This version effective from 1 November 2020.

EMPIENT values your trust, particularly when it comes to your personal data.

This policy explains what data, including personal data, we collect from and about you when you use:

• The EMPIENT Tenant App mobile application software provided by Optus Homes Ltd (the App) on behalf of the person or company with whom you have a tenancy agreement (the Landlord).
• Any of the services accessible through the App (Services).

We appreciate there’s a lot of detail, but it’s important that you read this policy to ensure you’re fully informed about how we use your personal data and your rights.

We may need to make changes to this policy occasionally, to reflect any changes to our services or legal requirements. We’ll notify you of any important changes via the App or by email before they take effect.

If you’ve got any questions about this policy, please email us at info@optus-homes.com

Who we are

We are Optus Homes Ltd, a limited company registered in England and Wales under company number 12429269. Our registered address is 56 Ashleigh Avenue, Egham, England, TW20 8LA.

Under UK data protection law, we are acting as a ‘processor’ of your personal data on behalf of your Landlord, who will be acting as a ‘controller’ of your personal data.

The personal data we collect

When we talk about ‘personal data’, we mean any data that identifies or can be used to identify you. This doesn’t include data where your identity has been removed (anonymous data). The types of personal data collected by and about you through our Website and App include:

Biographic data: When you first use the app, you may be asked for information such as your first and last name, month and year of birth, gender, profile image (optional) and email address.

Contact data: We ask you for your name and email address when signing up to use the App

Survey data: When you use the App, you may be asked to complete questionnaires or surveys related to the Services by us, or by your Landlord

Communications data: This includes any emails that you send to us and the information you communicate to, and receive from, your Landlord whilst using the Services

Transactions data: We don’t store or have any access to your credit or debit card details when you use the App to carry out any transactions using the Services, however we can see details of your transactions

Technical data: Our App uses cookies (see below) which collect the IP address assigned to you or someone who provides you with Internet access (although this is anonymised at the earliest possible opportunity), information about your device (including type, operating system, browser, resolution and time zone setting), which country you’re based in, and how you interacted with the content on our App and the Services

Where we get your personal data from

As long as you are using our App or the Services, we will only collect your personal data from you, or your Landlord.

What we use your personal data for

This section is really important as it explains what we’ll use your personal data for, and the legal grounds relied on by us for those purposes.

Under UK and EU data protection law there are six legal grounds that we may rely upon, the most relevant being where:

• you’ve given your consent to us using your personal data for specific purposes
• use of your personal data is necessary for us to enter into and perform our contract with you
• use of your personal data is necessary to comply with any legal obligation on us
• use of your personal data is necessary to pursue our legitimate interests and those interests are not outweighed by your fundamental rights and interests

We collect the following types of personal data, for the following purposes, using the following lawful grounds for processing the personal data:

• To install the App and register you as a new App user – we may collect Identity, Contact, Financial and Device data, based on the following lawful basis for processing: your consent.
• To deliver Services including communicating with your Landlord – we may collect Identity, Contact, Financial, Transaction, Device, Marketing and Communications, and Location data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to recover debts due to us).
• To manage our relationship with you including notifying you of changes to the App or any Services – we may collect Identity, Contact, Financial, Profile, and Marketing and Communications data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services; necessary to comply with legal obligations (to inform you of any changes to our terms and conditions).
• To enable you complete a survey – we may collect Identity, Contact, Device, Profile, and Marketing and Communications data – based on the following lawful bases for processing: your consent; performance of a contract with you; necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business).
• To administer and protect our business and this App including troubleshooting, data analysis and system testing – we may collect Identity, Contact and data – based on the following lawful bases for processing: necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).
• To deliver content and advertisements to you; To make recommendations to you about goods or services which may interest you; To measure and analyse the effectiveness of the advertising we serve you; To monitor trends so we can improve the App – we may collect Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, and Location data – based on the following lawful bases for processing: your consent; necessary for our legitimate interests (to develop our products/Services and grow our business).

We may use your personal data for purposes which are closely related to any of the above purposes. If we want to use your personal data for any unrelated purposes, we’ll let you know about this in advance.

Who we share your personal data with

We don’t sell your personal data for marketing purposes and we never will.

We share your personal data with your Landlord. Your Landlord will collect, use and process your data in accordance with the Landlord’s own privacy policy, which you should also read.

The only people that will have access to your personal data include:

• your Landlord
• our staff (who are either employed by us or engaged by us under contracts which include strict confidentiality and data protection obligations on them)
• our technical service providers, such as our developers, hosting providers, email marketing t