Last updated: 9 January 2021
We are committed to protecting your Information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at holmes-app.com
When you use the Platform, you trust us with your information. We take your privacy very seriously. We want to explain in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the Platform.
CHANGES TO THE POLICY OR YOUR PERSONAL DATA
We review the Policy regularly and it is your responsibility to check regularly and determinate whether this Policy has changed. If you do not agree to any change to the Policy then you must immediately stop using the Platform. In the event we make any significant changes to the Policy we will use our best endeavours to inform you or such changes in advance in writing.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes for example you change your email address.
The Platform is owned and operated by Holmes LLC (trading as Holmes), a company registered in Delaware with company number 4370773 whose registered office is situated at 8 The Green, Suite A, Dover, DE 19901, United States (Holmes/we/us/our). Holmes is the independent controller (also known as a data controller) and is responsible for your personal data. The term “you” refers to the user wishing to access and/or use the Platform.
As a company incorporated in the United States, Holmes has appointed Benjamin Fockter to act a representative in the United Kingdom and the European Union for the purposes of ensuring compliance with the UK and EU data protection laws and regulations. If you have any questions about your rights or your personal data in the UK and/or the EU, please contact us at firstname.lastname@example.org.
Holmes is a rented property review app. Users who register an account (a Registered User) can post and view reports of issues in the properties.
INFORMATION WE MAY COLLECT ABOUT YOU
Personal information you disclose to us
In Short: We collect personal information that you provide to us including information such as your name and email address, and information about your contacts and calendar data.
We collect personal information that you voluntarily provide to us when registering and using the Platform, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the products and features you use. When you use the Platform and/or when you otherwise deal with us, we may collect the following information about you (the Information):
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit the Platform.
We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. This information is primarily needed to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.
Occasionally we may receive information about you from other sources, for example from other users of the Platform who provide your contact details to us when creating or managing their events through the Platform. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
How do we use your information?
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the Platform for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Obligations). We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes:
Will your information be shared with anyone?
In Short: We only share information to comply with Legal Obligations, to protect your rights, fulfil our business obligations to you or with your Consent.
We only share and disclose your Information in the following situations:
We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Platform. In such circumstances we do not disclose any information which can identify you personally.
Is your information transferred internationally?
In Short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
Whenever we transfer your Information outside of the country where you created an account with Holmes App, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. To the extent that any transfer requires approved safeguards are in place (for example if transferring outside of the European Economic Area that the EU model contract clauses) we will ensure these measures are in place.
In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the Platform.
The Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Platform. You should review the policies of such third parties and contact them directly to respond to your questions.
How long do we keep your information?
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing Business Purpose to process your Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of personal information to and from the Platform is at your own risk. You should only access our services within a secure environment.
Do we collect information from minors?
In Short: We take steps to ensure that the Platform are only used by those over 12 years of age and we do not knowingly collect data from or market to children under 12 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Platform, you represent that you are at least 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
Your Consent to processing
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Platform.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing firstname.lastname@example.org.
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Platform and you object or do not provide Consent to us processing your Information, the Platform will not be available to you.
Marketing and opting out
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to email@example.com or unsubscribing from the communications.
You may at any time review or change the information in your account. You may change your account name or email address on your account tab in the Holmes App.
If you wish to terminate your account you must click on the “Delete Account” button on your account tab in the Holmes App. Some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service and/or comply with legal requirements.
What are your privacy rights?
In Short: You have certain rights in respect of your Information.
You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Information, (ii) to request rectification or erasure of your Information; (iii) to restrict the processing of your Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Information. To make any requests, please contact us at firstname.lastname@example.org. We will consider and act upon any request in accordance with applicable data protection laws.
We may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
We welcome your feedback and questions on this Policy. If you wish to contact us please email us at email@example.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.