Privacy Policy

Last updated: Dec 29, 2022

Introduction

Please read this Privacy Policy carefully. By using any of the services that are set out in our Terms and Conditions You agree to be bound by this Privacy Policy. You must not use this website or our Services if you do not accept this Privacy Policy. If You are providing us with another person's information You should first ask them to read this Privacy Policy and Terms and Conditions. By giving Us information about another person You are confirming that they have given You consent to provide the information to Us and that they understand how their details will be used.

We are Caasa Solutions Limited, trading as Caasa, (us, our, we), company registration number 12427467. We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information. This policy explains the information we collect, how we collect it and for which purposes. By using the Caasa website and the services we provide you are agreeing to be bound by this policy in respect of information collected about you through this site.

It is important that uou read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Our Website may contain links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

Caasa Solutions Limited is the controller and responsible for your personal data.

We use your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

If you do not agree with this policy please do not use this website.

Collecting and Using Your Personal Data

While using our Service, We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you.

Types of Data Collected

We may collect, use, store and transfer different kinds of personal data about you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The type of personal data that we may collect, use, store and transfer may include, but not limited to:

Identity Data includes first name, last name, title and date of birth.
Contact Data includes billing address, home address, email address and mobile telephone number.
Tenancy Data includes contract length, tenancy contract renewal intentions, landlord or agent identity and contact data.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, referral source, length of visit and number of page views for system administration. This is statistical data about our users' browsing activity and patterns and does not identify any individual.
Profile Data includes your email and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. we do not collect any Special Categories of Personal Data about You (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How Is Your Personal Data Collected

We use different methods to collect data from and about You including through:

Direct interactions: you may give us your Identity, Contact, Tenancy and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions: as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Third parties or publicly available sources: we may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe.
- Usage & results of survey data from platform partners such as Vaboo.
- Identity and Contact Data from publicly availably sources such as the Electoral Register based inside the EU.

How We Use Your Personal Data & Justification of Use

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Use of personal information under UK and EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:

Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at contact@caasa.io.

Purposes For Which We Use Your Personal Data

The table below provides a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. we have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

" Purpose / Activity "	" Type of Data "	" Justification "
To register you as a new customer and supply our services to you	a) Identity b) Contact c) Tenancy d) Financial e) Transaction	a) Contract Performance
To process and deliver our services including: a) Manage, payments, fees, charges. b) Collect & recover money owed to us.	a) Identity b) Contact c) Financial d) Transaction e) Marketing and Communications	a) Contract Performance b) Legitimate Interest (to recover debts due to us)
To manage our relationship with You which will include: a) Notifying You about changes to our terms or privacy policy b) Asking You to leave a review or take a survey c) Managing enquiries and complaints	a) Identity b) Contact c) Marketing and Communications	a) Contract Performance b) Legitimate Interest (maintain accurate records & understand how customers use our products/services)
Enable you to partake in a prize draw, competition or complete a survey	a) Identity b) Contact c) Profile d) Usage e) Marketing and Communications	a) Contract Performance b) Legitimate Interest (understand how customers use our products/services & develop/grow our business)
Administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	a) Identity b) Contact c) Technical	a) Legitimate Interest (running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) b) Comply with legal obligations
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of advertising we serve to you	a) Identity b) Contact c) Technical d) Profile e) Marketing and Communications f) Usage	a) Legitimate Interest (to study how customers use our products/services, to develop and grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experience	a) Technical b) Usage	a) Legitimate Interest (define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Create aggregated data for market research, from which all personal data is removed	a) Profile b) Transaction	a) Legitimate Interest (to define how differing customer types/segments use our products and services, assist our product development and product/service partnership strategy)
To make suggestions and recommendations to You about goods or services that may be of interest to you	a) Identity b) Transaction c) Contact d) Technical e) Usage f) Profile	a) Legitimate Interest (to develop our products/services and grow our business)
Send you communications & notifications pertaining to the provision of our products/services via the Caasa platform or platform partners	a) Identity b) Contact	a) Performance of our contract with you b) Legitimate Interest
Send to You our newsletter and/or other marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest, where you have specifically agreed to this, by email, sms notifications or similar technology. You can inform us at any time if you no longer require marketing communications to be sent by emailing us at help@caasa.io	a) Identity b) Contact c) Marketing and Communications	a) Performance of our contract with you b) Legitimate Interest

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage, Transactional and Profile Data to form a view on what we thinkyYou may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside Caasa for marketing purposes.

Opting Out

You can ask Us or third parties to stop sending uou marketing messages at any time by contacting us at help@caasa.io.

Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclousure Of Your Personal Data

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

We may have to share your personal data with the parties set out below for the purposes set out in the table in "How We Use Your Personal Data & Justification of Use" above.

External Third Parties such as:

Service providers and business partners, including payments processors, database & technology providers, to assist us in performing any contract we enter into with them or you, including providing the website and the services it enables. Analytics providers, (to assist us in the improvement and optimisation of the Website). Email marketing providers, we may use Email Marketing Service Providers to manage and send emails to you.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Fraud prevention agencies acting as processors or joint controllers based in the United Kingdom.

Specific Third Parties such as:

Vaboo

By signing up to any of our rewards platform subscription plans, you consent to the sharing of your personal information with Vaboo Limited for the provision & administration the of the service.

Stripe

We share your personal information with third party payment processor Stripe, which manages all payment related activity (fees/refunds) associated with a Caasa subscription. Further information in relation to Stripe can be found in our terms of service.

Third Parties In The Event Of Sale, Transfer Or Merger

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

Third Parties - General Notice

we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Storage, Processing & International Transfers

We make every effort to ensure that the personal data we collect from you, is processed and stored in the European Economic Area ("EEA"). However, we may choose to utilise external third-party organisations, business partners/service providers, who are based outside the EEA, or who have employees who are based outside of the EEA, to store and/or process your personal data. In these circumstances, we will endeavour to ensure that a similar degree of protection is afforded to your personal data, by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements.

Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 72 hrs. If your account is inactive for 2 years, we may contact you to assess whether you want to continue to use the Services. Some personal data may need to be retained for longer than this to ensure Caasa can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.

If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

In some circumstances we may irreversibly anonymise your data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us.

Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at support@caasa.io You have the following rights in relation to your personal data:

Right to Rectification:

We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data, where you believe the personal data we have is inaccurate or incomplete.

Right to erasure / 'Right to be forgotten':

Asking us to delete all of your personal data will result in Caasa deleting your personal data without undue delay (unless there is a legitimate and legal reason why Caasa is unable to delete certain of your personal data, in which case we will inform you of this in writing).

Right to restriction of processing:

You have the right to ask us to stop processing your personal data at any time.

Right to data portability:

You have the right to request that Caasay provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.

Right to complain:

You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner's Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints.

Right to object to discussions based solely on automated processing:

You have the right to not be subject to a decision based solely on automated processing which produces legal effects concerning your or similarly significant effects and to obtain human intervention, to express your point of view or contest the decision. Caasa will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs. Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Caasa's Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services. Where you request Caasa to rectify or erase your personal data or restrict any processing of such personal data, Caasa may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example payment processing companies.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within 14 days. Occasionally it may take us longer than 14 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at info@caasa.io