Privacy Policy

1. Who We Are

Our services are operated by:

Email: dpo@holt.global

iLet Technologies Limited is established in Ireland and provides its services in multiple countries.

2. Data Controller and Data Processor

The role of Holt depends on how and why personal information is being processed.

Where Holt acts as a Data Processor

When a landlord, property owner, property manager or letting agent uses Holt to manage properties, lettings, tenancy applications or related activities, that organisation will generally determine why the relevant personal information is processed.

That organisation will generally act as the Data Controller, and Holt may process the information on its behalf in providing our services.

This includes tenancy applications submitted through HeyNeighbour and subsequently managed by the relevant landlord, property manager or letting agent through Holt Agent.

The relevant Data Controller may provide its own privacy notice explaining how it processes your information.

Where Holt acts as a Data Controller

Holt acts as a Data Controller where we determine why and how personal information is processed for purposes including:

• user account registration;
• reusable HeyNeighbour profiles;
• authentication and login;
• website and platform administration;
• customer support;
• security monitoring;
• fraud prevention;
• service improvement;
• legal and regulatory compliance; and
• billing and contractual administration, where applicable.

In some circumstances, Holt may therefore act as a Data Processor for one purpose and a Data Controller for another.

3. Information We Collect

Depending on how you use our services, we may collect the following categories of personal information.

Identity Information

• Full name
• Date of birth
• Photograph, where provided
• Nationality, where required
• Government-issued identification

Contact Information

• Email address
• Telephone number
• Current address
• Previous addresses

Employment and Financial Information

Where required for a tenancy application:

• Employer details
• Employment status
• Occupation
• Salary or income information
• Payslips
• Employment references
• Bank statements
• Other proof of income

Rental and Household Information

This may include:

• Previous landlords
• Previous rental history
• References
• Guarantor details
• Household members
• Pets
• Vehicles
• Intended occupants
• Preferred move-in date

Supporting Documentation

Depending on the requirements of the landlord, property manager or letting agent, you may upload documents including:

• Passport
• Driving licence
• Other proof of identity
• Proof of address
• Utility bills
• Bank statements
• Payslips
• Employment letters
• Visa documentation
• Tax documentation
• References
• Other supporting documentation relevant to the application

Application Information

Where you apply for a property through HeyNeighbour, we may process:

• the property you applied for;
• your application answers;
• application status and history;
• eligibility information;
• application requirements;
• co-applicant information; and
• information generated as part of managing your application.

Business User Information

Where you use Holt Agent on behalf of a landlord, letting agent, property manager or other organisation, we may process information including:

• your name and contact details;
• your organisation or company;
• your user role and permissions;
• account activity; and
• information necessary to administer your access to the service.

Communications

We may retain communications made through our services, including:

• support requests;
• enquiries; and
• messages relating to tenancy applications, lettings or use of our services.

Technical Information

When you use our services, we may automatically collect certain technical information including:

• IP address;
• browser type;
• operating system;
• device information;
• login history;
• platform usage;
• security logs; and
• cookie information.

4. How We Collect Your Information

We may collect personal information:

• directly from you;
• when you create or update an account or profile;
• when you complete or submit a tenancy application;
• when you upload supporting documents;
• when you communicate with us;
• through cookies and similar technologies;
• from landlords, property managers or letting agents where necessary;
• from co-applicants; and
• from third parties where you have authorised them to provide information or where otherwise permitted by law.

Where you provide information about another person, you should ensure that you are entitled to provide that information.

5. How We Use Your Information

We may use personal information to:

• create and manage user accounts;
• maintain reusable HeyNeighbour profiles;
• enable prospective tenants to apply for rental properties;
• submit applications to landlords, property managers and letting agents;
• enable those organisations to review and manage applications;
• manage properties and lettings through Holt Agent;
• process application requirements and supporting documentation;
• communicate regarding applications and our services;
• provide customer support;
• operate and secure our platforms;
• prevent fraud and misuse;
• maintain appropriate records;
• improve our services;
• comply with legal and regulatory obligations; and
• establish, exercise or protect legal rights.

We do not sell personal information.

We do not use information contained in tenancy applications for third-party advertising.

6. Legal Basis for Processing

The legal basis for processing depends on the purpose of the processing and the law applicable to you.

Where Holt acts as a Data Controller, we may process personal information where:

• processing is necessary to provide a service requested by you or perform a contract;
• processing is necessary to comply with a legal obligation;
• processing is necessary for our legitimate interests or those of another party, where permitted by law and those interests are not overridden by your rights;
• you have provided consent where consent is required; or
• another lawful basis applies under applicable data-protection legislation.

Where Holt acts as a Data Processor, the relevant landlord, property manager, letting agent or other Data Controller is responsible for determining the appropriate legal basis for its processing.

Where sensitive or special-category personal information is processed, an additional lawful condition will be relied upon where required by applicable law.

7. Sharing Your Information

When you submit a tenancy application, relevant information will be shared with the landlord, property manager or letting agent responsible for the property.

Information processed through Holt Agent may similarly be accessible to authorised users of the organisation responsible for the relevant property, letting or application.

We may also share information with trusted service providers where necessary to operate our services, including providers supporting:

• cloud hosting and storage;
• email and communications;
• security and technical infrastructure;
• customer support; and
• professional services.

Where these providers process personal information on our behalf, appropriate data-protection obligations apply.

We may also disclose information where required by law or where reasonably necessary to establish, exercise or defend legal rights.

We do not sell personal information.

8. Reusable Tenant Profiles

HeyNeighbour allows prospective tenants to maintain a reusable profile so that information does not need to be entered again for every rental application.

Creating a profile does not make your information generally available to landlords or letting agents.

When you choose to apply for a property, relevant information from your profile and application may be shared with the landlord, property manager or letting agent responsible for that property.

Submitting an application for one property does not automatically make your information available to organisations responsible for other properties.

9. Data Retention

We retain personal information only for as long as necessary for the purposes for which it is processed and to meet applicable legal, regulatory and record-keeping obligations.

Typical retention periods include:

Landlords, property managers and letting agents may be subject to their own legal or regulatory record-keeping obligations and may apply different retention periods.

Where Holt acts as a Data Processor, retention may also be determined by the relevant Data Controller.

Information may be deleted earlier where it is no longer required and there is no legal, regulatory or other lawful reason for continued retention.

10. Security

Protecting personal information is important to us.

We implement appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration or disclosure.

These measures include appropriate access controls, secure infrastructure and security procedures.

Although we take appropriate precautions, no internet-based system can be guaranteed to be completely secure.

11. International Transfers

Holt is established in Ireland and provides services in multiple countries.

Personal information may be processed or stored in countries other than the country in which you are located.

Where applicable data-protection law restricts international transfers of personal information, we will use an appropriate lawful transfer mechanism or safeguard.

Depending on the jurisdictions involved, this may include an adequacy decision, approved contractual safeguards or another legally recognised transfer mechanism.

12. Cookies

We use cookies and similar technologies to:

• authenticate users;
• maintain secure sessions;
• remember preferences;
• provide website and platform functionality;
• analyse platform performance where applicable; and
• maintain security.

Where consent is required for non-essential cookies or similar technologies, we will request that consent.

Further information is available in our Cookie Policy.

13. Your Rights

Depending on where you are located and the applicable data-protection laws, you may have rights including the right to:

• access your personal information;
• request correction of inaccurate information;
• request deletion of your information;
• restrict or object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing relies on consent;
• obtain information about how your information is processed; and
• lodge a complaint with an appropriate data-protection authority.

These rights may be subject to conditions and exceptions under applicable law.

Where Holt processes information solely on behalf of a landlord, property manager or letting agent, requests relating to your tenancy application may need to be directed to the relevant Data Controller.

European Economic Area

Where GDPR applies, you have the rights provided by GDPR and may lodge a complaint with the relevant data-protection supervisory authority.

As an Irish-established company, Holt's Irish supervisory authority is:

Data Protection Commission

You may also have the right to complain to the supervisory authority in the EEA country in which you live or work.

Other Countries

Holt may provide its services in countries outside the European Economic Area. Where local privacy or data-protection legislation applies to our processing of personal information, we will comply with applicable requirements.

Depending on your location, you may have additional privacy rights or protections. Where necessary, we may provide additional country-specific privacy information or notices.

Nothing in this Privacy Policy is intended to limit any rights you have under applicable privacy or data-protection law.

14. Application Assessment and Automated Processing

HeyNeighbour and Holt Agent provide technology that assists landlords, property managers and letting agents in managing tenancy applications.

Depending on the application process configured by the relevant organisation, the platform may assist with checking application requirements, organising application information and displaying eligibility or other application information.

These tools support the application process.

Holt does not make the final decision to offer or refuse a tenancy.

The landlord, property owner, property manager or letting agent responsible for the property makes that decision.

If we introduce automated decision-making that produces legal or similarly significant effects on individuals, we will provide any additional information and safeguards required by applicable law.

15. Children's Information

HeyNeighbour is intended for use by individuals aged 18 years or older.

Applicants may provide limited information relating to dependent children or other household members where relevant to a tenancy application.

Such information should be limited to what is reasonably necessary for the application or tenancy.

16. Privacy Policy Acknowledgement

When you submit an application or create an account, we may ask you to confirm that you have been provided with or have read our Privacy Policy.

Acknowledging the Privacy Policy does not mean that you consent to every processing activity described in it. Where consent is required for a particular processing activity, we will request that consent separately where appropriate.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legislation, technology, our services or the countries in which we operate.

The most recent version will be published through our website or services together with its effective date.

Where appropriate, we may notify users of material changes or ask users to acknowledge an updated version.

18. Contact Us

If you have any questions regarding this Privacy Policy or our processing of personal information, please contact:

Email: dpo@holt.global

Where your request relates to information controlled by a landlord, property manager or letting agent, we may direct the request to or coordinate with that organisation.