Swipe Living Limited (“we”, “us” or “our”) is committed to protecting and respecting your privacy.
You can contact us using the details provided at the end of this Policy in the “Contact Us” section.
THE TYPE OF INFORMATION WE COLLECT FROM YOU AND HOW WE WILL USE IT
We will collect various types of personal information from you when you register to use our app, whether you use it to browse, secure and manage your student accommodation, or only wish to download it to access offers and events from third party providers or to view job adverts. Further details of how we use your personal data are set out below.
In this section, we have indicated with asterisks whether we need to process your personal data:
- * = to perform our contract with you to provide the services via our app;
- ** = to pursue legitimate interests of our own or of third parties, provided your interests and fundamental rights do not override those interests;
- *** = to enable us to comply with our legal obligations; and/or
- ****= with your consent.
Registering to use our App
We will need to collect the personal data listed in Section A below from you in order to enable you to register to use our app* and to create an app user profile*. If you do not provide this personal data to us then you will be unable to register to use our app.
You can also voluntarily provide the personal data listed in Section B below to be displayed on your profile and be visible to other users of our app, but you do not have to provide it in order to register.
- personal contact details including name, address(es), telephone number(s) and personal email address(es);
- date of birth;
- student ID number;
- university or college; and
- course and year of study.
- personal description; and
Requesting a Viewing from a Landlord/Managing Agent
You may use our app to browse student accommodation and request a viewing from a landlord/managing agent. If you request a viewing from a landlord/managing agent via our app, we will provide your full name, telephone number and email address to the relevant landlord/managing agent so a viewing can be arranged*.
Connecting with your Landlord/Managing Agent
Once you have entered into a tenancy agreement with a landlord, your landlord/managing agent will provide you with a unique reference code in order for you to connect with them via our app. On entering this unique reference code into our app, certain in-app functions will be made available to you and we may process the personal data you provide to us when using these functions in order to provide these services to you. Such functions include:
- storing tenancy related documentation*;
- communicating with the landlord/managing agent, for example, regarding maintenance requests or rental payments*;
- communicating with other app users (such as your new housemates who share the same landlord/managing agent)*; and/or
- making a one off payment or setting up a direct debit directly to a landlord/managing agent using a third party payment provider, the identity of which will be notified to you at the time of payment and otherwise by us from time to time via our app*. In order to enable this function, the third party payment provider will need to collect your bank account details from you. We will not view or collect your bank details.
We will also collect proof of your identity (such as passport details) to provide to the landlord/managing agent if required by them for purposes such as key collection, security verification or to assist with “right to rent” checks. When we request proof of identity from you, we will inform you of why they need this proof of identity and how they will use it. Provision of proof of your identity is not mandatory to register to use the app, it is only collected from you if specifically requested by your landlord/managing agent.
Other Uses of our App
We will also collect the personal data you provide when you use our app to:
- allow you to participate in interactive features of our service, when you choose to do so*;
- access offers and promotions or enter competitions via our app provided by third parties**; and/or
- browse and respond to job advertisements uploaded by third party employers*.
If you are looking for a room in a house share, you can choose to voluntarily provide us with information about your hobbies and interests, so that we can use this data for the purpose of attempting to match you to suitable housemates.
We will also process personal information you provide us with in order to:
- provide you with information about our services, offers, events or promotions we feel may interest you where permitted by law**/****;
- notify you about changes to the services provided through our app**; and
- ensure that content from our app is presented in the most effective manner for you and your device**.
Automatic Personal Data Collection
When you visit our app we will automatically collect technical information relating to the operating system, platform and device you use.
We will use the above information in order to:
- to administer our app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes to comply with our legal obligations**/***;
- to improve our app to ensure that content is presented in the most effective manner for you and for your computer / device**; and
- as part of our efforts to keep our app safe and secure to comply with our legal obligations**/***.
We will not carry out any solely automated decision-making using your personal data.
Change of Purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will usually notify you and we will explain the legal basis which allows us to do so.
DISCLOSURE OF YOUR INFORMATION
We will share your data with the third parties set out below:
- landlords/managing agents (as set out above);
- our third party payment providers (as set out above); and
- our software developer Sonin Agency in order for it to have access to our app to provide maintenance, updates and support services to us.
We enter into agreements with such third parties to ensure that they respect the security of your data and use it only in accordance with data protection laws.
We will disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- if Swipe Living Limited 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; and/or
STORAGE OF YOUR PERSONAL DATA
We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Policy, and for as long as we are required to keep it for legal purposes. Once you are a registered user, we will keep your personal data for the duration of your registration and for six years after your registration ceases for legal purposes.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, such as the use of SSL and hashing passwords stored on the database with Bcrypt. 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 app; any transmission is at your own risk.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Data protection laws provide you with the following rights to:
- request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- 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;
- 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);
- 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;
- request the transfer of your personal information to another party; and
- complain to the supervisory authority, which in the United Kingdom is the Information Commissioner’s Office.
You also have the right to object to the 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 this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If we rely on your consent to process your personal data, for example if we need your consent to send you direct marketing, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using any of the details set out below in the “Contacting Us” section. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO OUR POLICY
Any changes we make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy.
If you have any queries, comments or requests regarding this Policy or you would like to exercise any of your rights set out above, you can contact us in the following ways: