Privacy Policy

The General Data Protection Regulation 2016/679

In this statement, JLH has used specific terms as defined in the General Data Protection Regulation 2016/679 (GDPR or the Regulation):

• Personal data refers to any information related to an identified or identifiable natural person (data subject). An identifiable natural person is someone who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
• Controller refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data.
• Processor refers to a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
• Processing encompasses any operation or set of operations performed on personal data or on sets of personal data, whether automated or not, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

What JLH does

JLH is a letting agent, both online and offline, providing services and tools to make renting fairer, safer, and more affordable for everyone.

JLH assists property owners and landlords (collectively referred to as Landlords, whether actual or prospective) in finding tenants and creating tenancies, and offers a range of other services related to renting out and managing rental properties.

JLH assists prospective and actual tenants (collectively referred to as Tenants, including any individual guarantors of any Tenant) in finding rental properties and creating tenancies, and offers a variety of other services related to renting properties.

For the purposes of this Privacy Policy, Landlords and Tenants are collectively referred to as Users.

JLH Status Under GDPR

Depending on the nature of the interaction, JLH may act as a processor when following instructions from our Users in the provision of our services. When JLH controls the purposes and means of processing personal data, such as when processing our employees' personal data, JLH acts as a controller, as defined under GDPR.

What Legal Reasons Do We Use to Process Personal Data?

The legal reasons JLH uses to process personal data are outlined in Article 6 of the Regulation. In alignment with the business model adopted by JLH, our processing is lawful if at least one of the following conditions is met:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes (Consent).
• Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract (Contract Performance).
• Processing is necessary for compliance with a legal obligation which JLH is subject to (Legal Obligations).
• Processing is necessary for the purposes of the legitimate interests pursued by JLH, except where our interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, particularly if the data subject is a child (Legitimate Interest).

Concent

When JLH processes personal data based on the data subject's consent, JLH ensures that the consent is freely given, specific and informed, and established by a clear affirmative action. If consent is withdrawn, JLH outlines the procedure for doing so below.

Contract Performance

When JLH enters into a contract, processing personal data may be necessary to execute the contract or to take preparatory steps prior to entering into the contract.

Legal Obligations

When Japan London Homes has legal obligations to fulfill, processing personal data may be required by law.

Legitimate Interest

When JLH processes personal data based on our legitimate interests, We do so after carefully evaluating the balance between our interests and the data subject's rights and freedoms that require protection.

Currently, JLH has determined that our data processing practices provide sufficient protections for data subjects, justifying our reliance on Article 6.1(f) of the Regulation as a lawful basis for processing personal data.

Sensitive Personal Data

When JLH processes sensitive personal data on behalf of a User, we do so based on the User having established a lawful exception to the prohibition on processing sensitive personal data under Article 9 of the Regulation. For processing the sensitive personal data of employees, JLH relies on its employment relationship with its employees, using the exception provided in paragraph 2(b) of Article 9 of the Regulation.

JLH’s Use of Personal Data: Overview

The way JLH collects and uses personal data varies depending on the nature of our interaction with the individual whose data We are processing. For example, personal data provided by a prospective Tenant when registering on the JLH website may be used for multiple purposes and in different capacities, depending on the services We are offering.

For employees, We have outlined how their personal data will be processed in connection with their employment. Consequently, We have detailed how personal data is handled within our business and in the context of the services We offer throughout our commercial life cycle, specifically for Landlords and Tenants. Additionally, we have explained how We process personal data for other services and third parties.

Overall, our goal is to be transparent and to comply with the requirements of the Regulation.

Landlords

How Personal Data is Collected:

Landlords interested in learning more about JLH services can enter their details on our website at https://www.japanlondonhomes.com or any associated landing pages, or through an enquiry form. Landlords may also email or call us directly using contact details provided on our website or elsewhere. This information is typically collected for purposes such as entering into a relationship with JLH by accepting our terms and conditions, requesting that We contact them, reading or downloading information, or requesting support from our support team.

Occasionally, We may also connect with relevant business contacts at events or research individuals using social media platforms. When these individuals are approached (or approach us) in their capacity as employees of their organization, the interaction is considered a business-to-business exchange.

Type of Personal Data Collected:

Landlord personal data may include information such as a name, telephone number, home address, email address, place of employment, IP address from the device being used, online identifiers, as well as property and property-related information and location data. We do not knowingly collect sensitive personal data.

When a Landlord visits our website, We may collect and process information about their website usage, such as browsing history and navigation through our website, using cookies and similar technologies. Additionally, during communications with us, We may process information about these interactions.

Who Controls the Personal Data:

When a Landlord agrees to JLH's terms and conditions and enters into an agreement with JLH for services, the Landlord controls the purposes for processing personal data under that agreement and is thus considered the data controller.

Who Processes the Personal Data:

When JLH acts on the instructions of the Landlord according to their agreement, JLH serves as a processor. Additionally, Landlord personal data is processed by JLH and by our website, email, CRM, marketing platform providers, and third-party contractors who process personal data on our behalf. This processing is conducted in compliance with the Regulation and the ePrivacy Directive.

Where Personal Data is Stored and How It Is Used:

Landlord personal data is stored in our databases and is primarily utilised to deliver our services. It may also be utilised to send updates and information about our services, to enhance and refine our services, including their format and content, and to manage our website and internal operations. This includes activities such as troubleshooting, data analysis, testing, research, and conducting statistical and survey purposes. Additionally, we use this data as part of our efforts to maintain the security of our website, to assess the effectiveness of any advertising we present to you and others, and to provide relevant information.

How Long Personal Data Is Stored:

Landlord personal data is retained by JLH for the duration of the Landlord's contract with the Tenant and thereafter in accordance with the applicable limitation periods under English law. If the Landlord withdraws consent to receive marketing materials from JLH, or if the retention of personal data is no longer necessary in accordance with the principles outlined in Article 5 of the Regulation, the personal data will either be deleted or archived. When personal data is archived, it is kept to ensure that JLH maintains records of marketing consent or the withdrawal of such consent.

Type of Personal Data Collected:

Data collected from Tenants via the JLH website may include information such as name, telephone number, home address and past addresses, visa status and its expiry date, employment status and history, email address, and IP address from the device being used. We may also collect online identifiers and location data. Occasionally, We may gather sensitive personal data. In providing services such as setting up an application, We may process additional data including move-to and move-from addresses, moving dates, tenancy details, council tax status, and other information required for these services, including details about other occupants or household members.

When a Tenant visits our website, We may collect and process information about their usage of the site, such as browsing history and navigation patterns, using cookies and similar technologies. During communications, We may also process information about their interactions with us.

As part of our Referencing services, We may collect and process data including, but not limited to, the Tenant's date of birth, address history, nationality, occupation, income, passport details, and other necessary information. Similar details may also be required from the Tenant's Guarantor, if applicable.

Who Controls the Personal Data:

When a Tenant agrees to JLH's terms and conditions and discloses personal data to JLH for assistance in finding rental properties, JLH controls the resulting disclosure of this data to Landlords. Once the data is shared with a Landlord for further communication regarding the rental property, the Landlord becomes the controller of the data.

If the Tenant instructs JLH to assist in creating a tenancy for a specific property (such as by placing a holding deposit through our Making Offer service), the Tenant controls the processing of personal data in this context.

Who Processes the Personal Data:

When a Tenant, through JLH, begins discussions with a Landlord with the intention of agreeing to a contract, and Tenant personal data is disclosed to the Landlord by JLH, this data is transmitted under agreed terms. Under these terms, JLH acts as the processor. Tenant personal data may also be processed by JLH through our website, email, CRM, marketing platform providers, and third-party contractors who process personal data on our behalf. This processing is conducted in compliance with the Regulation and the ePrivacy Directive.

Where Personal Data is Stored and How It Is Used:

Tenant personal data is provided for the purpose of obtaining JLH's services and is stored in our databases. It is primarily used to enable us to deliver our services. Additionally, it may be used to send updates and information about our offerings, to implement and enhance our services, including their format and content, and to manage our website and internal operations. This includes activities like troubleshooting, data analysis, testing, research, and conducting statistical and survey analyses.

As part of our efforts to maintain the security of our website, We may also use this data to measure or understand the effectiveness of any advertising We present to you and others, and to provide relevant information. Anonymised bank data may be stored for the purpose of conducting anti-fraud checks.

How Long Personal Data Is Stored:

Tenant personal data is retained by JLH for the duration of the Tenant's contract with the Landlord and afterward, in accordance with the applicable limitation periods under English law. If the Tenant withdraws consent to receive marketing materials from JLH or if the retention of personal data is no longer necessary under the principles set out in Article 5 of the Regulation, the data will either be deleted or archived. When personal data is archived, it is kept to maintain records regarding marketing consent or the withdrawal of such consent.

Referencing:

To provide our Referencing services, we will perform a soft credit check on the Tenant or Guarantor (collectively, "Applicant") using Equifax Limited, a leading credit reference agency. To do this, we will need to share relevant personal data with Equifax. Equifax will store and act as the controller of this data. They provide a privacy notice detailing their data usage, available at https://www.equifax.co.uk/crain/. The dataset provided by Equifax to JLH may include, among other things, a history of the Applicant's County Court Judgments, adverse credit, risk score, bankruptcies, and electoral roll data.

JLH will process the data received from Equifax and use it to compile a report to be sent to the Landlord. In this context, JLH acts as a processor under the instruction of the Landlord, who serves as the controller.

For the purpose of Referencing, with the Applicant's consent, JLH will also process online financial account information received from TrueLayer Limited to assess the Applicant's income on behalf of the Landlord. Relevant personal data will need to be provided to TrueLayer, who details their data use in their privacy notice, available at https://truelayer.com/privacy. JLH will receive data, including the Applicant's banking transactions, and will use this data to compile a report for the Landlord. This report helps determine the Applicant's suitability for the tenancy. In this process, JLH acts as a processor, while the Landlord is the controller.

Payment Data

How Personal Data is Collected:

Users provide payment details to JLH during the service onboarding process to purchase JLH services, set up automatic payments, and facilitate payments to them (such as rent and deposit funds).

Type of Personal Data Collected:

Payment data includes information such as the name, address, bank account sort code, bank account number, payment card number, payment card issue date, payment card expiry date, and the three-digit or four-digit security number.

Who Controls the Personal Data:

Payment data is controlled by Users and processed by JLH according to User instructions, in accordance with the terms and conditions agreed upon with Users.

Who Processes the Personal Data:

User payment data is processed by JLH and our third-party payment gateway providers.

How Personal Data Is Used:

User payment data is used to charge for the use of our services and to transfer rent collected by JLH on behalf of the Landlord. Tenant payment data may be used to debit the Tenant's account for payments related to JLH services. Additionally, it may be used in situations where the Tenant has overpaid rent, ensuring that a record is maintained for appropriate reimbursement.

Employees

How Personal Data is Collected:

JLH employees provide their personal data to JLH through email, digital platforms or paper exchanges to facilitate the normal employer-employee relationship.

Type of Personal Data Collected:

Personal data may include an employee's name, mobile number, email address, home address, photo, postcode and notes about their role and skills. We also collect sensitive personal data related to health, as necessary and in a proportionate manner.

Who Controls the Personal Data:

Personal data of JLH employee is controlled by JLH.

Who Processes the Personal Data:

JLH processes employee personal data, which is also handled by third-party platforms that assist us in meeting standard employment requirements. This includes tasks such as processing employee payments through a third-party payroll service and sharing payment data with HMRC, as required by law.

How Personal Data Is Used By The Controller:

All JLH employee data is processed in compliance with the Regulation to ensure that the relationship between the employee and JLH is conducted in a manner consistent with the legal expectations of both parties, as well as any relevant third parties, such as HMRC.

How Long Personal Data Is Stored:

JLH employee personal data is retained by JLH for the duration of the employee's contract and subsequently in accordance with JLH's data retention policy, which considers limitation periods under applicable law.

Third Party Contractors

How Personal Data is Collected:

JLH engages third parties to deliver certain services, such as conducting gas safety inspections. We work with various businesses across different locations and collect the personal data of individuals associated with these third-party businesses.

Type of Personal Data Collected:

Personal data provided by individuals connected to third parties may include their name, email, phone number, home address, place of work, skill set and work history. We do not collect sensitive personal data.

Who Controls the Personal Data:

Personal data of third-party is controlled by JLH.

Who Processes the Personal Data:

Third-party personal data is processed by our suppliers when these third parties require instructions via email, for example, or when payments are made to them.

How Personal Data Is Used By The Controller:

Third-party personal data is managed by JLH when it is necessary to support the provision of our services.

How Personal Data Is Used By The Processor:

Third-party personal data is used by our processors to ensure that third-party contractors have the necessary information to provide services to JLH and to facilitate their payment.

How Long Personal Data Is Stored:

Third-party personal data is retained for as long as necessary and is subsequently archived or deleted in accordance with our data retention framework.

Sharing Information

We may share information with third parties to help us provide our services. Selected third parties may include:

• Other JLH Users, such as providing your details to a User advertising a property if you request to view it.
• Suppliers and sub-contractors for the performance of a contract, or, for example, providing your details to a gas engineer so they can contact you to arrange a visit to the property where the service has been ordered.
• Analytics and search engine providers that help us improve and optimize our website.

We may also disclose your personal information to third parties in the following situations:

• If JLH or a substantial portion of its assets is acquired by a third party, personal data held by JLH (in part or in whole) may be among the transferred assets.
• If we are required to disclose or share personal data to comply with a legal obligation, or to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of JLH or others. This may include exchanging information with other companies and organisations for fraud protection and credit risk reduction.

Transferring Out Of The EEA

Storing Personal Data:

We use cloud providers for the storage of personal data. In some instances, personal data may be transferred to and stored at locations outside the European Economic Area (EEA).

Processing Personal Data:

We may engage third parties, some of whom are based outside the EEA, to assist in delivering our services. When personal data is transferred outside the EEA, We ensure compliance with mechanisms approved by the European Commission, such as EU model contract clauses or adherence to the US Privacy Shield. Additionally, when We use sub-processors on our behalf, We ensure they also comply with these recognised standards by the European Commission.

Where We Are The Processor:

We may transfer personal data to jurisdictions outside the EEA (and non-adequate jurisdictions) when acting as a processor under the instructions of a third-party controller, such as a Landlord. In these cases, it is the responsibility of the third party to ensure that such transfers comply with GDPR requirements.

Where We Are The Controller:

We will retain personal data for as long as necessary. As described above, there are instances where we have a legal or statutory obligation to retain information for a specific period, such as during the limitation period.

Where We Are The Processor:

Personal data is stored according to the instructions provided by Landlords, in alignment with their approach to data retention, as long as it complies with the Regulation. We suggest reviewing their Terms of Use and Privacy Policy (where applicable) for further details.

Security Measures

We have implemented security measures aimed at protecting the personal data We collect or receive in connection with our services from unauthorized access or disclosure. For instance, We employ encryption techniques and password protection to secure data. However, it's important to note that no data transmission or storage method can be guaranteed to be completely secure, and We cannot fully ensure or warrant the security of the information We collect and store.

Cookies

We use cookies to differentiate you from other users of our website. This helps us enhance your browsing experience and allows us to improve our website. By continuing to browse, you consent to our use of cookies. A cookie is a small file made up of letters and numbers that we store on your browser or your computer’s hard drive if you agree. Cookies contain data that is transferred to your computer's hard drive. We use the following types of cookies:

Strictly Necessary Cookies:

These are essential cookies required for the operation of our website. They include, for instance, cookies that enable you to log into secure areas of the site.

Analytical/Performance Cookies:

These cookies enable us to recognise and count the number of visitors to our website and observe how they navigate through it. This information helps us improve the website's functionality, ensuring that users can easily find what they are looking for.

Functionality Cookies:

These cookies are used to recognise you when you return to our website. They allow us to personalise our content for you, greet you by name and remember your preferences, such as your chosen language or region.

Targeting Cookies:

These cookies track your visit to our website, including the pages you have viewed and the links you have followed. We use this information to tailor our website to better align with your interests.

First Party Cookies

How Do I Block First Party Cookies?:

You can block first party cookies by adjusting your browser settings to refuse the setting of all or certain cookies. However, please note that if you block all cookies, including essential ones, you may not be able to access certain parts of our website.

Third Party Cookies

We may use third party services, such as Google Analytics cookies, to track anonymous usage statistics. These cookies do not collect any personal information that could identify you. The data collected helps us analyse web page usage and improve our website to better meet our audience's needs. Services like Google Analytics store information about the pages you visit, how long you stay on the site, how you arrived there, and what you clicked on. These cookies are typically served by a third party service provider and are often used to recognise your computer when it visits other websites, such as when you log in to a social media site to share content.

How Do I Block Third Party Cookies?:

You can block third party cookies by adjusting your browser settings to refuse the setting of all or some cookies. However, please note that if you choose to block all cookies, including essential ones, you may experience difficulties accessing certain parts of our website.

Further Information

More information about cookies can be found at: https://www.allaboutcookies.org

Internet Advertising Bureau: Guide to online advertising privacy

International Chamber of Commerce United Kingdom: ICC UK cookie guide

Your Right to Complain

If you have any concerns about how we handle your personal data, you can file a complaint with the Information Commissioner’s Office in the United Kingdom by following the instructions at www.ico.org.uk. If you prefer to address your concerns directly with JLH, please reach out to us at info@japanlondonhomes.com.

Contacting You

The personal data we process is protected by strict measures and procedures designed to minimize the risk of unauthorized access or disclosure. If a data breach occurs, we will notify the supervisory authority, which in our case is the Information Commissioner, and the affected data subjects as required by the Regulation.

Changes To This Privacy Statement

If We make any changes to this privacy statement, We will inform you by publishing the updated version on our website.

Your Right

At the request of the data subject and where technically possible, We will confirm the information We hold about the data subject and how it is processed. In line with the Regulation, a data subject can request the following information.

• Identity and Contact Details: Information about the person or organization that has determined how and why to process personal data, which may include a representative in the EU.
• Data Protection Officer: Contact details of the data protection officer, if applicable.
• Purpose and Legal Basis: The purpose of the processing and the legal basis for it.
• Legitimate Interests: If the processing is based on legitimate interests of JLH or a third party, details of those interests.
• Categories of Data: The types of personal data collected, stored and processed.
• Recipients: The recipients or categories of recipients to whom the data is or will be disclosed.
• International Transfers: Information about any transfer of personal data to a third country or international organization and the security measures in place for such transfers. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure information.
• Data Retention: The duration for which the personal data will be stored.
• Data Subject Rights: Details of the data subject's rights to correct, erase, restrict or object to processing.
• Right to Withdraw Consent: Information on the data subject's right to withdraw consent at any time.
• Complaints: How to lodge a complaint with the supervisory authority.
• Provision of Data: Whether providing personal data is a statutory or contractual requirement, or necessary to enter into a contract, and the consequences of not providing such data.
• Source of Data: The source of personal data if not collected directly from you.
• Automated Decision-Making: Any details about automated decision-making, including profiling, the logic involved, and the significance and expected consequences of such processing.

What Forms Of ID Will I Need To Provide In Order To Access This?:

When requesting information about your personal data from JLH, the following forms of identification are accepted:

• Passport
• Driving license
• Birth certificate
• Utility bill from the previous 3 months

JLH reserves the right to request additional information if the provided identification is not clear or sufficient.

Contact Details

Londora Global Ltd.

Contact Name: Data Protection Officer
Address: Londora Global Ltd., 3rd Floor, 86-90 Paul Street, London, EC2A 4NE
Email: info@japanlondonhomes.com