Privacy Policy

Introduction

Welcome to the Kangaroom Limited ("Kangaroom") privacy policy.

Kangaroom respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website(s) (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.Important information and who we are

1.1 Purpose of this privacy policy.

This privacy policy aims to give you information on how Kangaroom collects and processes your personal data, particularly through your use of our website(s), including any data you may provide through our website(s) when you, for example, register for an account or sign up to our alerts.

1.2 Use by children.

Our website(s) are not intended for children and we do not knowingly collect data relating to children.

1.3 Please read.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

1.4 Controller – who we are.

Kangaroom Limited (Company Registration: 8500124) with a registered office address of Acre House, 11/15 William Road, London, NW1 3ER, United Kingdom and a trading address of Suite 2.06, Colony One Silk Street, Ancoats Urban Village, Manchester, M4 6AG, United Kingdom is the controller and responsible for your personal data (collectively referred to as "Kangaroom", "we", "us" or "our" in this privacy policy).

1.5 Data Privacy Manager.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your legal rights, please contact the data privacy manager using the details set out below.

1.6 Contact details.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

1.6.1 Full name of legal entity: Kangaroom Limited;

1.6.2 Email address: hello@kangaroom.com;

1.6.3 Postal address: Kangaroom Limited, Suite 2.06, Colony One Silk Street, Ancoats Urban Village, Manchester, M4 6AG, United Kingdom

1.7 Right to complain.

If you have a complaint about any aspect of our privacy policy, how we are handling your data or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact us using the contact details set out above. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or other competent supervisory authority if you use our website(s) outside the UK. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or other competent supervisory authority, so please contact us in the first instance.

1.8 Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. The new policy may be displayed on-screen or, if we consider it to be appropriate, sent to you by email and you may be required to read and accept the changes to continue your use of the website or Services. 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.

1.9 Third-party links.

Our website(s) may, from time to time, include links (or advertisements which operate as links) to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or applications and are not responsible for their privacy statements or their cookie policies. When you leave our website(s), we encourage you to read the privacy policy, cookie policy and terms and conditions of every website or application you visit.

2.The data we collect about you

2.1 Personal Data.

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).

2.2 Categories of Data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.2.1 Identity Data: this includes first name, last name, username or similar identifier, title and gender.

2.2.2 Contact Data: this includes address, email address and telephone numbers.

2.2.3 Technical and Device Data: this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, referral source, the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, operating system and platform, and other technology on the devices you use to access our website(s).

2.2.4 Content Data: this includes information stored on your device, including login information, photos, videos or other digital content

2.2.5 Profile Data: this includes your username and password, ads placed by you through our website(s), your interests, searches, preferences, and friends list.

2.2.6 Usage Data: this includes information about how you use our website(s) and services including length of visit, number of page views and similar information.

2.2.7 Marketing and Communications Data: this includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3 Aggregated data.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

2.4 Special categories of personal data.

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.

2.5 If you fail to provide personal 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 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.

3.How is your personal data collected?

3.1 Different methods.

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

3.1.1 Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms, using functionality on our website(s) or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:

(i) create an account on our website(s);
(ii) post an ad on our website(s);
(iii) respond to an ad on our website(s);
(iv) request marketing or alerts to be sent to you;
(v) report a problem with our Service or our website(s) (including the content contained within them); or
(vi) give us feedback or contact us;

3.1.2 Automated technologies or interactions. As you interact with our website(s), we will automatically collect Technical and Device Data and Usage 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 and Device Data about you if you visit other websites employing our cookies.

3.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as those set out below:

(i) Technical and Device Data and Usage Data from analytics providers such as Google based outside the UK.
(ii) Identity, Contact and Profile Data from third parties where you have logged into our website(s) using your profile and account information of that third party’s website or app, such as Facebook based outside the UK.
(iii) if you are a journalist or social influencer, Identity and Contact Data from third party providers of contact databases relating to journalists and social influencers.

4.How we use your personal data

4.1 How we use your personal data.

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:

4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.

4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.1.3 Where we need to comply with a legal obligation.

Click Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

4.2 Consent.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

5.Purposes for which we will use your personal data

5.1 Purposes.

We have set out below, in a table format, 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. Please 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
(c) Profile
 Performance of a contract with you
To publish your ads (and make them searchable by others) and facilitate introductions (a) Identity
(b) Contact (although we will not share your email address with other users of our website(s))
(c) Profile (although we will not share your passwords, searches, preferences, friends list or feedback with other users of our website(s))
 Performance of a contract with you
To notify you by email of:
(a) other user’s ads matching search preferences
(b) other user’s interest in your ad(s)
 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (for running our business, ensuring services remain suitable and improving customer experience and improving customer service)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Notifying you about changes to our services
(c) Communicating information about the products and/or services provided to you
(d) Providing customer services to deal with enquiries and complaints
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, ensure services remain suitable and improve our customer service)
To match you with other users of our website(s) who you are already friends with on Facebook or have similar interests or histories (a) Identity
(b) Contact
(c) Profile
 Necessary for our legitimate interest (for running our business and for aiding users in finding suitable flatmates, ensuring services remain suitable and improving user’s experience of our website(s))
To administer and protect our business and our website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, removing unsuitable content and protecting our users from fraud) (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical and Device
 (a) Necessary for our legitimate interests (for running our business, ensuring services remain suitable, improve user experience, provision of administration and IT services (including issue resolution), network security, to help resolve customer disputes, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Technical and Device
(d) Usage
(e) Profile
(f) Marketing and Communications
 Necessary for our legitimate interests (to study how customers use our products/services and to improve user experience, to develop them, encourage customer engagement, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website(s), products/services, marketing, customer relationships and experiences (a) Usage
(b) Technical and Device
 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website(s) updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical and Device
(d) Usage
(e) Profile
(f) Marketing and Communications
 Necessary for our legitimate interests (to develop our products/services, encourage customer engagement and grow our business)
To verify your identity (a) Identity
(b) Contact
(c) Technical and Device
(d) other data such as customer type, customer role, billing type and subscriber status from your wireless operator
 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (for running our business, ensuring services remain suitable, verifying your identity, to prevent fraud and improve user experience)
If you are a journalist or social influencer, to provide information to you that may be interesting to you or relevant to you (a) Identity
(b) Contact
(c) Marketing and Communications
 Necessary for our legitimate interests (to develop our products/services, encourage customer engagement and grow our business)

6.Marketing

6.1 Personal data control mechanisms.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

6.1.1 Promotional offers from us. We may use your Identity, Contact, Technical and Device, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and events may be relevant for you (we call this marketing). You will receive marketing communications from us if: (i) you have requested information from us; or (ii) purchased goods or services from us; or (iii) registered an account with us; and you have not opted out of receiving that marketing.

6.1.2 Third-party marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

6.2 Opting out.

You can ask us to stop sending you marketing messages at any time by:

6.2.1 Email link - following the opt-out links on any marketing message sent to you; or.

6.2.2 Contact us - contacting us at any time using the contact details set out at the beginning of this privacy policy.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.

6.3 Cookies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website(s) may become inaccessible or not function properly.

6.4 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.

7.Disclosures of your personal data

7.1 Sharing your personal data.

Other than as expressly set out in this privacy policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent. We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:

7.1.1 Internal Third Parties as set out in the Glossary;

7.1.2 External Third Parties as set out in the Glossary;

7.1.3 Specific third parties such as:

(i) Google Analytics to help us understand our users’ usage and behaviour across our platforms;
(ii) Facebook Analytics to help us understand our users’ usage and behaviour across our platforms;

7.1.4 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 policy.

7.2

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.

7.3

You should note that the public elements of our website(s), including your profile (with the exception of your email address and password) and any ads you post on our website(s), will be visible to other users of our website(s) anywhere in the world. You should, therefore, be careful when submitting information about yourself and only submit information you are happy to be publicly available.

8.International transfers

8.1 Transfers outside the UK.

We share your personal data with other companies within the same group as Kangaroom and many of our External Third Parties are also based outside the UK, so the processing of your personal data will involve a transfer of data outside the UK.

8.2 Protections.

Save where an exception may apply, whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

8.2.1 Adequacy - We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see the guidance provided on the Information Commissioner’s Office website (www.ico.org.uk) relating to International transfers and UK "adequacy regulations".

8.2.2 Model Contracts/Standard Contractual Clauses - Where we use certain service providers, we may use specific contracts or standard contractual clauses approved for use in the UK which give personal data the same protection it has in the UK. For further details, see the guidance on the Information Commissioner’s Office website (www.ico.org.uk) relating to Model Contracts/Standard Contractual Clauses.

9.Data security

9.1 Security measures.

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. However, data transmission over the internet is inherently insecure so, whilst we have put in place appropriate security measures to protect your data, we cannot guarantee the security of any data sent over the internet. 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.

9.2 Personal data breach.

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.

10.Data retention

10.1 How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us using the contact details set out at the beginning of this privacy policy.

10.2 Deletion.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

10.3 Anonymisation.

In some circumstances we will anonymise your personal 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.

11.Your legal rights

11.1 Your legal rights.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

11.1.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it

11.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

11.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

11.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

11.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(i) if you want us to establish the data's accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

11.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

11.1.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11.2 Exercise your legal rights.

If you wish to exercise any of the rights set out above, please contact us using the contact details set out at the beginning of this privacy policy.

11.3 No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

11.4 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.

11.5 Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

12.Glossary

12.1 LAWFUL BASIS

12.1.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

12.1.2 Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

12.1.3 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the contact details set out at the beginning of this privacy policy.

12.1.4 Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

12.1.5 Vital Interest means processing your data where it is necessary in order to protect your vital interests or the vital interests of another natural person.

12.2 THIRD PARTIES

12.2.1 Internal Third Parties. Other companies in the same group as Kangaroom acting as joint controllers or processors and who are based in the United Kingdom and United States of America and provide marketing, standards maintenance, quality control, fraud prevention, IT and system administration services and undertake leadership reporting.

12.2.2 External Third Parties

(i) Service providers acting as processors based in the United Kingdom, European Union, United States of America and Canada who provide IT and system administration services, analytics services, advertising services, hosting services and any other services necessary to enable us to provide you with any products or services that you have requested through our website(s).
(ii) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and United States of America who provide consultancy, banking, legal, insurance and accounting services.
(iii) Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(iv) A third party where you have logged into our website(s) using your profile and account information from that third party’s website or app, such as Facebook.
(v) Any third party who intends to publish any comments or reviews you have written about our website(s) in any medium, including on third party websites, so your comments and review can be verified by that third party.
(vi) Any person to whom disclosure is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of Kangaroom or our customers (including contacting those you have communicated with in cases where we suspect activity which is fraudulent or in breach of our terms and conditions) or users of our website(s) or the public.