Homelync Ltd (“We”) are committed to protecting and respecting your privacy. We have put in place policies and procedures to protect any personal information we collect about you to comply with the General Data Protection Regulation (GDPR) Regulation (EU) 2016/679; and any subsequent amendments. Details of how we collect, use and disseminate your personal data are described here to demonstrate our commitment to protecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
What is the GDPR?
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679); is an EU regulation which replaces the Data Protection Directive of 1995 (Directive 95/46/EC). GDPR aims to harmonize data protection and data privacy laws across EU member states, giving back control to citizens over their personal data; and to simplify the regulatory environment for businesses by unifying regulations within the EU and by providing a clear legal framework for commercial organisations to operate within.
The Government intends for the GDPR to continue in UK law post-Brexit and has introduced a Data Protection Bill to replace the existing Data Protection Act (DPA).
Your Rights Under GDPR
Your new rights under the GDPR are set out in this policy notice. Please read the following carefully so that you understand our practices regarding your personal data and how we will manage it.
For the purposes of data protection legislation in force from time to time the Data Controller is:
Homelync Ltd, Future Space – Office 34, Filton Road, Bristol, England, BS34 8RB
Our nominated Data Protection Officer is Luke Loveridge.
Who We Are & What We Do
We are an Internet of Things (IoT) creation and integration company (“our business”).
We collect the personal data of the following types of people to allow us to undertake our business:
- Prospective and live client contacts with landlords
- Prospective and live client contacts with tenants
- Supplier contacts to support our services
- Employees, consultants and temporary workers
We collect information about you to carry out our core business and ancillary activities.
Information We Collect About You
This is personal information about you that you supply to us by filling in forms on our website homelync.io (“our site”); or by corresponding with us by phone, e-mail or other communication channels. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events or other social media functions on our site and when you report a problem with our site.
The information you give us, or we collect about you, including: your name, address, private and corporate e-mail address, phone number, social media usernames, compliance documentation. As a prospective or live employee or temporary worker this also includes references verifying your employment history, experience and qualifications, your right to work in the UK, curriculum vitae (CV) and photograph and links to your professional profiles available in the public domain (LinkedIn, Twitter, Facebook or corporate websites).
Information We Collect When You Visit Our Website
With respect to each of your visits to our site, we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet.
- Browser plug-in type and version.
- Your operating system and platform, information about your visit, including the full Uniform Resource Locators (URL).
- Products you viewed or searched for, page response times and download errors.
- Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
- Any phone number used to call our customer service number.
Information We Obtain from Other Sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, CVs, your business card and personal recommendations.
In this case we will inform you, by sending you this policy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We work closely with third parties, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors. We may receive information about you from them for the purposes of potential or live employment and ancillary support services.
Purposes of the Processing and the Legal Basis for the Processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into (or have entered into between you and us); and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your organisation or your property.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our clients is the installation, integration, aggregation and analytics of IoT technologies within the housing sector for landlords and tenants. Our services also involve supporting landlords and tenants through the day-to-day operation of our service.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide services to you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. An example of when consent may be the lawful basis for processing include gaining permission to introduce you to a client if you are a candidate.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
As an IoT device creation and integration company we manufacturer and install IoT devices into the homes of tenants for the purposes of data aggregation and analytics to provide insights into the health of the tenants property. The storage and exchange of personal data of tenants is a fundament, essential part of this process.
In order to support landlords and tenants we require a database of tenant and landlord personal data containing historical information and current property metadata to facilitate more accurate insights into property and personal health.
To expand, develop and maintain our business we need to record the personal data of prospective tenants and landlord contacts.
Should we want or need to rely on consent to lawfully process your data, we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our CRM system. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this particular processing at any time.
Other Uses We Will Make of Your Data
- Use of our website (“our site”).
- To notify you about changes to our service.
- To ensure that content from our site is presented in the most effective manner for you and for your computer
We will use this information to:
- Administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Improve our site to ensure that content is presented in the most effective manner for you and for your computer.
- Allow you to participate in interactive features of our service, when you choose to do so.
- As part of our efforts to keep our site safe and secure.
- Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- Make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
What are Cookies?
A “cookie” is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. It can only be read by the web server that set the cookie. For users who login to the online system we set a session cookie. The purpose of this cookie is to retain your identity for the duration of that session only. Homelync Ltd provides the option to store a permanent cookie thus enabling automated login to the site.
Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
We only use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from our system.
Accepting & Declining Cookies
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Provision has been made for users of our site who prefer not to have a cookie set. This enables you to apply to jobs without logging in.
Third Party Cookies
When you visit certain pages of our site, you may notice some cookies that are not related to Homelync Ltd. When you visit a web page that contains embedded content (for example, from YouTube), you may be sent cookies from these websites. Homelync Ltd is unable to control the setting of these cookies, therefore we suggest you check these third-party websites directly for more information about their cookies and how to manage them.
If you decide to share our website content with friends and co-workers through social networks (LinkedIn, Facebook, Twitter etc), you may be sent cookies from these websites. Homelync Ltd is unable to control the setting of these cookies, therefore we suggest you check the third-party websites directly for more information about their cookies and how to manage them.
If cookies aren’t enabled on your computer, it will mean that your online experience on our website will be limited to browsing and researching. You may not be able to apply easily for jobs. If you’re not sure of the type and version of web browser you use to access the Internet, click the ‘help’ option at the top of your browser window and select the ‘about’ option.
Disclosure of your Information Inside & Outside of the EEA
We may share your personal information with selected third parties including:
- Clients for the purpose of creating deployment strategies and monitoring services.
- Tenants for the purpose of arranging IoT device installations and ongoing support.
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you.
- Sub-contractors including IoT device suppliers and installers, email marketing specialists and event organisers.
- Analytics and search engine providers that assist us in the improvement or optimisation of our site.
We may disclose your personal information to selected third parties:
- In the event that we sell or buy our business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Homelync Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third-party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their obligation to provide a service related to an IoT device.
- Satisfaction of their contractual obligations to us as our data processor.
- For the purpose of a contract in place or in contemplation.
- To fulfil their legal obligations.
Where We Store & Process Your Personal Data
The data that we collect from you will be in stored inside of the European Economic Area (“EEA”) however it may be transferred to, and stored at, a destination outside the EEA by third parties outside of the EEA for the purpose of providing an IoT enabled service such as environmental monitoring. It may also be processed by staff operating outside the EEA who work for one of our suppliers. This includes staff engaged in the provision of support services.
By submitting your personal data, you agree to this transfer, storing or processing. Homelync Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
All information you provide to us is stored on our secure servers. All data transfers will be encrypted (using SSL technology). Where we have given you (or where you have chosen), a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Our site has security measures in place to protect the loss, misuse and alteration of the information under our control. All personal data is stored on a secure database; a firewall is in operation to prevent hacking. Only current authorised Homelync employees have access to the database, and a unique ID and Password controls the access rights of these employees.
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining. We take the following action to try to ensure our data is accurate:
We keep in contact with you so that you can inform us of changes to your personal data.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
- The nature of the personal data
- Its perceived accuracy
- Our legal obligations
- Whether a contract has been entered into
- Accuracy of data analytics and insights
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Management (CRM) system.
All data captured and stored sourced from IoT devices is pseudonymised.
We also pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so. Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers or ‘pseudonyms’.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by contacting us at: email@example.com.
Our site may contain links to / from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies directly before you submit any personal data to these websites.
The GDPR Provides You with the Following Rights
The right to:
- Accuracy – request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Deletion – request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Objection – object to processing of your personal information where we are relying on a legitimate interest (or those of a third party); and there is something about your particular situation which makes you want to object to processing on these grounds. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Restriction – request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you. For example, if you want us to establish its accuracy or the reason for processing it.
- Transfer – request the transfer of your personal information to another party in certain formats, if practicable.
- Complain – make a complaint to a supervisory body. In the UK, this is the Information Commissioner’s Office (ICO). The ICO can be contacted at: https://ico.org.uk/concerns.
Access to Information
The GDPR and Data Protection Act 1998 (DPA), give you the right to access information held about you. You are also welcome to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the DPA and the GDPR once it is in force.
A subject access request can be submitted to: firstname.lastname@example.org.
Changes to Our Privacy Notice
Any questions, comments or concerns regarding this policy (and our data protection processes in general), can be addressed for the attention of the Data Controller at email@example.com