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LET’S SHIELD LIMITED – PRIVACY POLICY

Introduction

Privacy Policy. For the purposes of the Data Protection Act 1998 (“DPA”) and the European General Data Protection Regulation (“GDPR”) that came into force on 25 May 2018, the data controller, who is responsible for your personal data, is Let’s Shield Limited(Company Number 11640155) whose registered office is Sanderum Center, 38 Oakley Road, Chinnor, United Kingdom, OX39 4TW, which is referred to as “we”, “us” or “our” in this privacy policy. We are registered with the Information Commissioner’s Office, registration number: ZA509304.

We have appointed a Data Privacy Manager (“DPM”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights under DPA and/ GDPR, please contact the Data Privacy Manager using the following contact details:

Our contact details

Data controller: Let’s Shield Limited

Email address: support@letsshield.co.uk

Postal address: The Data Privacy Manager

Let’s Shield Limited

Sanderum Centre

38 Oakley Road

Chinnor

OX39 4TW

United Kingdom

Telephone number: 0800 1931198.

We are dedicated to DPA and GDPR compliance. Protecting your privacy online is an evolving area, and our website is constantly being modified to meet these requirements. If you have any comments or questions regarding this Privacy Policy, please do contact ourData Privacy Manager as set out above. Whilst we cannot guarantee data privacy perfection, we will address any matter to the best of our abilities, as soon as possible.

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you approach the ICO, so please contact our Data Privacy Manager in the first instance.

Changes to this Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review and reserve the right to change this Privacy Policy at any time.  If we make changes to this Privacy Policy, we will take reasonable steps to bring these changes to your attention by posting all such changes prominently on our website for a reasonable period. This Privacy Policy was last updated on 1stMarch 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What is this Privacy Policy for?

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of our website www.letsshield.co.uk, including any data you may provide through our website when you purchase products or services from us,  and governs the privacy of the users (referred to as “you” or “your” in this Privacy Policy”) who choose to use it. This Privacy Policy sets out the different areas where user privacy is concerned and outlines the obligations and requirements of you, the users of the website and of us, the website owners. Furthermore, the way we process, store and protects user data and information will also be detailed within this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using you data. This Privacy Policy supplements our other notices and privacy policies and is not intended to override them.

Our Website Use Terms and Conditions

Your use of our website is governed by our Website Use Terms and Conditions, which appear on our website and refer to this Privacy Policy. Before using our website you, and all other users, are required to confirm your agreement to those terms and conditions (including this Privacy Policy).

What personal information we collect about you

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, maiden name, last name, user name or similar identifier, marital status, title, date of birth and gender.
  • Contact Data: includes billing address, delivery address, email address and telephone numbers.
  • Financial Data: includes bank account and payment card details.
  • Transaction Data: includes details about payments from and to you and other details of products and services you have purchased from us.
  • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
  • Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data: includes information about how you use our website, products and services.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data,such as statistical or demographic data, for any purpose. Such Aggregated Data could be derived from your personal data but is not legally considered to be personal data as this data will notdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data with that of other users to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We require customers who register to order our products or use the services  offered on our website to provide contact information, such as their name, company name (Identity Data), address, phone number, and e-mail address (Contact Data), and (in the case of paying customers) billing information (Financial Data), such as billing name and address, and the number of users within the organisation that will be using the Services (Usage Data). Customers of our products or services may use our website to host data and information that includes personal data (“Data”).

We may collect certain information about how you use our products and services. This may include your IP address, geographical location, browser type, referral source and similar information (Technical and Usage Data). This information may be collected by a third-party website analytics service provider on our behalf and may be collected using cookies.

We do notcollect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your heath, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have ordered from us, but we will notify you if this is the case at the time.

When a report is created through our website and the products/ services offered on it, photographs and images of the relevant property and other information will be requested from you. It is important that any photographs or images which you submit do notinclude images of people.

How is your personal information collected?

We use different methods to collect personal data from and about you including:

  • Direct interaction: you may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email, telephone, post or otherwise. This includes personal data you provide when you:

– apply for our products or services;

– create an account on our website;

– subscribe to our services or publications;

– request marketing information to be sent to you;

– enter a competition, promotion or survey; or

– give us feedback or contact us.

  • Automated technologies or interactions: as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy (https://www.letsshield.co.uk/cookie-policy/) for further details.
  • Third parties or publicly available sources: we will receive personal data about you from various third parties and public sourcesas set out below:
  • analytics providers such as Google based outside the EU;
  • advertising networks such as Facebook, based inside or outside the EU;
  • Search information providers such as Safari, Firefox, Bing etcbased inside or outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as ChargeBee based outside the EU;
  • Identity and Contact Data from data brokers or aggregators based inside the EU; 
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU;

Data accuracy

We will store personal data in as few places as necessary. Our staff members are trained not to create unnecessary additional data sets. Our staff members are also trained to take every opportunity to ensure data is updated. For example, by confirming your details when you call us.

We provide functionality on our website for you to update the information we hold about you. Inaccuracies should be updated as soon as they are discovered.

Where is personal information processed and how it is stored

Our products and services are cloud-based. Our data processing operations take place in the UK. Personal data for users within the European Economic Area will not be transferred to a country or territory outside the European Economic Area.

User sensitive data is encrypted. All data is encrypted during transit.

Our website and cookies

We take a proactive approach to the privacy of users of our website and ensure the necessary steps are taken to protect the privacy of users throughout their visiting experience. Our website complies with all UK national laws and requirements for user privacy.

Please also view our Cookie Policy (https://www.letsshield.co.uk/cookie-policy/) and Website Use Terms and Conditions (https://www.letsshield.co.uk/terms-and-conditions/ ) that can be found on our website.

How we use the personal information we collect

We will only use your personal data when the law (applicable in the UK) allows us to. Most commonly, we will use your personal data in the following circumstances:

  • to provide products or  services to you and for ongoing utilisation by individuals and organisations, for example, you are asked to provide an email address when registering for our products or services in order to receive a username and/or password;
  • where we need to perform the contract we are about to enter into or have entered into with you, for our products or services;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • where we need to comply with a legal obligation.

To find out more about the types of lawful basis that we may rely on to process your personal data, please refer to the Glossary at the end of this Privacy Policy.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will obtain your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal information

We set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using it. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the following table.

Purpose/ Activity:

 

Type of data: Lawful basis for processing, including basis of legitimate interest:

 

To register you as a new customer

 

(1)  Identity

 

(2)  Contact

Performance of a contract with you
To process and deliver your order for our products or services including:

(a)  to manage payments, fees and charges

 

(b)  to collect and recover money owed to us

 

(1)  Identity

 

(2)  Contact

 

(3)  Financial

 

(4)  Transaction

 

(5)  Marketing and Communications

(a)  Performance of a contract with you

 

(b)  Necessary for our legitimate interests (to recover money due to us)

To manage our relationship with you which will include:

(a)  to notify you about changes to our terms and conditions or this privacy policy;

 

(b)  to ask you to leave a review or take a survey

(1)  Identity

 

(2)  Contact

 

(3)  Profile

 

(4)  Marketing and Communications

(a)  Performance of a contract with you

 

(b)  Necessary to comply with a legal obligation

 

(c)  Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and Services

To enable you to participate in a prize draw or competition or to complete a survey (1)  Identity

 

(2)  Contact

 

(3)  Profile

 

(4)  Usage

 

(5)  Marketing and Communications

(a)  Performance of a contract with you

 

(b)  Necessary for our legitimate interests (to study how customers use our products/ Services, to develop them and grow our business

To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(1)  Identity

 

(2)  Contact

 

(3)  Technical

(a)  Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

 

(b)  Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve you (1)  Identity

 

(2)  Contact

 

(3)  Profile

 

(4)  Usage

 

(5)  Marketing and Communications

(6)  Technical

Necessary for our legitimate interests (to study how our customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/ services, marketing, customer relationships and experiences

 

(1)  Technical

 

(2)  Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about products or services that may be of interest to you

 

(1)  Identity

 

(2)  Contact

 

(3)  Technical

 

(4)  Usage

 

(5)  Profile

 

(6)  Marketing and Communications

 

Necessary for our legitimate interests (to develop our products/ services and grow our business).

 

We will not process your personal data for any other purpose than that stated, as explicitly set out in this Privacy Policy.

Any photographs or images that are uploaded to our Platform by you remain your intellectual property. By uploading any such photographs or images to our Platform for us to provide the products or services you require, you give us the right (an irrevocable worldwide royalty free licence) to host, store, modify, reproduce, communicate, publish and distribute those photographs or images, only to the extent permitted by this Privacy Policy. By uploading any photograph or image, you confirm that you have the right to upload that photograph or image to our Platform and for us to use it in the ways outlined in this Privacy Policy. We shall have the right to limit the size and nature of any photographs or images that are uploaded by you to our Platform.

All information that you submit to us, other than photographs or images, will become our intellectual property, but can only be used by us to the extent permitted by this Privacy Policy.

Your personal data may also be processed by us within our Platform to protect a landlord’s legitimate interest in maintaining its property or properties that are managed using our products or services.

Marketing

We strive to provide you with choices regarding certain uses of your personal data, particularly around marketing and advertising. You can ask us to stop sending you marketing messages at any timeby following the opt-out links on any marketing message sent to you or bycontacting us at any time via support@letsshield.co.uk.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.

Third- party marketing

We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing

You can ask us or third parties to stop sending you marketing messages at any timeby following the opt-out links on any marketing message sent to you orcontacting us at any time via support@letsshield.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/ service purchase, or a product/ service experience.

Data Security

We have put in place appropriate security measures to prevent your personal data being accidentally lost, used or accessed in an unauthorised or unlawful way, altered or disclosed. In addition, we limit access to your personal data to those of our staff, agents and contractors and other third parties who have a business need to know such information. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any such breach where we are legally required to do so.

Staff training and security

Our staff members have regular training reviews, and as a company, we operate with stringent training operating procedures, some being:

  • To ensure our staff understand their responsibilities when processing data
  • To NOT store data on paper
  • To lock their computer screen when it is not in use
  • To NOT discuss or share sensitive data informally
  • To NOT send personal sensitive information via email.

 

Data retention – how long we will keep your personal information for

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements (“ObligatoryRequirements”). We may retain your personal data for longer in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate period for which to retain your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable Obligatory Requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes.

In some circumstances you can ask us to delete your personal data (or some of it): see Your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may continue to hold and use such anonymised information indefinitely without further notice to you.

Save as set out above (and subject, in particular, to any Obligatory Requirements), we will retain your personal data for no longer than is necessary, for the purposes for which it is processed, as set out above. This means that (save for those types of data we are required to hold for longer, including under the Obligatory Requirements) we will usually delete or anonymize your personal data within 60 days following the completion, expiry or termination of any agreement with you to purchase our products or services. During the term of any agreement with you to purchase our products or services, we will retain your personal data for the duration of the applicable limitation period, such period to commence on the last date on which the data was processed.

Email newsletter

Our website operates an email newsletter program, used to inform subscribers about products and services supplied by us through this website, as well as broader articles and updates relating to the rental property industry. Users can subscribe through an online automated process, should they wish to do so, but do this at their own discretion. Some subscriptions may be manually processed through a prior written agreement with you.

Subscriptions are taken in compliance with UK ‘spam laws’, detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the DPA and GDPR. No personal details are passed on to third parties, nor shared with companies/people outside of our ownership or control. Under the DPA, you may request a copy of personal information held about you by our website’s email newsletter program. If you would like a copy of the information held about you, please contact our Data Privacy Manager as set out above..

Email marketing campaigns published by us or our website, may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include (but is not limited to): the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. Please refer to our Cookie policy under  “How is your personal information collected? – Automated technologies or interactions” which can be found at https://www.letsshield.co.uk/cookie-policy/

This information is used to refine future email campaigns and supply you with more relevant content based around your activity.

External links

Our website may include links to external third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. Although we only look to include quality, safe and relevant external links on our website, we do not control these third party websites and are not responsible for their privacy policies. You should always adopt a policy of caution before clicking any external web links mentioned on our website and we would encourage you to read the privacy policy of every website you visit.

We cannot guarantee or verify the contents of any externally linked website. You should, therefore, note that you click on any external links on our website at your own risk.

Social media platforms

Communication, engagement and actions taken through external social media platforms that we and our website participate on, are subject to the terms and conditions, as well as the privacy policies, held with each social media platform respectively.

You are advised to use social media platforms wisely and to communicate with or engage upon them with due care and caution regarding your own privacy and personal data. We will ever ask you for personal or sensitive information through social media platforms and we encourage you if you wish to discuss sensitive personal details, to contact us through primary communication channels, such as telephone or email.

Our website may use social sharing buttons, which help share web content directly from web pages to the social media platform in question. You are advised, before using such social sharing buttons, that you do so at your own discretion and you should note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened links in social media

We and our website may share web links to relevant web pages, through our social media platform accounts. By default, some social media platforms shorten lengthy URL’s [web addresses] (this is an example: http://bit.ly/zyVUBo).

You are advised to exercise caution and good judgement before clicking any shortened URL’s published on social media platforms by our website.  Despite using our best efforts to ensure that only genuine URL’s are published, many social media platforms are prone to spam and hacking and therefore we cannot be held liable for any damages or implications caused by you visiting any shortened links.

Third Party Information

Our third-party suppliers have all complied with GDPR data protection from our internal risk assessments and their details follow:

  • Mailchimp Privacy Policy – This is our marketing service provider. It is only used to send information to personal users who have opted in to receive our marketing. Details of their GDPR policy can be found at https://mailchimp.com/legal/privacy/ or please refer to our website for further opt in / out information.
  • Chargebee Privacy Policy – This is our payments hosting provider. They are based in USA and India. Please visit their website to view their privacy policy.
  • New OrbitPrivacy Policy – This is our software and maintenance provider, who are based in the UK. Please visit their website to view their privacy policy.
  • Webinar-jam (Genesis Digital)Privacy Policy – This is our webinar hosting provider. They are based in USA. Please visit their website to view their privacy policy.

We may also share your personal information with the following third parties from time to time:

  • Professional advisers, including lawyers, bankers, auditors and insurers based in the UK who provide us with consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, our regulators and other authorities based in the UK which require reporting of processing activities in certain circumstances.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of any new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request to erase your personal data for specific legal reasons which we will notify to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction on the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in any of the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager as set out above.

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to anyone who has no right to receive it. We may also need to contact you to ask you for further information in relation to your request to help speed up our response.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than one month to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

GLOSSARY

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best products/ services and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Privacy Manager.

Performance of contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Platform means the Let’s Shield Platform, our bespoke software tool which provides training, assessment and reports regarding the health and safety compliance of rental property, access to which may be purchased via our website (with any customer who does so being provided with separate log in details and a link to reach the Let’s Shield Platform.

 

Further Information

If you have any questions or require any further information in connection with this privacy policy, please contact our Data Privacy Manager as set out above.

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