Our Privacy Policy

1. Who are we?

At Twindig Limited ("we", "us", "our") we work very hard to keep your information safe and we want our website and our services to be safe and enjoyable for everyone. We also recognise that it is important for you to understand how we use your personal data.

This privacy policy (and any other documents referred to in it) describes the way we will process and use any personal data about our users, potential users and other visitors to our website. We aim to be transparent about our data practices regarding the personal data that we may collect, use, maintain and otherwise process. Please read this privacy policy carefully to understand our practices regarding your personal data and how we will treat it – it should only take you a few minutes.

We have a legal duty to protect personal information that we collect under the Data Protection Act 2018 (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the DPA and GDPR, we (Twindig Limited) are the data controller. In other words, Twindig Limited is the organisation that determines how your personal data is used.

If you have any questions, you can contact us at [email protected] and also by using the contact details set out at section 12 of this privacy policy below.

2. Structure of our privacy policy

The types of personal data that we collect about you, how we collect it and what we use it for is quite different depending on our relationship with you. We have therefore split some sections of this privacy policy into different parts to help make the position clear.

All you need to do is identify whether you are a:

an occupier of a property in the UK (such as a homeowner, a tenant or users looking to rent or buy for the first time) (a "Home User"); or
an organisation that provides services regarding properties in the UK (such as a private landlord, an estate agent, a conveyancer, a kitchen fitter or an architect) (a "Business User").

For the avoidance of doubt, if you own a second home (which you don't rent out to tenants) or a holiday property, you will be considered as a Home User.
You only need to read the sections that are relevant to you.

3. For our Home Users: How Twindig works

This section contains some additional data protection information for our Home Users.

Twindig is different to other sites. When you create a Home User account with us you can provide information and update your personal preferences. You can also 'claim' the Twindig of your home and provide information about your home on your home's Twindig. When you move home, your Home User account details move with you but you will relinquish control of your old home's Twindig and take control of your new home's Twindig.

Any information that you upload to your home's Twindig will stay with that Twindig when you move home and can be accessed by the new residents, however you will be able to remove this information before you move if you want to. We ask that you don't upload your name or any other contact details such as phone numbers or email addresses to the public facing section of your Twindig.

We will collect information about properties that is publicly available such as previous sold prices, EPC data including property type and floorspace, estate agents listings, school catchment data and broadband coverage. We don't attribute or relate that information to any identified or identifiable individual, nor do we take or instigate any action in relation to any such individual (e.g. a tenant or homeowner) until that individual becomes a Home User and 'claims' the Twindig, at which point we become a data controller for that personal data.

Got it? If so, great! If not, you can contact us at any time at [email protected] and also by using the contact details set out at section 12 of this privacy policy below.

4. Information collected about you

Please click on the link below to take you to the section that is relevant to you:

Home User
Business User

Home User

The personal data that we collect from or about you includes the following:

Your name
Your email address
Your password and account details (if you create an account with us)
Your home address
Your phone number
The details of your home (such as the number of rooms, when your tenancy expires (if renting), parking details etc.) that you that you upload to your home's Twindig
Information about your home that it is in the public domain (such as previous sold prices, EPC data including property type and floorspace, estate agents listings, school catchment data and broadband coverage)
Images of your home (that you upload to your home's Twindig)
Documents related to your home that you have uploaded to your home's Twindig's secure 'vault' (such as title deeds, utility bills, architects' drawings, building regs approvals)
TA (fixtures and fittings) forms that you have completed about your home and any updates that you make to them
Your current status regarding your home (such as whether you are happy in your home or are looking to move or if you are renovating your home)
Any information that you provide to us to verify that you live in your home
Any information that you enter into our budgeting tool and financial calculators
Any information that you enter when using the reminders tool including the reminder description and any relevant dates
Information regarding the services of Business Users that have provided services at your home, including whether you would recommend them to other Home Users and any photos uploaded by Business Users regarding your home
Any other information that you upload to your home's Twindig
Your social media handle/user name details if you engage with us on social media
Your geolocation, where you have asked us to provide you with location specific services such as looking at the property value in the postcode you are currently in. We will only use your geolocation data for the purpose of providing you with that location specific service
Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, information about your device (such as device IDs) your login information, browser type and version, time zone setting, browser plug-in types and versions, device types, operating system
Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse the website
Any feedback that you give us
Any other information that you choose to give to us via our website or to our customer services team

Business User

The personal data that we collect from or about you may include the following:

Your name
Your email address
Your phone number
Your postal address
Any information we may need to verify your identity and, if you are a landlord, verify your ownership of a property, such as data of birth, a copy of a passport or drivers licence and (if you are a landlord) title deeds or mortgage statements to verify your ownership claim
The name of the business or the business you work for and your role within that business
The properties that you are providing or have provided services for (as verified by a Home User) and any photos that you upload about those services
If you are a private landlord, the details of properties that you own (that may or may not be occupied by a Home User)
Your password and account details (if you create an account with us)
Payment details (such as billing address and card details)
Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, device types, operating system
Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse the website
Any other information that you choose to give to us

5.. How do we collect information about you?

Please click on the link below to take you to the section that is relevant to you:

Home User
Business User

Home User

We may collect personal data in a variety of ways. In terms of information about you, it is generally when you give it to us; which includes when you:

Create an account with us
Access our website
Ask us to provide you with services and use our services
Upload documents or information to our website
Sign up to receive marketing communications from us
Contact our customer services team
Enter one of our competitions or promotions or fill in a survey
Engage with us on social media (for example by mentioning/tagging us or by contacting us directly)
Leave comments on our website or interact with other functionality where you provide us with data on our website

In terms of information about your home, a lot of information that we process is obtained from a number of sources (most of which are publicly available) to ensure that we are able to provide a comprehensive database of residential information in the UK to help Home Users find their dream home, or their next move, quickly and easily. These sources include:

Government open data
Land Registry
Royal Mail
Housebuilders
Our trusted suppliers who provide us with property listings information

Business Users may also provide us with details of the services that they have provided at your home, including photographs of work carried out at your home. You will remain in control of what is publicly available on your Twindig, so you don't have to include any information from Business Users if you don't want to.

Business Users

We may collect personal data in a variety of ways, including when you:

Create an account with us
Access our website
Sign up to receive marketing communications from us
Contact our customer services team
Enter one of our competitions or promotions or fill in a survey
Engage with us on social media (for example by mentioning/tagging us or by contacting us directly)
Receive feedback from a Home User

6. How do we use your personal data and what are our justifications for doing so?

Please click on the link below to take you to the section that is relevant to you:

Home User
Business User

Home User

How and why we use your personal data	What is our legal justification for processing your personal data
To provide you with the information and services that you request from us (i.e. to complete certain tasks, processes, and to communicate with you regarding the services that you request from us and respond to your questions and comments).	We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to our services. Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues or deal with your specific queries on social media). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To measure how satisfied our customers are and provide customer service (including troubleshooting in connection with your requests for services or when you ask us questions on social media).
We may use your personal data to tell you about our services or relevant services of third parties ("marketing"). For example, if you use our reminder service, then we will use your data for marketing purposes (including sending you marketing relating to other people's services) where you tell us that you are interested in hearing from third party service providers towards the end of your existing contract (e.g. your contract with your broadband provider). As another example, you may tell us that you are looking to move house soon and that you want to hear about relevant service providers that could help (such as removal companies and estate agents). If you use our referral service to tell a friend or family member about Twindig, we will include your name in the invite you send. We may use cookies to do this.	We can usually only use your personal data to serve you with our marketing messages if we have consent from you to do so or, in some cases, we can rely on a legitimate interest. We will never serve you with marketing messages from third parties unless you have given us consent to do so. You can ask us to stop sending you marketing messages from us and/or third parties by contacting us at any time at the contact details set out at section 12 of this privacy policy below. You will also be able to adjust your marketing settings in your account and you will be able to unsubscribe to particular types of marketing communications from us (for example from our newsletter) by clicking the unsubscribe button in the newsletter.
To find out more about the users of our services as a whole and their homes (and not to find out more about you as an individual) to: ensure that the services that we offer are most likely to interest our Home Users and Business Users; and to identify trends in the UK housing market in order to provide you with relevant information regarding your home or when looking for your next home.	We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you. We rely on our contractual arrangements with you as the lawful basis to provide you with the information that you request from us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To monitor the use of our website and ensure that it is presented in the most effective and relevant manner for you and your device. We may use cookies to do this.	We have a legitimate interest to ensure that our website works properly and that our products and services are high quality and efficient. We rely on consent to place non-essential cookies on your device. For information on how we use cookies, please see our cookie statement
To ensure that the personal information that you provide to us is accurate	In some cases, we will use your personal data because it's necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud or ensuring security of the site) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To detect, investigate, report, and seek to prevent financial crime or other illegal activity
To manage risk for us and our customers.
To fulfil our legal and compliance-related obligations
For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our website.	We have a legitimate interest to respond to your contact for the purposes of administering our business. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

Business User

How and why we use your personal data	What is our legal justification for processing your personal data
To provide you with the information and services that we request or purchase from us (i.e. to complete certain tasks, processes, and to communicate with you regarding the services that you purchase or request from us and respond to your questions and comments).	We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order from your school for products and services. In other cases (such as to maintain an internal list of schools that have previously contacted us) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
We may use your personal data to tell you about our services or relevant services of third parties ("marketing"). We may use cookies to do this.	We can usually only use your personal data to serve you with our marketing messages if we have consent from you to do so or, in some cases, we can rely on a legitimate interest. We will never serve you with marketing messages from third parties unless you have given us consent to do so. You can ask us to stop sending you marketing messages for us and/or third parties by contacting us at any time at the contact details set out at section 12 of this privacy policy below. You will also be able to adjust your marketing settings in your account and you will be able to unsubscribe to particular marketing communications (for example from our newsletter) by clicking the unsubscribe button in the newsletter.
To monitor the use of our website and ensure that it is presented in the most effective and relevant manner for you and your device. We may use cookies to do this.	We have a legitimate interest to ensure that our website works properly and that our products and services are high quality and efficient. We rely on consent to place cookies on your device. For information on how we use cookies, please see our cookie statement
We may record calls you make to us and will use this data for training and quality assurance purposes (where your call is recorded we will tell you in advance).	We use data in this way for a variety of reasons. It may be pursuant to a legal obligation and it is also in our legitimate interests to review call recordings for quality control purposes.
To ensure that the personal information that you provide to us is accurate	In some cases, we will use your personal data because it's necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud or ensuring security of the site) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To detect, investigate, report, and seek to prevent financial crime or other illegal activity
To manage risk for us and our customers.
To fulfil our legal and compliance-related obligations
For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our website.	We have a legitimate interest to respond to your contact for the purposes of administering our business. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

7. Disclosing information

When we provide you with services, in order for us to provide our services to you, we share your personal data with our trusted third-party service providers as detailed below. Whenever we share your personal data, we put safeguards in place which require these other organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes unless you have given us your consent to do so. Where you tell us that you are happy for us to do so (i.e. by marking it as data to be transferred to the next occupant of a property), we will share that personal data when you move with the next Home User that claims ownership of your property. We will never sell your personal data to a third party.

a. To provide you with our services:

We work with a number of trusted service providers who carry out services on our behalf. The services provided by these service providers include website and database hosting, sending out our marketing communications to you and processing your payment securely (if you are a Business User). It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.

b. Other professional services:

We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.
We work with carefully selected third parties, such as our customer database hosting provider, marketing agencies and advertising partners who assist us in providing you with a positive customer experience.

c. Sharing data to prevent crime and otherwise comply with laws:

There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.

d. Where our corporate structure changes:

We may also share your personal data if we choose to sell, transfer, or merge parts of our business and/or group, or our assets in the future. Or we may seek to acquire other businesses or merge with them. During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private. If there is a change to our corporate structure, then unless/until they tell you otherwise, other parties may use your data in the same way as set out in this notice.

8. Where we transfer and store personal data

We may transfer your personal data outside of the UK and the European Economic Area (EEA) where local laws may not provide legal protection for your information in the same way as is applicable in the UK or the EEA.

Whenever we send (or permit a third party to send) your personal data outside of the UK and the EEA, we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may require the overseas recipient to enter into particular contract terms.

9. Security of your information

We take the security of your information very seriously and have put physical, technical, operational and administrative strategies, controls and measures in place to help protect your personal information from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate.

10. Retention of your information

We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information. This means that the retention periods will vary according to the type of personal information. For example, when you store personal data in the vault section of your account, we will retain that personal data until you delete it, or you delete your account. However, if you disclose any personal data to another Home User, or a Business User, for example by transferring certain documentation, we can't delete that data from the other users account.
At the end of our retention period, some information may be anonymised (i.e. so that it can't be attributed back to you) and used for our own purposes.
If you would like more information on our data retention practices, please contact us at the contact details at section 13 of this privacy policy below.

11. Your rights in your information

You have certain rights in respect of the personal information that we hold about you (or your child). Details of these rights are set out below. To exercise any of these rights, please contact us at the contact details at section 13 of this privacy policy below.
You have the right:

to ask us not to use your personal data for direct marketing purposes;
to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
to ask us to correct or update any personal data which is inaccurate;
to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
to ask us to temporarily stop using your data if you don't believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.

12. Type of cookies

Third party vendors, including Google, use cookies to serve ads based on a user's previous visits to your website or other websites.

13. Changes to this policy

We reserve the right to modify this privacy policy from time to time – for example, if we need to reflect changes to the way that we use your personal information. Any changes we make in the future will be posted on our websites and, where appropriate, notified to you by e-mail. You should check back frequently to see any updates or changes to our privacy policy.

This policy was last updated on Friday 19th March 2021.

14. Contact Us

We are very keen to hear from you, including if you have any questions, concerns, comments, requests or complaints regarding this privacy policy, our websites and/or our use of your personal information. Please contact us at the following details:

Customer Services line: [To insert]
Email: [email protected]

15. How to raise a concern about how your data is handled

Please contact us with any concerns you have about how we are handling your data. For detailed guidance on how to raise a concern, and your rights to escalate concerns to the Information Commissioners Office (ICO) please visit: https://ico.org.uk/for-the-public/raising-concerns/