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Client Privacy Notice [Draft]

Last updated April 24, 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,
London,
United Kingdom
W1W 7LT

Telephone: +44 (0)208 0502 818

Emaill: privacy@passthekeys.com

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:

<TBC>

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

  • Personal Identification Information: First name, last name, title, date of birth, photo ID, in some locations Identity Number.
  • Contact Information: Address, email address, and phone numbers.
  • Gender: Gender category
  • Employment Status: Category of employment status
  • Age Category: Approximate Age

Airbnb Account Information

  • 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

  • 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

  • Bank Account Details: Including account numbers and sort codes for transaction purposes.
  • Payment History and Details: Records of transactions, payments made, and amounts owed.
  • Loan or Credit Information: In exceptional circumstances, details of any loans or credit arrangements you have with us.

Business Information

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

Legal and Regulatory Information

  • 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

  • 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

  • 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:

PurposeLegal basis
Carrying out B2C financial Accounting, i.e. all activities related to recording, summarising, and reporting the various B2C transactions resulting from business operationsPerformance of contract - Art. 6 (1) (b) UK GDPR Compliance with legal obligations - Article 6(1)(c) UK GDPR
Carrying out B2B financial Accounting, i.e. all activities related to recording, summarising, and reporting the various B2B transactions resulting from business operationsPerformance of contract - Art. 6 (1) (b) UK GDPR Compliance with legal obligations - Article 6(1)(c) UK GDPR
Raising FundsPerformance of contract - Art. 6 (1) (b) UK GDPR
Assigning receivablesPerformance of contract - Art. 6 (1) (b) UK GDPR
Securing debts via guaranteesPerformance of contract - Art. 6 (1) (b) UK GDPR
Implementing and managing the debt assumption processLegitimate interests - Art. 6 (1) (f) UK GDPR
Implementing and managing the debt assignment processLegitimate interests - Art. 6 (1) (f) UK GDPR And Compliance with legal obligations - Article 6(1)(c) UK GDPR, where necessary to comply with legal and regulatory obligations
Assertion, exercise or defence of legal interestsLegitimate interests - Art. 6 (1) (f) UK GDPR

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:

ServiceProviderReason why your data is sharedLocation of data processing
AirbnbAirbnb IncTo manage your properties on your behalf we create or update an Airbnb account with your personal and/or business details.US
Google WorkspaceGoogle Cloud EMEA Limited, Privacy NoticeWe use GMail, Google Chat, Google Drive (collectively Google Workspace) for communicating with you and internally to manage your property.US EU
BigQueryGoogle Cloud EMEA Limited, Privacy NoticeWe use BigQuery for data analysis. This allows us to constantly improve our service to you.London, UK
Check-in ScanCheck-in Scan, SL, Privacy PolicyWe use Check-in Scan in some countries to comply with local requirements to register Guest stay information.EU
HolisticsHolistics Software Pte LtdHolistics is a business intelligence tool we use to analyse our service usage and improve our quality and efficiency.Singapore
HubspotHubspot, Inc.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
Freshdesk, FreshcallerFreshworks Inc., [Privacy Notice]We use Freshdesk to manage email communication with you, and Freshdesk when speaking to you on the phone.USA
Just CallTelephony provider used by our internal sales team.
Amazon Web Services (AWS)Amazon Web Services, Inc. https://aws.amazon.com/compliance/gdpr-center/Hosting of our internal Property Management System to coordinate the service activities we provide you.London, UK
XeroXero Limited, https://www.xero.com/uk/data/xero-and-gdpr/Managing financial accounting information, including records of your payments.USA
GoCardlessGoCardless Ltd, https://gocardless.com/legal/gdpr/We use GoCardless to collect payments from you for our services.EU
FacebookMeta Inc,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
ZapierZapier Inc,We use Zapier to move information collected on Facebook into Hubspot so that we can contact you.USA
OpinyinEssencient LtdWe use Opinyin to send you surveys about your experience with our service.USA
TypeFormWe use TypeForm to ask you about why you chose us.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.

  • 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).

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 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.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

By post: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

By live chat: https://ico.org.uk/global/contact-us/live-chat

By email: casework@ico.org.uk

By phone: +44303 123 1113

 This notice was created with the support of DataGuard.