PROPIERGE PRIVACY AND COOKIES POLICY
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. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of applicable data protection law, we are the data controller in relation to any personal data that you provide to us via the Platform. In relation to any personal data that you provide to us via the Platform in connection with the Services, we are merely the data processor. The data controller of any such information will be the property manager who has subscribed for the Service and authorised your use of the Platform in relation to that subscription.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
i) “Information you give us (Submitted information)”: You may give us information about you by filling in forms on the Platform or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the Platform, download the Platform, make an in-Platform purchase or order third party services using the Platform, and when you report a problem with the Platform or our Services. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, age, username, password and other registration information, your location, photos or other details about your property or use of the Services.
ii) Information we collect about you and your Device. Each time you visit or use the Platform, we may automatically collect the following information:
Technical information, including the type of Device you use, a unique Device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting, (“Device Information“);
Details of your use of or visits to the Platform including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (“Log Information“).
If you contact us, we may keep a record of that correspondence.
Location information. We may also use GPS technology or other technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you do not wish to use this particular feature then you may turn off this functionality using your Device or by altering the settings on your Platform, however this will limit the functionality of the Platform which is available to you.
Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, users of the Platform who provide services to other users, such as property managers, property owners, tenants or guests, or vice versa, our sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Some features require browser settings to be enabled. Consult your browser´s Help section for information on how to change this setting.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We will be using the following cookies:
Session: This is the normal way to implement sessions
i) Token CSRF: this is to prevent hacker attacks (http://en.m.wikipedia.org/wiki/Cross-site_request_forgery)
We may use the following cookies:
i) Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform, use a shopping cart or make use of e-billing services.
ii) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
iii) Functionality cookies. These are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
iv) Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform.
The cookies we use are not currently configured to expire after a specific period.
We may also collect and store personal data on your Device, for the purposes set out in this privacy and cookies policy, using web browser storage technology (HTML5).
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
i) Submitted Information:
- To personalise your visits to the Platform, offer you tailored content and otherwise improve our Service;
- So that you have a more relevant and beneficial experience, and to analyse and understand how the Platform is used;
- To provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you, where you have provided your express consent;
- To notify you about changes to the Platform;
- To conduct market research or carry out technical and statistical analysis to monitor our Service or the Platform;
- To anonymise Personal Information and preparing aggregated data reports showing anonymized information for the purpose of advising ourselves, Merchants and our business partners regarding past and potential future patterns of spending, fraud, and other insights that may be extracted from this data;
- To prevent and prosecute fraud, or meet legal, regulatory, insurance or security requirements.
ii) Device information: No Device information is required for the application.
iii) Log information: No logs will be stored in the Device or Platform apart from the one provided by the operating system, however, server error log information will be used for maintenance purposes.
iv) Location information: No location information will be used in the Platform, however all information relevant to location will be forwarded to third party map applications.
v) Third Party Information: Maps, as above.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. Therefore, your personal data, including the data collected using cookies. may be used for behavioural advertising, allowing us and our advertisers to show you ads by means of analysing your browsing habits.
DISCLOSURE OF YOUR INFORMATION
We may disclose some or all of the data we collect from you when you download or use the Platform to any subcontractor or utility provider to the extent reasonably necessary to enable us to provide the Services.
We may disclose your personal information to any member of our group, which means any subsidiaries, our ultimate holding company and its subsidiaries.
We may disclose your personal information to third parties:
i) In the event that we are proposing to sell any part of our business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets;
ii) If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
iii) If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or enforcement request from the state or any court or regulatory body;
iv) In order to enforce or apply the EULA, or the terms of an agreement we enter into with you or to investigate potential breaches; or
v) In order to protect the rights, property or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE AND HOW WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted with Secured Sockets Layer technology for web and mobile data encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you and get your consent (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. You can consent to such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to ask us not to process your personal data for marketing purposes at any time by contacting us at the details stated at the start of this Policy.
The Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Platform or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION
In accordance with applicable data protection law, you may exercise your rights of access, rectification, cancellation and opposition regarding your personal data at any time and at no cost by contacting us at the details stated at the start of this Policy.
Please note that any requests to exercise any of the previous rights must comply with all the requirements set forth under applicable data protection laws, and in particular:
(i) the request should be in writing and signed,
(ii) a photocopy of the passport or another official identification document should be attached to the request, and
(iii) the signature in the request should match the one in the passport.
You can also access your personal data via the Platform if you have purchased a Subscription to the Platform.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). We may charge a small administration fee (not exceeding the maximum permitted by law in England) in relation to fulfilling a request for access to Personal Information.
CHANGING OR DELETING YOUR INFORMATION
You may review, update, correct or delete the personal information you provide to us in the course of the use of the Service via Platform or by contacting us. If you completely delete any or all such information then your account may become deactivated or certain functionality may be reduced. If you would like us to delete your account in our system, please contact us with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honour your request. We may retain an archived copy of your records as required by law.