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Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how John Lewis Partnership BTR Ltd and associated company BTR (operating) Ltd , (referred to from this point as BTR Operating Ltd) uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.

 

This Privacy Policy explains our practices, including your choices regarding the collection, use, and disclosure of certain information by the John Lewis Partnership group of companies in accordance with the General Data Protection Regulation (GDPR) and any subsequent or associated data protection legislation in force from time to time (Data Protection Legislation). 

 

Explaining the legal bases we rely on.

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. For example when using our resident app.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, details on your tenancy agreement and personal data that we collect for this.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example in order to complete the right to rent checks. 

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we may contact you for market research and reviews.

 

When do we collect your personal data?

By visiting any BTR Operating Limited affiliated websites and apps or corresponding with us by telephone, email (including any of our online forms) or post you are accepting and consenting to the practices described in this policy. We will use this information to contact you in relation to your tenancy agreement and / or property.. 

For the purpose of the General Data Protection Act, the data controller is John Lewis Partnership BTR Operating Ltd, 1 Drummond Gate, London, England, SW1V 2QQ

Within our websites and apps you may find outbound links to websites or apps owned and operated by third parties. These websites and apps have their own privacy policies and you should review these as only they are liable for the use and security of the data you provide them.

Information you provide to us: 

Your name, email address, postal address, payment method, date of birth, copy of passport and contact number and any relevant information that is featured in your lease agreement. This is required from you to enable us to perform our contract as managing agent

Information when you choose to provide reviews & ratings, account settings and preferences in BTR Operating Ltd . We collect this information in a number of ways, including when you enter it while using our service, interact with our team, or participate in surveys or marketing

Information we automatically collect: 

We will be able to see your activity on our customer portal(s); last log-in and requests

Details of your interaction(s) with our team, such as the date, time, reason for contacting us and resolution, and if you call us, your phone number, SMS. A CCTV system may monitor parts of the building or estate within which you rent a property that we manage, for up to 24 hours a day. This data is recorded.

Use of information

We use information to process a task, your registration, any orders (e.g fobs), enhance our services, your experience and to share relevant updates. We seek to ensure that our information collection and processing is always proportionate. For example, we use your information to:

• Help us quickly and efficiently respond to inquiries and requests
• Communicate with you regarding our service (for example by email, portal notifications and SMS), so that we can send you financial documents, updates on maintenance issues, news about BTR Operating Ltd, details about new features and content available on our app/ portal, surveys and to assist you with operational requests such as password reset requests. 
• Carry out our obligations to provide you with the information, products and services relating to the service that we are contracted to carry out
• Carry out website and app admin tasks and for internal operations, including troubleshooting, website and app safety and security
• Notify you of any changes to our services or our websites and apps
• Administer and process billing. We will retain some billing history as a part of our corporate records, and will record our correspondence with you. We may also share this information with third parties that can provide maintenance to your property. 
• Fulfil your contract with us.

 

Disclosure of Information

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Should we ever disclose any personal information obtained about you to a third party, it would be for the following reasons: 

Service Providers: There may be times where we will have to use other companies, agents or contractors (“Service Providers”) to undertake services on our behalf or to assist us. Yardi as the provider of our operating platform / app are the main third party we work with. We also work with Service Providers to process credit card transactions or other payment methods and to provide customer assistance with certain maintenance requests. Whilst undergoing the task the Service Providers may have access to your information. We do not authorise them to use or disclose your information except in connection with providing their services. We use Yardi as an operating platform and so the platform is used to hold and store personal information in order to allow Yardi to support us in the services we offer you. Third parties: we do not share any of your data to third parties unless we are instructed to transfer the service provision to a new agent or to enable us to perform our contract as managing agent

BTR Operating Ltd  and its Service Providers may disclose and otherwise use your personal and other information where disclosure is needed to

Satisfy any applicable law, regulation, legal process or governmental request

Enforce applicable terms of use, including investigation of potential violations

Detect, prevent, or address illegal or suspected illegal activities (including payment fraud), security or technical issues

Protect against harm to the rights, property or safety of BTR Operating Ltd , its users or the public as required or permitted by law.

We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of BTR Operating Ltd our customers, or others.. For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies or across the John Lewis Partnership. We may also share information with Abrdn as our investment partner as part of our regular reporting and review schedule. 

You may also choose to disclose your information in the following ways:

While using our services you will have opportunities to post reviews or other information publicly, and third parties could use the information you disclose.

Your Payment Methods

All credit/debit card payments are done through our operations platform provider Yardi.  They are liable for the use and security of the data you provide them and will have their own policies which you will be able to find on their website.

Your Rights 

You have the following rights regarding Your Information:

The right to be informed : You have the right to be provided with clear, transparent and easily understandable information about how we use Your Information and your rights. This is why we’re providing you with the information in this Privacy Policy

The right of access :You have the right to obtain access to Your Information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using Your Information in accordance with data protection law.

The right to rectification: You’re entitled to have Your Information corrected if it’s inaccurate or incomplete

The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of Your Information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions

The right to restrict processing: You have rights to ‘block’ or suppress further use of Your Information. When processing is restricted, we can still store Your Information, but may not use it further. We keep lists of people who have asked for further use of their personal information to be ‘blocked’ to make sure the restriction is respected in future

The right to data portability: You have rights to obtain and reuse Your Information for your own purposes across different services. E.g., if you decide to switch to a new provider, this enables you to move, copy or transfer Your Information easily between our IT systems and their safety and securely, without affecting its usability.

The right to object: You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent)

Right to withdraw your consent: Where we are relying on consent to process Your Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

​​What if I want to do more than update my details? To exercise other rights, you can contact us online, by post or by email.

• Online: Use our Customer Rights Contact Form
• Post: Write to: 
• Customer Rights Team
  1 Drummond Gate
  London
• SW1V 2QQ
• Email: [email protected]

 

 

 

Cookies and Internet Advertising

We use cookies to provide a better user experience for our customers. For example, we use cookies to make it easy to access our services by remembering you when you return, for analytical purposes, to learn more about what our users want, and to deliver and tailor our services. 

What are cookies?
Cookies are small data files that are commonly stored on your device when you browse and use websites, apps, and online services

Why does BTR Operating Ltd use cookies?

We use cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites.

We and our Service Providers may use the following types of cookies:

Performance and functionality cookies: These cookies are not essential but help us to personalise and enhance your online experience with BTR Operating Ltd. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (e.g. during registration). We also use these cookies to collect information such as web traffic, viewing patterns and click-through rates. Although this is an ‘opt-in’ service, we highly recommend that you do opt-in to our cookies so that you can benefit from all of our website’s and apps’ functions and experience the best of BTR Operating Ltd.  

You can adjust your cookie preferences either when first logging on to the portal via the “pop up” banner notifying you of the use of cookies, or via the preferences section within the website. 

Security

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

 

We secure access to all transactional areas of our websites and apps using ‘https’ technology. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and encrypted to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

Contacting Us

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at [email protected]

Alternatively, write to us at:

DPO, 1 Drummond Gate, London, SW1V 2QQ

Please also contact us at this address if you have any questions about this notice or the information we hold about you.

The data controller of your personal information is BTR Operating Ltd, who also provide the service to you. When contacting the team for assistance, the receiver will need to authenticate your identity before fulfilling your request. This is for your safety and ours.

Retention of data

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. For some of this data it means holding it in line with legal and regulatory requirements.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Complaints

You have the right to complain to the Information Commissioner about the way in which we collect and use Your Information: www.ico.org.uk/concerns or telephone 0303 123 1113.