer apply, you object to the use of your personal data, or you revoke your previously given consent. However, your personal data may also be stored beyond this, in particular in the following cases:

If there are outstanding obligations from the contractual relationship
If a deletion conflicts with contractual, legal or statutory retention periods
For the assertion, exercise or defence of legal claims
If this is required for the fulfilment of a legal obligation to which we are subject.

Your rights

You have the following rights under the General Data Protection Regulation:

right to be informed about how your data is used;
right of access to your personal data;
right to correction or rectification of your data;
right to request deletion of your data;
the right to object to the processing of your data;
the right to restrict the processing of your data;
the right to not be part of automated decision making;
the right to data portability.

Should you wish to exercise the above rights, please send an email to the following email address: privacy@passthekeys.com

In most cases, we will respond to any requests to exercise your rights free of charge and within one month, if not before.

Further information on your right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out in the public interest or based on our legitimate interests.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate interests for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.

The objection can be made without any formalities.

Further information on your right to withdraw consent

In addition, if you have consented to the processing of your personal data, you may revoke your consent at any time. Please note, however, that the lawfulness of the data processing that took place until the revocation is not affected in this case.

Complaints

If you are unhappy with any aspect of this privacy notice, or how your personal data is being processed, please contact our data protection officer.