Mashroom Ltd. – Privacy Policy

Introduction

Welcome to Mashroom’s privacy policy. 

Mashroom respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Mashroom collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account on this website. 

This website is not intended for children and we do not knowingly collect data relating to children.

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 your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Mashroom is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy). Mashroom is registered at the ICO with number ZA487305.

We have appointed a data protection officer (DPO) 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, please contact the DPO using the details set out below. 

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: MASHROOM LTD

Email address: DPO@mashroom.com

Postal address: 21 Navigation Business Village, Navigation Way, Ashton-On-Ribble, Preston, PR2 2YP.

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

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 22 June 2020. 

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, 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, last name, username or similar identifier, title, date of birth and copies of any documents you have provided for identification purposes (for example, your passport or driving licence number and utility bill).
• 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 to and from you and other details of 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 this 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 and services and about your property searches. 
• Property Data includes information relating to the properties such as images of properties, property asking prices, sales history and sold prices, property addresses, property locations and property descriptions, floorplans, letting arrangements of users and rental information about the properties, and information relating to the maintenance of properties.     
• Information you give to us includes any information that you may provide to us when applying for our services through our website. For example your employment history, employment status, availability to view a property, your preferred moving date, details of your household income for calculating affordability of rent, indication of whether you are moving alone or with others, and your feedback on a property that you have viewed. 
• Information we receive from third parties includes information we receive from third party providers such as Rentprofile, in relation to referencing screening checks.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, your messages you send to us, agents and other third parties through us, recordings of your calls with us and with other third parties using phone numbers shown on our website.

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

Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “sensitive personal data”. Generally, we try to limit the circumstances where we collect and process sensitive personal data. Where we process sensitive personal data on behalf of a user, we do so on the basis that the user has established a lawful exception to the prohibition on processing sensitive personal data under Article 9 of the General Data Protection Regulations.

If you fail to provide personal data

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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

Sharing your Personal Data

Mashroom may share your personal data in a number of ways:

a) Your personal data may be used by Mashroom as the data controller and shared with our Business Partners and their respective sub-contractors with whom we may share data for the administration of services provided to you as is necessary and explained within this privacy policy. 

b)  Mashroom will also share personal data with our Business Partners who provide various services.  Our Business Partners may be data controllers in their own right. 

Mashroom also acts as an Insurance Broker, if we are providing this service for you we will present quotes and incept policies from our panel of insurers. Some of these are intermediaries who will provide quotes to us from their own panel of insurers.

In order for us to provide our insurance broking services, your personal data is shared between Insurance Participants, including our insurance panel members, some of which you will not have direct contact with. Whilst Mashroom is the data controller of any data it collects or uses, during the insurance journey, other Insurance Participants may also be a data controller.

c)  We may also share your personal data with law enforcement bodies, reinsurers and regulators such as the Financial Conduct Authority, as is necessary and permitted by law. In addition, in the event of a merger, acquisition, or any form of sale of some or all of our assets to a third party, we may also disclose your personal data to the third parties concerned or their professional advisors as is necessary.

d)  To assist us in providing services to you, it is necessary for us to use third party suppliers. In using these third party suppliers, we often have to share and allow access to personal data to enable those third party suppliers to carry out the relevant services. If third party suppliers are using personal data to provide services on our behalf, they are known as ‘data processors’. Examples of important areas where we use third party suppliers (and therefore data processors) include for the purposes of:

• web and data hosting;
• cloud software;
• claims management;
• print production;
• market research;
• pricing and statistical analysis;
• providing credit;
• credit searches;
• brand and product development;
• financial crime prevention including fraud;
• compliance monitoring, quality management and audit; and
• debt management and collection.

We will ensure that any data processor we use has entered into a contract with us which fully sets out the data processor’s duties, including in relation to protecting the processing of your personal data.

3. How is your personal data collected?

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

• Direct interactions. You may give us some personal data such as your Identity, Contact, Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service, newsletters or publications; 
  • request marketing to be sent to you; 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
  • Technical Data from analytics providers such as Google Ireland Limited, Gordon House Barrow Street Dublin 4 Ireland, Heap Inc of 460 Bryant Street 3rd Floor San Francisco, CA 94107 United States. 
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Rentprofile based inside the EU (RentProfile is owned and operated by Rentprofile Group Ltd, registered in England and Wales with company number 09650698).
  • Identity and Contact Data from publicly available sources such as Companies House, HM Land Registry and the Electoral Register based inside the EU.

We may also receive personal data about you from third parties such as:

• Companies to which we have outsourced the provision of specific services to you.
• Companies that provide us with data in accordance with privacy policies that include information that may be shared with us.

4. How we use your personal data

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

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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. 
• Where you have provided explicit consent.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent where we need to collect and process sensitive personal data and before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us. However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or parts of the services you have requested from us.

Purposes for which we will use your personal data

We have 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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 table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

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

Third-party marketing 

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

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time. 

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

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Profiling

We may from time to time profile your activity when using our services or our website. This profiling is limited in its scope to telephone and email enquiries you send to us. It only takes place to help us understand what sort of properties or services you may be interested in and/or to categorise your activity to help us determine how likely you are to require services from us. We may then contact you to offer our services, although we can only do so if we have a lawful reason to do so (known as a lawful basis of processing your personal data). You can always object to our profiling by emailing us here dpo@mashroom.com. Any profiling data that we hold about you will only be kept for a period of 12 months from the date of the last telephone or email you have sent to us.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Internal Third Parties as set out in the Glossary. 
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

7. Data security

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

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 our website; 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.

The computers that store the information are kept in a secure facility with restricted physical access and we use secure firewalls and other measures to restrict electronic access. If we are working with third parties, we will require them to have in place similar measures to protect your information.

Only employees who need access to your information to perform a specific job are granted access to personally identifiable information. We may require you to co-operate with our security checks before we disclose information to you.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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

8. Data retention

How long will you use my personal data for?

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

To determine the appropriate retention period for 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 legal, regulatory, tax, accounting or other 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 and other purposes such as to resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our services.

In some circumstances you can ask us to delete your data: 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 use this information indefinitely without further notice to you. 

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 6 years.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

• Request access to your personal data.

• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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. 

10. 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 service/product and the best and most secure experience. We make sure 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 us.

Performance of Contract means processing your 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.

THIRD PARTIES

Internal Third Parties

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

External Third Parties

• Service providers who deliver our services, such third parties who provide IT and system administration services in technical, payment and delivery, advertising networks, analytics providers, search information providers, and credit reference agencies that could be based in or outside the EEA.
• Independent contractors commissioned by Mashroom, in the event that you request property maintenance services via our website. These may include: suppliers of Energy Performance and Gas Certificates in the UK; suppliers of floor plans, inventory checks and other property service providers in the UK; suppliers of home photography and floor plans in the UK); suppliers of surveys; insurance providers in the UK, mortgage providers in the UK).
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Other users of our website, for example, we share tenant information with landlords and vice versa.
• Credit and debit card companies, credit reporting agencies and fraud control service providers, to process payments and (where necessary) carry out fraud controls.
• In response to legal and valid requests from governments and law enforcement agencies, such as customs and immigration authorities and fraud and organised crime agencies.
• Third parties such as the police and regulatory authorities, to protect our rights and properties or the safety of our customers, employees and assets.

YOUR LEGAL RIGHTS

You have 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, though we may need to verify the accuracy of the 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 continuing 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified 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 those 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 of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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. 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.