Company Details
Click and Keys Limited
Company number: 16451752
Registered office: Malvern House, New Road, Solihull, England, B91 3DL
1. Introduction & Scope
1.1 This Privacy Policy explains how Click and Keys Limited ("Click and Keys", "we", "us", "our") collects, uses, stores, and protects your personal data when you use our website [www.clickandkeys.co.uk] ("Website") and the services provided through it (together, the "Platform").
1.2 We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1.3 This Privacy Policy applies to all users of the Platform, including landlords, tenants, buyers, sellers, guarantors, contractors, and any other visitors ("Users", "you", "your").
1.4 By using the Platform, you consent to the practices described in this Privacy Policy. If you do not agree with this Policy, you must stop using the Platform immediately.
1.5 This Privacy Policy should be read together with our Terms & Conditions and our Cookies Policy, which form part of the agreement between you and Click and Keys.
2. Data We Collect
We may collect and process the following categories of personal data about you:
2.1 Information You Provide Directly
- a) When creating an Account: name, email address, phone number, postal address, login credentials.
- b) When listing a Property: property details, photographs, descriptions, and related documents.
- c) When applying to rent or buy a Property: employment details, financial information (such as income, bank details for payments), identification documents, references, and guarantor details.
- d) When communicating with us: records of your correspondence, queries, feedback, or complaints.
2.2 Information We Collect Automatically
- a) Technical information: IP address, browser type, operating system, device identifiers.
- b) Usage data: pages visited, time spent on the Website, features used, and interaction with our emails.
- c) Cookies and similar technologies: please see our Cookies Policy for more detail.
2.3 Information From Third Parties
- a) Referencing agencies (credit, employment, landlord references).
- b) Payment processors (confirmation of successful or failed transactions).
- c) Compliance providers (AML and identity verification checks).
- d) Public sources (e.g. Land Registry, electoral roll, Companies House).
2.4 Special Category Data
In limited cases, we may process special category data (such as data relating to immigration status for right-to-rent checks). We will only process such data where necessary, lawful, and with appropriate safeguards.
3. How We Use Your Data
We use your personal data for the following purposes:
3.1 To Provide Our Services
- a) Creating and managing your Account.
- b) Advertising properties for sale or rent.
- c) Facilitating communication between landlords, tenants, buyers, sellers, and guarantors.
- d) Processing applications, tenancy agreements, and sale agreements.
- e) Carrying out referencing, right-to-rent, and anti-money laundering (AML) checks.
- f) Collecting and transferring rent or holding deposits where applicable.
3.2 To Manage Our Relationship With You
- a) Responding to enquiries, requests, or complaints.
- b) Sending service updates, notices, or information relating to your Account or transactions.
- c) Providing customer support.
3.3 For Legal and Compliance Purposes
- a) Complying with our legal and regulatory obligations (e.g., AML, tenancy deposit rules, consumer protection laws).
- b) Assisting law enforcement or regulatory authorities when required by law.
- c) Enforcing our Terms & Conditions.
3.4 For Marketing Purposes
- a) Sending you information about our services, promotions, or updates where you have consented or where we are otherwise permitted by law.
- b) You may opt out of marketing communications at any time by using the unsubscribe link in our emails or contacting us directly.
3.5 For Business Operations
- a) Monitoring Website usage to improve functionality and user experience.
- b) Analysing data to understand trends and service performance.
- c) Protecting the security and integrity of our systems.
4. Legal Basis for Processing Data
We rely on one or more of the following lawful bases under the UK GDPR to process your personal data:
4.1 Performance of a Contract
Where processing is necessary to perform the contract we have with you, or to take steps at your request before entering into such a contract.
Example: processing tenant applications, facilitating a property sale, or collecting rent.
4.2 Legal Obligation
Where processing is required for us to comply with our legal obligations.
Example: conducting anti-money laundering (AML) checks, complying with tenancy deposit rules, or responding to lawful requests from authorities.
4.3 Legitimate Interests
Where processing is necessary for our legitimate interests (or those of a third party), provided your rights and freedoms do not override those interests.
Example: improving our services, preventing fraud, or ensuring platform security.
4.4 Consent
Where you have given us clear and explicit consent.
Example: sending you marketing communications or processing special category data where required.
4.5 Vital Interests
In rare cases, we may process your data to protect someone's life.
Example: sharing information in an emergency involving serious safety risks.
5. How We Share Your Data
We may share your personal data with the following categories of recipients where necessary and lawful:
5.1 Between Users
- a) Landlord details may be shared with prospective Tenants and vice versa.
- b) Seller details may be shared with prospective Buyers and vice versa.
- c) Guarantor details may be shared with the relevant Landlord or Letting Agent.
5.2 Service Providers
- a) Referencing and credit agencies to carry out background checks.
- b) Payment processors to handle rent, holding deposits, or service fees.
- c) IT and hosting providers who support the Platform.
- d) Contractors providing optional services such as inventories, photography, or compliance checks.
5.3 Regulators and Authorities
- a) Government-authorised tenancy deposit schemes.
- b) Law enforcement or regulatory bodies where disclosure is required by law.
- c) HMRC or other tax authorities where legally required.
5.4 Professional Advisors
Our accountants, auditors, legal advisors, or insurers where necessary for business management and compliance.
5.5 Business Transfers
In the event of a merger, acquisition, or sale of business assets, your data may be transferred to the new owner, subject to safeguards.
5.6 No Unauthorised Sharing
We will never sell or rent your personal data to third parties for marketing purposes.
6. International Transfers of Data
6.1 We primarily store and process your personal data within the United Kingdom (UK) and the European Economic Area (EEA).
6.2 In some cases, your personal data may be transferred to, and processed in, countries outside the UK or EEA. These countries may not have the same data protection laws as the UK.
6.3 Where such transfers occur, we will ensure that one of the following safeguards is in place:
- a) the country has been deemed to provide an adequate level of protection by the UK government;
- b) we have implemented standard contractual clauses (approved by the UK government or European Commission) with the recipient to ensure appropriate data protection safeguards; or
- c) you have given us explicit consent, after being informed of the risks of such transfers.
6.4 We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy when transferred internationally.
7. Data Retention
7.1 We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including:
- a) providing our Services;
- b) complying with legal, accounting, or reporting requirements;
- c) resolving disputes;
- d) enforcing our agreements.
7.2 Retention periods may vary depending on the type of data:
- a) Account data - retained for as long as your Account remains active and for up to six (6) years after closure, in line with limitation periods for legal claims.
- b) Transaction records (e.g., tenancy or sale agreements, payment history) - retained for at least six (6) years to comply with financial and tax regulations.
- c) Referencing and AML checks - retained for a minimum of five (5) years, as required by anti-money laundering legislation.
- d) Marketing preferences - retained until you opt out or withdraw consent.
7.3 When personal data is no longer required, we will securely delete or anonymise it so that it can no longer be associated with you.
8. Your Rights under Data Protection Law
As a data subject, you have the following rights under the UK GDPR and Data Protection Act 2018:
8.1 Right of Access
You have the right to request a copy of the personal data we hold about you, together with information on how we process it.
8.2 Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data.
8.3 Right to Erasure ("Right to be Forgotten")
You may request deletion of your personal data where:
- a) it is no longer necessary for the purposes for which it was collected;
- b) you withdraw consent (where consent is the basis of processing);
- c) you object to processing and there are no overriding legitimate grounds;
- d) the data has been unlawfully processed; or
- e) erasure is required to comply with a legal obligation.
8.4 Right to Restrict Processing
You may request that we restrict the processing of your personal data in certain circumstances (e.g., while verifying accuracy or resolving a legal claim).
8.5 Right to Data Portability
You have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable format, and to transmit that data to another controller where technically feasible.
8.6 Right to Object
You may object at any time to the processing of your personal data where processing is based on legitimate interests or direct marketing.
8.7 Rights Relating to Automated Decision-Making
You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal or similarly significant effects, unless necessary for a contract, authorised by law, or based on your explicit consent.
8.8 Right to Withdraw Consent
Where we rely on your consent to process your data, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
8.9 Exercising Your Rights
To exercise any of these rights, please contact us using the details in Section 11 (Contact Us). We may need to verify your identity before responding.
9. Data Security
9.1 We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include encryption, access controls, secure servers, and regular monitoring of our systems.
9.2 While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.
9.3 Users are responsible for:
- a) keeping their login credentials confidential;
- b) ensuring that any devices used to access the Platform are protected with up-to-date security software; and
- c) promptly notifying us if they suspect unauthorised use of their Account.
9.4 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours and, where legally required, notify affected Users without undue delay.
11. Contact Us
11.1 Click and Keys Limited is the data controller responsible for your personal data processed through the Platform.
11.2 If you have any questions, requests, or concerns about this Privacy Policy or how we handle your personal data, please contact us at:
Click and Keys Limited
Registered office: Malvern House, New Road, Solihull, England, B91 3DL
Email: info@clickandkeys.com
Telephone: 07514003000
11.3 You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues. You can contact the ICO at ico.org.uk or by calling 0303 123 1113.