Privacy and data protection

A quick note on your privacy

Thanks for wanting to know more about how we handle and treat your data. We hope you find this page satisfies any questions you might have, in any case where it doesn’t – please contact us at hello@reposit.co.uk.

Our terms and conditions, and the privacy notice below, are all written to be fully compliant with the European privacy and data regulations (GDPR). We’ve made the effort to ensure it’s all written in a format that is easily understood and as easy (as possible) to read.

Let’s start by outlining the basics to give you an overview of our data protection principles:

We only collect data required to adequately fulfill our core service.
We will never sell your personal data to a third party.
We will only share data with another entity if you’ve given us consent to do so or if it’s absolutely required as a part of our service offering. For example we may need to share some information with our partnered insurance company for the process of creating an insurance contract. You may withdraw your consent at any time by contacting us.
Landlords and/or other third party providers may provide us with information about you and your tenancy, which we shall use for the purpose of verifying any Charge raised by the landlord at the end of your tenancy (such information may include your Tenancy Documents and any other evidence to support the Charge). Our lawful basis for receiving and using this information in this way is our legitimate interest in providing this aspect of our service to landlords and tenants.
We will only use your contact details to notify you if you are required to perform an action, or there is an update to something directly related to you that we think you actually care about.
Our server infrastructure is provided by Amazon Web Services and is located in the United Kingdom.
We never store highly sensitive information such as passwords in plain text, they are encrypted so even we can’t read them!
We hold all users of our platform to the same standards we comply to, if you’d like to know more about this please read our terms and conditions.

Reposit Group LTD Privacy and Data Protection Policy

1. General

Reposit Group Limited (“we” or “us”) take the privacy of your information very seriously. Our Privacy and Data Protection Policy is designed to tell you, the user of our tenancy deposit replacement service (“Service”) about our practices regarding the collection, use and disclosure of personal and other information about you or your business that may be provided via this website or collected through our web application or otherwise.
This policy applies to information provided by our account holders (“members” or “users”) and also applies to information which is processed by us when a person (referred to for convenience as a “Customer”) adds or is added to a tenancy (generally referred to as a ‘Reposit’) via our system.
The processing of a Reposit requires information relating to tenancies. Subsequently a letting agent or landlord (“Supplier”) may enter tenancy information into our system when creating a “Reposit”, tenants will then be invited to complete further information associated with that Reposit.
Reposit Group Limited is registered under the Data Protection Act 1998 (the “Act”) and from 25 May 2018 the General Data Protection Regulation (GDPR).
The data controller is Reposit Group Limited trading as Reposit of 128 City Road, London, EC1V 2NX. You can find us on the Data Protection Public Register on the Information Commissioner’s Office (ICO) website reference number ZA203506.

2. Our policy

We aim to limit our interaction with your data wherever possible. We have a general policy relating to access to your data. We will generally seek only to access that data which is necessary in accordance with supplying the core service which you the user originally entered the data to receive.

If for whatever reason, we require data for other purposes we will always ask for your consent in clear and uncertain terms.

3. Basis on which we store or process personal data

We will only store or process your data for the following reasons:

You have consented to the processing for the specific purposes described in this notice
The processing is required to provide our core service of a tenancy deposit alternative to you and other users.
To determine your eligibility to use our platform as outlined in our terms and conditions.
To monitor and improve our user experience and service offering.
The processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
For security purposes to prevent unauthorised use of our platform.

4. Personal data we collect

We may collect and process the following personal information or data (information that can be uniquely identified with you) about you:
1. log-in details and information you provide as an account holder when you register with the Service (Log-In Information);
2. contact information we collect from you as an account holder (for example, names, addresses, contact addresses, telephone numbers and email address provided to us by you or by someone who you have given consent to be added to our platform) (“Contact Information”);
3. a record of the Reposits created through the Service and information relating to each individual Reposit (address, tenant details) (“Reposit Information);
4. a record of the Claim created through the Service and information relating to each individual Claim (amount, description and any subsequent disputes) (“Claims Information);
5. information required for or resulting from performing checks to verify that a user is eligible for our service. These checks include identity verification, credit checking and affordability checks (“Referencing Information”)
6. information relating to payment transactions which is collected where we collect payment on behalf of our account holder (but we do not collect credit card information which is sent directly from the user to our payment processor) (“Payment Information”)
7. information we may require from you when you report a problem or complaint (“Complaints Information”)
8. details of your visits to the Site, the resources and pages that you access and any searches you make (“Technical Information”).
9. a record of any correspondence between you and us and other interactions with the Service or the Site (“Correspondence Information”)
We only collect such information when you choose to supply it to us. You do not have to supply any personal information to us and you may withdraw your authority for us to process your data or request that we restrict our processing (see below) but our Service may not be operable in practice without providing such data to us.
Information may also be gathered through the Site without you actively providing it, through the use of various technologies and methods such as Internet Protocol (IP) addresses and cookies.
An IP address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet.
We use your IP address for your security and to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our site, and to administer and improve the site.

5. How we use your personal data

Please see the table below which sets out the manner in which we will process the different types of personal data we hold:

Purpose/Activity	Type of data	Lawful basis for obtaining or processing (including legitimate interests)
When you (or your employer) register with us to provide the service	Log-in information Contact information	Performance of our contract. Necessary for our legitimate interests (to establish necessary information in order to provide our Service).
When you use the service to create, manage or administer a Reposit	Log-in information Contact information Reposit information	Performance of our contract. Necessary for our legitimate interests (in order to provide our deposit replacement service).
When you use the service to complete or provide information relating to a Reposit you have been added to by your Landlord or Letting Agent	Log-in information Contact information Reposit information Payment information	Performance of our contract. Necessary for our legitimate interests (in order to provide our deposit replacement service).
When have been added to a Reposit by your Landlord or Letting Agent and you use the Service to verify your eligibility to use Reposit	Log-in information Contact information Reposit information Referencing information	Performance of our contract. Necessary for our legitimate interests (in order to provide our deposit replacement service).
When you use the service to create, update or submit information relating a claim for a expired or expiring Reposit	Log-in information Contact information Reposit information Claims information	Performance of our contract. Necessary for our legitimate interests (in order to provide our deposit replacement service).
When you use the service to respond to a claim relating to you	Log-in information Contact information Reposit information Claims information	Performance of our contract. Necessary for our legitimate interests (in order to provide our deposit replacement service).
To manage our relationship with our users which will include:Notifying users about status changes to an associated case or recordNotifying users about changes to our terms or privacy noticeAsking them to leave a review or take a surveyWhen a complaint is submitted	Log-in information Contact information Reposit information Claims information Technical information Correspondence information	Performance of our contract. Complying with a legal obligation. Necessary for our legitimate interests (to keep our records updated and study how our customers use our Service).
To verify whether our Terms of Use are being complied with	Log-in information Contact information Reposit information Claims information Referencing information Technical information Correspondence information	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. Necessary to comply with a legal obligation.
To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Log-in information Contact information Reposit information Claims information Technical information Correspondence information	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. Necessary to comply with a legal obligation.
To use data analytics to improve the Service, Site, marketing, customer relationships and experiences	Reposit information Claims information Technical information Correspondence information	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our services updated and relevant, to develop our business and to inform our marketing strategy).

6. Sharing your information

We do not disclose any information you provide to any third parties other than as follows:
1. if you are a Letting Agent or Landlord; we will share information that identifies your or you business to any tenants you add to a Reposit. We will also share any information relating to that Reposit with those tenants.
2. if you are a Letting Agent or Landlord; we will share all account information with any other user you add to your account as a team member. Team members should be people who are employed at your organisation.
3. payment information will be provided to our payment processors
4. information entered for the purposes of referencing will be shared with our referencing providers so we can validate your identity and if you are eligible for our Service
5. Claims information and any evidence provided will be shared with our third party adjudicator in the event of a dispute between tenant and supplier
6. Reposit and claims information will be shared with our partnered insurance companies and regulatory providers for the purpose of issuing or claiming on insurance contracts/policies which our core Service depends on
7. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
8. in order to enforce any terms and conditions or agreements for our Services that may apply;
9. we may transfer your personal information to a third party if our business is sold of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
10. to protect the rights, property, or safety of Reposit Group Limited, our account holders, or any other third parties
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so.

7. Security

In order to safeguard the information we collect from you we will take all reasonable steps to ensure that:

our servers are protected by security mechanisms and can only be administered via strictly controlled cryptographic keys;
our data processing storage facilities are sited in secure locations to prevent unauthorised access, our infrastructure is provided by Amazon Web Services (AWS) and certifications for infrastructure provided by AWS can be obtained here: AWS Certifications
all communication with our servers is encrypted through Secure Sockets Layer (SSL), an industry standard encryption method that encrypts data between your computer and our servers so that in the event of your network being insecure no data is passed in a format that could easily be deciphered.
regular security assessments of our infrastructure are performed. This includes web vulnerability scans, dependency vulnerability scans, static code analysis, rule based OS inspection and manual assessments.

8. Data retention

Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:

Length of retention	Length of retention
Records relevant for tax purposes	8 years from the end of the tax year to which the records relate
Personal data processed in relation to a contract between you and us	7 years from either the end of the contract or the date you last used our Service, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim
Personal data held on marketing or business development records	3 years from the last date on which a data subject has interacted with us
Information relating to an individual Reposit or Claim	2 years following the date of the most recent interaction with the system by a connected party (tenant, landlord or letting agent)
Information relating to the outcome of a reference (Identity, credit or affordability)	2 years following the date that the user last used the system, or 2 years after any associated Reposit has ended, whichever is later

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please refer to clause 10 below, which explains your privacy rights.

10. Your privacy rights

The GDPR gives you the following rights in respect of personal data we hold about you:


The right to be informed	You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice. You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right of access	You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
The right to correction	Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
The right to erasure (the ‘right to be forgotten’)	Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our Service without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
The right to restrict processing	You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.
The right to data portability	You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).
The right to object	Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.
Rights with respect to automated decision-making and profiling	You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.
Right to withdraw consent	If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).

All SARs and other requests or notifications in respect of your above rights may be sent to us via email at hello@reposit.co.uk.
We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
We reserve the right to charge a nominal fee if your request results in significant time investment, complexity or volume of requests.

11. Data breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

12. Other websites

Our Site may contain links, redirects and references to other websites. Please be aware that this Privacy Policy does not apply to those websites.
We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site and/or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you came to this Site via a third party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

13. Transferring your information outside of Europe

Reposits server infrastructure is currently located in the UK and your data will not be stored or transferred outside of Europe.
However, if you use our Site or Service while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

14. Notification of changes to our Privacy Policy

We will post details of any changes to our Privacy Notice on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.

15. Contact Us or a Privacy Supervisory Authority

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can contact us via hello@reposit.co.uk.
If you would like to raise a concern with a Privacy Supervisory Authority, you should contact the Information Commissioner’s Office.

This policy was last updated in November 2018.