Privacy

Last updated: 18th June 2018

Introduction

We believe you have a fundamental right to privacy and we aim to do everything we can to protect the security of personal data we process. This Privacy Notice describes how we will handle and protect your personal information as you interact with us online and offline. It explains how we collect, use, disclose and transfer the information that you provide to us through our partners, on our websites or mobile applications, and how we manage our communications.

When we receive personal data about you in providing our services we will process it in accordance with all applicable laws (including the EU’s General Data Protection Regulation) and this Privacy Notice. You can find the Just Move In terms and conditions governing our services for end users at www.justmovein.org/terms.

Please read this Notice in full to make sure you understand how your personal information will be handled.

 

1. Who is Just Move In?

Just Move In is owned and run by Ethical Introductions Ltd, registered in England with company number 09280849 and registered office at Unit 3 Vista Place, Coy Pond Business Park, Ingworth Road, Poole, Dorset, United Kingdom, BH12 1JY. This is the company that decides on the purposes for which your data is processed and the methods of processing. In this Notice, references to ‘we’, ‘us’ or ‘our’ refer to Ethical Introductions Ltd. You can contact us at:

Data Protection

Ethical Introductions Ltd

Barclays Eagle Labs, County Gates House,

300 Poole Road,

Bournemouth, BH12 1AZ

Email: my.data@justmovein.co

We welcome comments or questions about this Notice. You can also use these contact details to exercise your legal rights referred to in this Notice.

 

2. What are the purposes for which we process personal data? And what are the legal bases that allow us to process it?

We use personal data (relating to you, other members of your household, and/or other occupants of the property you are moving from or to) for the following purposes and relying on the following legal bases:

  • Processing necessary for the performance of our services contracts:
  • to deliver our move and settle-in services (e.g. setting up or closing accounts in accordance with your instructions or making change of occupancy notices on your behalf);
  • to generate quotations for you, and if you decide to proceed, registering you with the relevant new supplier;
  • to communicate with you about those services;
  • to provide and deliver additional products and services at your request;
  • to charge for our services, collect payments, and pay others as required;
  • to send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.

The legal basis for these operations are that they are necessary in order to perform the contracts for our services, with you directly or with our partners if we are providing the services on their instructions and for your benefit.

  • Processing necessary for our legitimate business interests:
  • to maintain, and improve our sites, products and services. This may include contacting you by telephone, to discuss how we can better provide our services or to get feedback after a move. This may also include technical information as referred to in Section 6;
  • to maintain proper records (and where you have been introduced to us by a partner, keeping that partner informed of the services provided);
  • to respond to comments and questions and provide customer service;
  • to communicate with you about promotions, upcoming events, and other news about products and services offered by us and our selected partners where these have a clear connection to moving into a new home;
  • to make sure that our marketing is tailored to your interests;
  • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • The legal basis for these operations are that they are necessary for the legitimate interests of our business or our partners’ businesses. When deciding to rely on this legal basis we always need to assess whether the data is necessary for those interests and whether they could be overridden by your own individual rights and freedoms. We have concluded that these operations are within the type of data processing that any of our users would expect based on the relationship we have, are not intrusive and do not have any negative impact on your privacy. We will re-assess this decision on a regular basis.

You also have the right to opt out of this processing. If you wish to do so please email us at my.data@justmovein.co. Please bear in mind that if you object then this may affect our ability to carry out some services above for your benefit.

Processing with your consent

There may be some cases in which we judge that we need your consent for processing your data. In such cases, we will ensure that we ask for your consent having given you all necessary information about how we’ll use the data and who may see it, in a fair and clear way.

Where you are introduced to us by our business partners, those partners should ask you (verbally or in writing) for your consent to share your personal details with Just Move In and provide information on how they will be used.

Where we rely on your consent as the legal basis for processing your data, you may withdraw that consent at any time by emailing us on my.data@justmovein.co. However, any processing that occurred before you withdrew consent will still be legal.

Processing necessary to comply with legal obligations

We will also need to process data where required for compliance with legal or regulatory obligations that apply to our business e.g.:

  • tax and accounting;
  •  to respond to lawful requests and legal processes from courts, regulators or law enforcement authorities;
  • to protect the rights and property of Ethical Introductions Ltd, our agents, customers and others. This includes enforcing our agreements, policies, and terms and conditions.

 

3. Do we provide data to any third parties?

Our overarching principle is that we will restrict access to your data to the minimum number of people and organisations necessary. However, we do need to do so at times e.g. to provide our services and to comply with the law. Specifically, we may share your data:

  • Where we have agreed or are legally obligated on behalf of yourself or a landlord (or a managing agent acting on behalf of a landlord) to provide change of occupancy notifications to utility providers (water, sewerage, gas, and electricity companies)  and/or the local council.  
  • Where use third-party organisations to help facilitate changed of address we occupations. Details of such organisations can be found in the Annex: 'Key Data Processing Partners'.
  • Where we have your consent to register you or your property with a chosen supplier e.g. broadband, cleaners, or removals, or any other tradespeople or service providers that we work with and make available as part of our services from time to time.
  • With those who need it to do work for us in order to provide our services to you or market our services, or whose services we use in managing and maintaining our data records.
  • During any sale or transfer of our business or assets. This could include through a merger, financing, acquisition, or bankruptcy transaction or proceeding. In these events we will endeavour to ensure that the purchasing or contracting organisation(s) continue the same obligations and responsibilities in terms of holding and processing of personal data as are set out in this Notice.
  • For legal, protection, and safety purposes e.g.:
    • to comply with laws or any regulatory obligation;
    • to respond to lawful requests and legal processes from courts, regulators or law enforcement authorities;
    • to protect the rights and property of Ethical Introductions Ltd, our agents, customers and others. This includes enforcing our agreements, policies, and terms and conditions.
    • in an emergency. This includes protecting the safety of our employees and agents, our customers, or any other person.

We regularly work with our partners (e.g. estate agencies or corporates) to help them fulfil their legal obligations around change of occupancy notifications and to provide a better move experience for their customers or staff.  If you were introduced through a partner, we may share your information with the organisation that referred you to help them measure impact and to allow them to communicate with you about other move related services.

We sometimes work with suppliers who store data outside of the European Union and European Economic Area (EEA), and other places not officially recognised by the European Commission as having equivalent data protection laws. Where we do so, we ensure that they are accredited under schemes that offer additional safeguards, such as the EU-U.S. Privacy Shield or have in place approved contractual clauses that ensure equivalent protections. You may contact us as indicated in Section 1 above to obtain a copy of such safeguards.

Should we identify a need to share your data outside of the circumstances outlined above, we will secure your consent to this in advance of sharing your data in this way.

 

4. How long do we retain your personal data?

We will retain your personal data only for the period necessary to fulfil the purposes outlined in this Notice, unless a longer retention period is required or permitted by law (e.g. for tax and accounting or mandatory recordkeeping).

If you have agreed to open a JMI account or are included in a household member’s account with us then we will retain your data for as long as that account is open and then for up to six years after that in case of legal claims.

If you don’t have an account with us, our normal policy is to retain data for not more than two years after all services have been provided or after we have no further contact from you. This may be extended where there is the possibility of a legal claim.

 

5. Where do we obtain your data from?

We obtain information about you in a range of ways:               

  • Information we receive from partners

If you consent to a partner providing us with your information, then we will normally receive your name, the address you're moving to, tenancy start date or expected completion date, email address and phone number. We may also receive additional information about the property or your preferences which will affect the services we can provide: e.g. a SKY dish is not allowed at the property, or all occupants of the property are exempt from council tax.

  • Information you give us

We may also collect personal information from you directly if one of our concierge managers speaks to you over the phone or when you correspond with us (e.g. through our website, or by telephone, e-mail or letter).

  • Information we get from others

We may get information about you and your property from other sources including, the national energy databases. We may add this to information we get from the other sources mentioned above.

 

6. Technical information

  • Information automatically collected

For online users, we automatically log information about you and your computer. For example, when visiting our site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.

  • Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our site to track the actions of users on our site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the site at an aggregate level, so that we can manage our content and promote the site more effectively.

  • IP addresses

We may collect information about your computer or mobile device, including where available your IP address, operating system, log in times and browser type. We use this information to better understand how visitors use our site and for internal reporting purposes.

We may anonymise and share this information with advertisers, sponsors and/or other businesses.

 

7. How secure is your data?

We want you to feel confident about using Just Move In and we are committed to protecting the personal information we collect. We limit access to personal information about you to employees and contractors who reasonably need access to it in order to do their jobs. We have (and require our suppliers to have in place), appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction.

 

8. What are your rights?

You have various legal rights in relation to data that we process about you e.g.:

  • To ask for access to it;
  • To ask for inaccuracies or out of date information to be corrected;
  • To ask for it to be deleted (the “right to be forgotten”); or if not deleted, to ask us to restrict its processing;
  • To object to its processing for specific purposes;
  • To ask for a copy to take to another service provider.

You can also ask us not to send you direct marketing communications.

If you wish to exercise any of these rights, please email: my.data@justmovein.co (or write to the address in Section 1). If you are not satisfied with our response on any matter, you also have a right to contact the UK Information Commissioner’s Office to ask them for a resolution of your concern.

 

9. Changes to this Notice

From time to time we may change this Notice. If we make any changes, we will change the Last Updated date above. If material changes are made to this Notice, we will notify you by email or by placing a prominent notice on the site. If you do not agree to these changes, please do not continue to use our services.

 

Annex: Key Data Processing Partners:

  • Landlord Tap Ltd (UK) - provide a platform to facilitate change of address notifications with the water and sewerage industry