Privacy Policy

Policy Version: April 11th, 2025

INTRODUCTION

This Privacy Policy is provided by DOTGOMM LTD (Company No. 16289808) having its registered office at 60 High Street Chobham, Woking, Surrey, United Kingdom, GU24 8AA (‘we’, ‘our’ or ‘us’) for use of our Rentman – Lettings and Estate Agency Software platform, associated websites, and web portal (collectively referred to as “Services”).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share personal data. We operate under two distinct roles as defined by UK GDPR: (1) as a data processor processing personal data strictly under our customers' instructions through our Services, and (2) as a data controller determining the purposes and means of processing business contact information for our own operations. This policy transparently outlines our obligations and responsibilities under both roles.

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We act as a data processor on behalf of our customers (lettings and estate agents) who are the data controllers of the personal data processed through our Services. However, we are the data controller for certain personal data we collect directly, such as account management information of our customers.
WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

PERSONAL DATA WE COLLECT ABOUT YOU

As a data processor, we process the following categories of personal data on behalf of our customers (letting and estate agents) through our Services:

Category of Data	In more detail
Identify and account data you input into the Services Registration is mandatory in order to use the Services	Your name and email address Your account details, such as username and password
Data collected when you use specific functions in the Services	Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you permit the collection of location data	Details of your location with a high degree of precision, see the section ‘Location services/data’ below data concerning location is collected when using the Maps function of the Services
Other data the Services collects automatically when you use it	Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use Technical information including device type, operating system version, browser type, app version number, IP address, and usage analytics to ensure proper system functionality and security
Data collected concerning properties	Property details including addresses, specifications, images, and related documentation as provided by our customers for property management purposes. While some of this information may not constitute personal data, we handle all property-related information with appropriate security measures.
Data collected when you make an enquiry with us	Your name and email address

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

SENSITIVE DATA

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that while we generally do not process sensitive personal data, our customers may need to collect and process certain sensitive data for legitimate business purposes, such as for tenant verification processes. Any such processing will be carried out in accordance with applicable data protection laws, including additional safeguards required for special category data under Article 9 of the UK GDPR, and the privacy policies of our customers (the data controllers). We have implemented specific technical and organisational measures to protect any sensitive data processed through our platform.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature, we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
LOCATION SERVICES/DATA

Our Services may process property location data as necessary for property management and advertising purposes. This data is provided by our customers and is essential for the core functionality of our property management platform.

Our platform includes comprehensive audit logging capabilities that track all data access and modifications. This helps ensure data security and allows our customers to maintain oversight of their data processing activities. Property location data is essential for our services and cannot be disabled as it is core to the property management functionality.

All customer data is hosted on Microsoft Azure servers located in the UK, with individual databases for each customer on shared MySQL servers. We maintain appropriate technical and organisational measures including encryption at rest and in transit, access controls, and regular security testing to ensure the security of your data. Our data storage architecture ensures logical separation between customer databases, and we maintain comprehensive backup and disaster recovery procedures. Customers can access their data through our desktop application or web portal, with optional local backup capabilities. For information about Microsoft Azure's data protection practices, please visit https://azure.microsoft.com/en-us/privacy/.
How your personal data is collected

As a data processor, we collect and process personal data on behalf of our customers (letting and estate agents) through the Services. This includes data related to properties, tenants, landlords, contractors, applicants, and employees, as well as associated payment histories, banking details, and legal documents. We also collect account management data directly from our customers' authorised users, including login credentials, user preferences, access logs, and system usage statistics. This data is retained for the duration of the account's active status plus 12 months after account closure for security and audit purposes, after which it is securely deleted or anonymised in accordance with our retention schedule.

We use Microsoft Azure cloud services to host our platform and store data in the UK. Each customer's data is stored in an individual database on shared MySQL servers. Our comprehensive auditing tools track all access and modifications to data, including who accessed the data, when, and from where. This information is stored securely and is only accessible for legitimate business purposes such as technical support, bug fixing, and security monitoring. Customers have the option to maintain local backups of their data through our automated backup utility.

How and why we use your personal data

For the limited purposes where we act as a data controller (such as managing customer accounts and providing technical support), we rely on the following. As a data processor, we process personal data under instructions of our customers (the data controllers) and in accordance with data protection law. The legal bases for processing:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) the Maps Function will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

As a B2B service provider, we may send email marketing communications about our services and promotions to our direct customers (letting/estate agents) and their authorised business representatives where we have a legitimate interest to do so or where you have provided explicit consent. These communications will be limited to information about our services, system updates, and relevant promotions.

As a B2B service provider, we will obtain appropriate consent before sending marketing communications to business contacts at letting/estate agencies. This consent may be obtained when setting up your business account or through explicit opt-in procedures. If you have previously opted-in to receiving marketing communications or were given the option to opt-out during account creation and did not do so, we may continue to send you relevant business communications.

You will have the right to opt out of receiving marketing communications at any time by:
- contacting us at info@dotgomm.co.uk
- using the ‘unsubscribe’ link included in all marketing emails you may receive from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes. For more information on your right to obect at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with

We routinely share personal data with carefully selected service providers and integration partners who act as our sub-processors. Each sub-processor has been assessed for compliance with UK GDPR requirements and is bound by appropriate data processing agreements that ensure the security and confidentiality of personal data. We maintain an up-to-date list of all sub-processors, including the categories of data processed and specific safeguards in place.
Each sub-processor has been carefully selected and is bound by data processing agreements that ensure compliance with UK GDPR requirements. These integrations are under customer control and can be configured for both manual and automated data transfers. Customers can choose which integrations to enable and configure how data is shared. Each integration partner has their own privacy policy, and we recommend reviewing these policies for more information about how they handle personal data.

We only allow service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We implement strict security protocols and data processing agreements with all integration partners, including regular security assessments and audit requirements. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you. All third-party integrations are secured through industry-standard encryption and authentication mechanisms, and data transfers are logged and monitored for security purposes.

We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

How long your personal data will be kept

As a data processor, we will retain customer data in accordance with our customers' (the data controllers') instructions and our contractual obligations. Our default retention periods vary by data category: financial records are retained for 6 years to comply with tax regulations; tenancy records for 6 years after tenancy end; marketing preferences for 2 years; and general correspondence for 3 years after service termination. Upon service termination, data will be securely archived with restricted access limited to essential personnel on a strict need-to-know basis. Customers may request different retention periods based on their specific requirements.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK

While our primary data processing occurs on Microsoft Azure servers located in the UK, some data may be transferred to DotGomm Inc. in Canada for technical support and maintenance purposes. Additionally, data may be transferred to third-party integration partners (including DocuSign, Vorensys, TDS, RSign, Rightmove, Zoopla, and OnTheMarket) based on our customers' configurations and preferences. These transfers can occur both manually and through automated processes (e.g., daily property listing updates). Our customers maintain full control over which integrations are enabled and how they are used. All such transfers comply with UK data protection laws and appropriate safeguards are in place to protect your personal data. For transfers to Canada, we rely on the UK's adequacy regulation. For other international transfers, we implement appropriate safeguards such as Standard Contractual Clauses.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguard under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Your rights

As a B2B service provider, we process personal data on behalf of our customers (letting/estate agents) who are the data controllers. If you are an end-user whose data we process (tenant, landlord, contractor, or applicant), please note that these rights should primarily be exercised through your letting/estate agent, who is the data controller responsible for your personal data. We will assist the data controller in responding to your requests in accordance with our obligations as a data processor. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any automated decisions that produce legal effects or similarly significant effects concerning you. While we use automated processing for routine operations such as data backup and security monitoring, these processes do not involve automated decision-making that affects your rights or interests.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at www.dotgomm.ca or email, call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We implement robust security measures to protect personal data through our secure infrastructure, which includes MySQL databases hosted on secure shared servers. We implement robust security measures to protect personal data on secure Microsoft Azure servers in the UK. These measures include: maintaining separate databases for each customer, implementing comprehensive audit trails to monitor data access and modifications, and restricting access to authorised personnel for support and maintenance purposes. Data can be accessed through our desktop application, web portal, or directly through the database by authorised Company personnel for support purposes. We maintain detailed logs of who accesses the data, when, and for what purpose, both through our application interfaces and backend systems. Customers may also have the option to maintain local backups of their data.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We strongly recommend implementing proper user access management procedures, including: promptly deactivating accounts when employees leave your organisation, regularly reviewing active user accounts, and assigning appropriate access levels based on job responsibilities. We recommend following industry best practices for securing your Rentman account and protecting your clients' data. This includes using strong passwords, enabling two-factor authentication where available, and ensuring secure access to both the desktop application and web portal. For additional cybersecurity guidance, you may visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes (including changes to data processing activities, data sharing practices, or your rights under this policy), we will notify our customers (letting/estate agents) directly via email and through notifications in the Rentman desktop application and web portal at least 30 days before the changes take effect, and we will provide appropriate documentation to support this communication. As a data processor, we recommend that our customers inform their end-users of any relevant changes that affect their data processing.
How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

DotGomm Ltd
167-169 Great Portland Street
5th Floor
London
W1W 5PF
info@dotgomm.co.uk

+44 1200 377520