Keyholder Privacy Notice
Last updated: June 3rd, 2023
This Privacy Notice includes important information about your personal data and we encourage you to read it carefully.
1. INTRODUCTION
Keyholder is a communication platform for tenants, prospective tenants, landlords, property managers, real estate brokers and agents, and sub-lessors. Keyholder is a trading name of Credit Score Technology.
Users of Keyholder are:
Users of the platform who are looking to rent a home and use Keyholder to provide information about themselves to landlords and agents. These users can create a profile, and are known as “Tenants”.
Users of the platform who use it to receive information about Tenants, who are known as “Landlords”. For the purposes of Keyholder, the definition of Landlord includes anyone acting on behalf of a Landlord, such as Letting Agents and Property Managers too.
If you are a tenant or someone looking to rent a property, you are referred to as a "Tenant". If you own or manage a property that you rent out, or wish to rent to Tenants, or you help Landlords rent to Tenants, you are referred to as a "Landlord" (which includes institutional landlords).
Keyholder acts as both a Data Controller and a Data Processor when handling personal data, depending on your relationship with Keyholder, and you have rights around how we handle your data, as explained in this notice.
‘Data Controller’ is the legal term that means the organisation that is responsible for and controls the processing of your personal data, when you have a direct relationship with Keyholder.
‘Data Processor’ is the legal term that means an organisation that processes personal data on behalf of a Data Controller with whom you have a relationship, such as a Landlord that contracts with Keyholder to process your data on their behalf.
'Personal Data’ is the legal phrase used to describe any information that relates to an individual person. For example, name, address, email address, IP address, date of birth, health information, ethnicity, religious beliefs, financial information, and more.
‘Processing’ is the legal word that means collecting, storing, sharing, using, or anything else that we do with your Personal Data.
Our client is the Data Controller responsible for the management and oversight of personal data relating to the application process for rental properties. Keyholder serves as Data Processor and processes personal data on behalf of our clients. Keyholder recommends that you read and familiarise yourself with our clients privacy notices which set out how your data will be used.
2. INFORMATION WE COLLECT
Landlords, Letting Agents, and other business contacts
When you have a business relationship directly with us, we process your name, contact details, and other information produced through our interactions, to enable us to manage our working relationship with you, on the basis of our business’s Legitimate Interests to be able to run our business, and provide our services to those who need them, in the most effective way.
You have the right to object to any of our processing of your personal data and we will assess any objection sensitively.
When you create a ‘Landlord’ account, request a demonstration, submit a request to us, engage in live chat on our website, have cookies and similar set on your device when you visit our website, refer someone, provide payment information, or otherwise contact us or provide information to us, we will collect and process personal data from you including:
- First and last name,
- Email address,
- Phone number,
- Mailing address,
- Account name (but not passwords, which are encrypted),
- Any images you upload to your profile,
- Location information, and
- IP address.
In addition to the information we request from you, you may choose to provide us with additional information on a voluntary basis through the Service. When using the "Notes" feature or communicating with us through email, chat, or message forms, please be cautious, especially with sensitive personal information or anything that may violate our Terms of Use, such as discriminatory or illegal content.
We also collect information about Landlords and other business-related contacts from public sources, including your business website and online presence, as part of building a relationship with you.
Tenants
We also carry out a large amount of processing of personal data on behalf of our clients, in order to provide our services to them. Our clients are Landlords and Letting Agents who use our Services to collect information about their prospective Tenants. In these cases, the client is the ‘Data Controller’ and has identified the legal basis for the data being processed, and we carry out the processing on their behalf, using our expertise.
The data we process will vary depending on the circumstances, but may include:
- First and last name,
- Email address,
- Phone number,
- Mailing address,
- Your housing history,
- Employment / financial information,
- References,
- Family / household information,
- Account name (but not passwords, which are encrypted),
- Any images you upload to your profile,
- Location information, and
- IP address.
Tenants can transition from using our Services at the request or instructions of a Landlord to being a direct user of our Services. This means that you can ask us to share your Tenant profile with a number of Landlords, not just the one who asked you to provide information to us.
If you transition to being a direct user of the Keyholder Services, we are acting as a Controller of your personal data for the purposes of sharing your Tenant profile with any additional Landlords you may choose.
If you are a direct user, we will collect, store, share and otherwise process your data only as necessary for our Service Agreement with you, to provide the Services. You control which Landlords we share your Tenant profile with.
Third-Party Privacy Policies
Through the Service, including our web site, app, or any other links, you may be able to link to or otherwise utilise technology, software and services owned and controlled by third parties (“Third-Party Services”). Such use of Third-Party Services and submission of information through Third-Party Services will be subject to such applicable third party’s terms of use, terms of service, Privacy Notice and/or practices. You agree to look solely to the applicable third party and not to Keyholder to enforce your rights in relation this. When you have clicked on a third-party link, logo, or URL displayed or accessible through the Service which links you to any Third-Party Services, our Privacy Notice and Terms of Use no longer apply, and you must read the terms of use, terms of service, and Privacy Notice of the third party or contact the third party directly to see how your personal information will be handled on their website or service.
3. HOW WE USE YOUR INFORMATION
Landlords
If you are a prospective, current or former client, including Landlords and Letting Agents, or another type of business contact (e.g. supplier or prospective supplier) we use the information we collect for our legitimate business and commercial purposes.
The personal information you provide to us will allow us to communicate with you and provide the Service to you, depending on the aspects of the Service you utilise. We primarily use the personal information you provide and any general information we receive from you for the following business purposes:
- To create and manage your account;
- To process your orders, requests or applications submitted through the Service;
- For billing purposes;
- To facilitate communications between you and other users on the Service where appropriate;
- To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- To prevent and address fraud and threats of harm;
- To personalise your customer experience;
- To provide customer service and respond to requests;
- To monitor, analyse trends, usage, and activities;
- To improve our services, the interactions you have with our Service, and other Keyholder websites, apps, marketing, products, and services;
- To market products and services that may be of interest to you;
- To provide property management companies, agents, landlords, and other users of our service with the ability to offer you other products and services that may be of interest to you;
- To comply with and enforce applicable legal requirements, relevant industry standards, and our policies;
We keep track of your interactions with us, including but not limited to your activity within the Service.
Except as set forth in this Privacy Notice, or unless we have your consent, we will not share your personal information with any person or entity other than entities acting on our behalf, including our service providers (such as those needed to collect and maintain our servers and perform technology and related services).
In our Terms of Use, we prohibit the use of any information collected through the Service in violation of Irish law and any other applicable laws.
We may use information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Service (including information that has been de-identified or aggregated). We aggregate or de-identify information by either combining it with information about other users (aggregating your information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. We may use aggregated or de-identified information for any purpose except as prohibited by applicable law.
Tenants (Direct Users)
If we need your Personal Data for the purposes of the Service Agreement, and you prefer not to provide your data, we will not be able to enter into an agreement with you. We will sometimes send you communications - letters, emails, phone calls - when they are necessary for managing the agreement that we have with you.
If anyone in your household has additional needs or anything that is a risk to your household or to anyone else, that we need to know about so we can provide the service to you in the most appropriate way, such as health conditions or criminal information, we will collect that Data so that we can fulfil our legal obligations and protect our clients, colleagues, and the public.
Sometimes we use Personal Data about you for our own legitimate reasons, only where it is fair to you, including when we want to get feedback from you about our services. You can always tell us if you would rather not be asked for feedback. This is known as “objecting” to the processing of your Data.
Sometimes we use your contact details and other Personal Data to send you information we think will be useful to you (but is not necessary as part of our agreement with you.) This information will keep you up to date on the latest Keyholder news. If we do this through the post, for our own legitimate reasons, you can also object to this processing, by telling us to stop sending you that type of information and we will stop immediately.
If we want to send you this type of information using electronic methods, such as text or email, we will ask for your permission first. If you do give us permission, but later change your mind, you can tell us you don’t want to receive that information anymore and we will stop immediately.
If we ask your permission to use your Personal Data for any other reason, you can always change your mind, by letting us know, and we will stop using your Data in that way.
4. WHERE WE STORE YOUR PERSONAL INFORMATION
Landlords & Tenants
The personal data that we collect from you is processed in the European Economic Area (“EEA”) and stored on Amazon Web Services (Europe) Cloud Servers. A full list of our third party sub-processors and details of their privacy policies can be requested. Countries outside the EEA may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the European Commission; or (ii) any organisation which ensures an adequate level of protection in accordance with applicable data protection laws.
Your passwords are stored on Keyholder servers in encrypted form. We do not disclose your account details. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Keyholder will do its 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 measures.
5. DISCLOSURE OF YOUR INFORMATION
We disclose your personal information to our service providers (our Data Processors), including payments processors (currently Stripe) and database providers (to assist us in performing any contract we enter into, including providing the Website and the Services it enables), analytics providers, (to assist us in the improvement and optimisation of the Website).
Further information in relation to Stripe can be found in our terms of service.
Asset transfers. In the event that Keyholder is involved in a merger, acquisition, or other transaction that involves the sale of some or all of our assets, user information, including personal information collected through the use of our Service, may be transferred as part of the assets. We will make every effort to notify you of such a change through email or by posting a prominent notice on our website.
As part of our Services, we offer Tenants with regulated account information services provided by Tink AB, a Swedish limited company with its registered office in Stockholm, Sweden. Tink is supervised by the Swedish Financial Supervisory Authority. Tink provides us with a portal through which Tenants can authorise Tink to share their information with us. Once we receive such information, we shall process such personal data in accordance with this Privacy Notice. We are not responsible for, and take no liability for, the acts and omissions of Tink. Tink's Privacy Notice shall apply to their processing https://legal.tink.com
We may also offer our content through social media websites. Any information you provide to us when you engage with our content (such as through our brand page on Facebook) is treated in accordance with this Privacy Notice and you should be aware of the social media platform’s own Privacy Notice too.
6. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 72 hrs. If your account is inactive for 2 years, we may contact you to assess whether you want to continue to use the Services. Some personal data may need to be retained for longer than this to ensure that Keyholder can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
7. YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at support@keyholder.ie
You have the following rights in relation to your personal data:
Right to be informed: You usually have the right to know how and why we collect and use your Personal Data, how long we will keep it, and who we will be sharing it with. We explain these things in this Privacy Notice, but if you would like more information, please contact us.
Occasionally, there are times when we don’t have to let people know that we’re using or sharing their Data. These times include when the Data is being used as part of an investigation into crime or other regulatory investigations, legal proceedings, and similar reasons that protect the public.
Right of access: You have the right to access the Personal Data that we hold about you, to know what we hold, and to have a copy of it. This is called a subject access request (or SAR) and it is free of charge. For more information, or to make a request, please contact us.
Right to Rectification: We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.
Right to erasure / ‘Right to be forgotten’: Asking us to delete all of your personal data will result in Keyholder deleting your personal data without undue delay (unless there is a legitimate and legal reason why Keyholder is unable to delete certain of your personal data, in which case we will inform you of this in writing).
Right to restriction of processing: You have the right to ask us to stop processing your personal data at any time, and we will assess all requests carefully and sensitively.
Right to data portability: In some circumstances, you have the right to request that Keyholder provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.
Right to complain: You have the right to lodge a complaint to a supervisory authority such as the Data Protection Commission (see www.dataprotection.ie). Although we encourage clients to engage with us in the event they have any concerns or complaints.
Keyholder will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Keyholder Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
Where you request Keyholder to rectify or erase your personal data or restrict any processing of such personal data, Keyholder may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example payment processing or insurance companies.
8. CHANGES TO THIS NOTICE
Any changes we make to our Privacy Notice in the future will be posted on this page, and where appropriate, notified to you by email or notifications via the App. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.
9. COOKIES & WEBSITE
Cookies
The Keyholder website uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our Website, and also allows us to improve our Services.
We collect information about your use of the Service, including your preferences and other tendencies, through aggregated or de-identified traffic data and tracking information provided by our website host or analytics provider. This data does not personally identify you, but it may be helpful for marketing purposes or for improving the services we offer. We may also collect information about which pages you visit, how long you stay on a particular page, emails and advertisements you view, products and services you view, your referring and existing pages, and your location (using imprecise location data such as IP address or city/postal code level, or precise location data such as latitude/longitude). This information helps us tailor the Service to you, such as by helping you find agents nearby. It may also provide information about the browser, network, or device you use to visit our site. If you use the Service to search for rental properties or submit a rental application, we may also collect information about you, in accordance with this Privacy Notice and our Terms of Use.
When you visit our site, we may collect information about your device and its connection to the internet, including your IP address, browser type, device type, operating system, and regional and language settings. We may also collect device identifiers to help us understand how you use our site and diagnose any issues with our server. This information is used to administer and provide our service, and to tailor the content we display to your preferences.
Our cookies consent banner allows you to easily accept or reject non-necessary cookies.
Necessary cookies are always switched on unless you completely disable cookies being stored on your computer by changing your browser settings. Please note that our website may not perform properly or some features may not be available to you if you completely disable cookies.
Website
Please be aware that our website includes links to external websites that are not operated by us. These third-party websites have their own privacy notices and practices, and we have no control over or responsibility for their content or use of your personal information. We encourage you to review the privacy notices of any external websites before disclosing any personal information.
10. CONTACT
Questions, comments and requests regarding this Privacy Notice are welcome and should be addressed to support@keyholder.ie
For the purpose of the relevant data protection legislation, the data controller is Credit Score Technology Limited(trading as Keyholder) (company no. 713496) with registered address at COLLEGE HOUSE, 71/73 ROCK ROAD, BLACKROCK, DUBLIN, A94 F9X9, IRELAND.