Version 2.05

Effective Date: April 1,2020

Last Revised: May 1,2020

Off-Grid.Net.com ( “Off-Grid.Net” ) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our Website, located at www.Off-Grid.Net.com and Services. Any terms not defined herein shall have the meaning given to them in the associated Terms of Use available at https://www.Off-Grid.Net.com/terms.

  1. Questions; Contacting Off-Grid.Net; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following email or address:

support@Off-Grid.Net.com

Off-Grid.Net.com

Attn: Nick Rosen

First floor, Roxborough House,

273-287 Regent Street, London W1  UK

  1. User Consent. By submitting Personal Data through our Website or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
  2. A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Off-Grid.Net and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at support@Off-Grid.Net.com.
  3. A Note to Users Outside of the United States. If you are a non U.S. user of the Website, by visiting the Website and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
  4. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. For Renters, Personal Data also means: and for “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
  1. Information You Provide to Us.
  • We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses, company name, and password when you create an account to log in to our network ( “Account” ).
  • If you use our Services on your mobile device, we may collect your phone number and the unique device id number.
  • If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can deactivate GPS on your mobile device.
  • When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
  • When you order services on our Website, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. We do not store this information directly on our servers, but this information may be shared with third parties who will help process and fulfill your purchases. When you submit credit card numbers, we encrypt that information using industry standard technology.
  • We retain information on your behalf, such as files and messages that you store using your Account.
  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
  • When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Website, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page ( “Profile” ). The information that you provide in your Profile will be visible to others, including anonymous visitors to the Website.
  • When you post messages on the message boards of our Website, the information contained in your posting will be stored on our servers and other users will be able to see it.
  • When you participate in one of our surveys, we may collect additional profile information.
  • We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
  • If you participate in a sweepstakes, contest or giveaway on our Website, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
  • We may also collect Personal Data at other points in our Website that state that Personal Data is being collected.
  1. Information You Provide to Facebook and other Social Networking Websites. The Services allow users to access Facebook to interact with friends and to share on Facebook through Wall and friends’ News Feeds. If you are already logged into the Services and Facebook or another SNS, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to merge your profiles. If you are already logged into the Services but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Services to access your information and you are agreeing to the Facebook or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Services, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account on the Website and show our relevant content from your Facebook or SNS friends. Once you register on the Website and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. You have the option to disable Facebook Connect at any time by logging into your Account through the Website and going to “Manage account” from the drop-down menu, and then clicking “remove” next to Facebook. Further, you can edit privacy settings for the reviews that appear on Facebook or disconnect your Services activity stream by visiting the Facebook Applications Settings page.
  2. Information Collected via Technology.
  • Information Collected by Our Servers. To make our Website and Services more useful to you, our servers (which may be Ownered by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
  • Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Website or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
  • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs.
  • Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
  • How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
  • Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
  • Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Website. This includes third party analytics services, including but not limited to Google Analytics ( “Analytics Services” ), that we engage to help analyze how users use the Website, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Website and Services. The information generated by the Cookies or other technologies about your use of our Website and Services (the “Analytics Information” ) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Website and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at support@Off-Grid.Net.com. We may also partner with ad companies to support out marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting https://www.aboutads.info/ or https://networkadvertising.org/choices/.
  1. Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at support@Off-Grid.Net.com to request the removal of this information from our database. As part of your use of the Services, we provide you the opportunity to connect automatically with your friends. We employ various techniques in order to facilitate friends finding each other on our service, including offering contact importer tools to facilitate adding to your contacts (including Facebook Friends and contacts in your address book) so that you can more readily ask your contacts to join and communicate with you through the Services. With your permission, we will access your address book, call log and SMS log, and import your contacts’ names, e-mail addresses, phone numbers, image, geographic location and Facebook IDs to facilitate automatic connection with your friends. We do this only for contact matching to help your friends and you find each other. Also, when you invite friends to the Services, we will access your Address Book and we will import your contacts names and phone numbers in order to facilitate the invitation. The e-mail that is sent to your friends will come from your e-mail address so that your friends know that you want to invite them to visit the Website. We do not store any passwords you provide as part of the contact import process. We also collect some settings that help us to interpret your data, such as the language and keyboard settings that you have established, and the phone’s carrier, mobile network code and mobile country code.
  2. Google ID. We allow you to use your Google ID to set up an Account. If you wish to use your Google account you are taken to the Google website to login to your account and this information is then shared with us for the sole purpose of setting up your Account.
  3. Location Information. If you have enabled location services on your phone, we collect your location information to make a map more relevant to your location. If you do not want this information collected by us, you can disable location services on your phone.
  1. Use of Your Personal Data
  1. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
  • facilitate the creation of and secure your Account on our network;
  • identify you as a user in our system;
  • provide improved administration of our Website and Services;
  • provide the Services you request;
  • improve the quality of experience when you interact with our Website and Services;
  • send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • respond to your inquiries related to employment opportunities or other requests;
  • make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Off-Grid.Net; and
  • provide necessary information to relevant parties involved in a booking you’ve made on the Off-Grid.Net marketplace
  1. User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Website from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Website, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
  2. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Website navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
  1. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
  1. Users. We will share your Personal data with other Users solely for the purpose of providing the Services.
  2. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Website; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Off-Grid.Net. These third party service providers are required not to use your Personal Data other than to provide the services requested by Off-Grid.Net.
  3. Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control ( “Affiliates” ), in which case we will require our Affiliates to honor this Privacy Policy.
  4. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
  5. Social Networking Websites. Some of our Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.
  6. Public Profile. Certain portions of the information you provide to us may also be displayed in your Profile. As an essential element of the Services, most of the Personal Data you explicitly provide to us when you register or update your Profile is displayed on your Profile. In order for your Profile to be made public, you must go to your profile settings and then to profile visibility. By default, your Profile is not for public viewing. Your photos, posts, friends, and other content you post to the Website are also meant for public consumption. We may display this content on the Website and further distribute it to a wider audience through third party sites and services. Once displayed on publicly viewable web pages, that information can be collected and used by others. We cannot control who reads your postings or what other users may do with the information that you voluntarily post, so it is very important that you do not put Personal Data in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Website, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).
  7. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Off-Grid.Net may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Off-Grid.Net; (c) to protect or defend the rights or property of Off-Grid.Net or users of the Website or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
  8. Third Party Websites. Our Website may contain links to third party websites. When you click on a link to any other website or location, you will leave our Website and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
  1. Your Choices Regarding Information. You have several choices regarding the use of information on our Service:
  1. Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Website or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
  2. Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
  3. De-Linking SNS. If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
  4. Changing or Deleting Your Personal Data. All users may review, update, or correct the Personal Data in their user account (including any imported contacts) by editing within the system or by making a request to support@Off-Grid.Net.com. You may delete your personal data and account by making a request to support@Off-Grid.Net.com. If you completely delete all of your Personal Data, then your user account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
  5. Security of Credit Card. For online payments, we use the payment services of Stripe, Inc. (https://stripe.com). We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://stripe.com/us/privacy.
  1. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here https://www.Off-Grid.Net.com/privacy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.

EUROPEAN GDPR

For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation 2016/679 the data controller is Off-Grid.Net Limited. Off-Grid.Net is registered at the ICO with number ZA083975.

Off-Grid.Net is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data We collect from you or that you provide to us, directly or indirectly, will be processed by us. Please read the following carefully to understand our views and practices regarding personal data and how We treat it.

Off-Grid.Net’s Data Protection Officer can be contacted at nick@off-grid.net.

The General Data Protection Regulation 2016/679

In this statement We have used certain terms which are set out in the General Data Protection Regulation 2016/679 (GDPR or the Regulation):

  • personal data means: any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • controller means: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • processor means: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • processing means: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

What We Do

Off-Grid.Net is an online letting agent, offering services and tools to make renting fairer, safer and cheaper for everyone.

Off-Grid.Net assists property owners and Owners (together, Owners (being either actual or prospective Owners)) in finding Renters and creating tenancies; and offers a range of other services relating to renting out and managing rental properties.

Off-Grid.Net assists prospective and actual Renters (collectively, Renters (which for the purposes of this privacy statement, shall be deemed to include any individual guarantors of any Renter)) in finding properties to rent and creating tenancies; and offers a range of other services relating to renting properties.

For the purposes of this Privacy Policy, Owners and Renters are referred to collectively, as Users.

Our Status Under GDPR

Depending on the nature of the interaction, We may act as a processor in that We are acting upon instructions from our Users when We provide our services to them; and when We control the purposes and means of the processing of personal data, such as processing our employees’ personal data, We act as a controller, as defined under GDPR.

What Lawful Reasons Do We Use To Process Personal Data?

The lawful reasons Off-Grid.Net uses to process personal data are set out in Article 6 of the Regulation and with respect to the business model undertaken by Off-Grid.Net, our processing is lawful given that at least one of the following applies:

  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Consent).
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Contract Performance).
  • processing is necessary for compliance with a legal obligation which We are subject to (Legal Obligations).
  • processing is necessary for the purposes of the legitimate interests pursued by Off-Grid.Net, except where our interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Legitimate Interest).

Consent

Where We process personal data as a result of data subject consent, We ensure that consent is freely given, specific and informed; and established by a clear affirmative act. Where consent is withdrawn, We have set out (below) how this may be undertaken.

Contract Performance

Where We enter into a contract, processing of personal data may, as a matter of course, be necessary in order to execute such a contract or take pre-contract preparation steps.

Legal Obligations

Where We have legal obligations which apply to Off-Grid.Net, processing of personal data may be required by law.

Legitimate Interest

Where We process personal data as it is necessary for the purpose of our legitimate interests, We do so on the basis of a balanced evaluation of our interests and the rights and freedoms of the data subject which require protection.

Presently, We have concluded that the way We manage the processing of personal data results in a cumulation of data subject protections which show that the balance is in favour of Off-Grid.Net being able to rely on Article 6.1(f) of the Regulation as a lawful reason to process personal data.

Sensitive Personal Data

Where Off-Grid.Net processes sensitive personal data on behalf of a User, Off-Grid.Net does so on the basis that the User has established a lawful exception to the prohibition on processing sensitive personal data under Article 9 of the Regulation; and where Off-Grid.Net is processing sensitive personal data of employees, it does so pursuant to its employment relationship with its employees and so uses the exception set out in paragraph 2(b) of Article 9 of the Regulation.

Off-Grid.Net’s Use Of Personal Data: Overview

How Off-Grid.Net collects and uses personal data differs based on the nature of the interaction with the individual whose personal data We are processing. For example, personal data provided by a prospective Renter when registering on the Off-Grid.Net website may be used for several purposes and in a different capacity by us, depending on the nature of the services We are providing. Where Off-Grid.Net’s engagement of an employee requires the processing of the employee’s personal data, We have also set out how this will be conducted. As a result, We have explained how personal data may be processed when used within our business, and in the context of the services we offer during our commercial life-cycle, i.e. in the context of the services We provide Owners and Renters, respectively. In addition, We have referred to other services which require the processing of personal data and how We process the personal data of third parties. In general, our objective is to inform through being transparent while being consistent with the requirements of the Regulation.

Owners

How personal data is collected: Owners interested in learning more about Off-Grid.Net’s services can enter their details into our website at https://www.Off-Grid.Net.com or any landing pages hosted at https://www.Off-Grid.Net.com or via an enquiry form; or Owners may email or call us directly using contact details provided on our website or elsewhere. This will likely be for the purposes of entering into a relationship with Off-Grid.Net through acceptance of our terms and conditions, requesting that We contact them, reading or downloading information, or requesting support from our support team. From time-to-time, We may also meet business-relevant connections at events or research individuals using social media platforms. Where these individuals are approached (or approach us) in their capacity as employees of their organisation, the interaction will be regarded as a business to business exchange.

Type of personal data collected: Owner personal data might include a name, telephone number, home address, email address, company of work and IP address from the device being used, online identifiers, property and property-related information and location data. We will not knowingly collect sensitive personal data. Where a Owner visits our website, We may collect and process information about their website usage (e.g. browsing history and information about their navigation through our website) using cookies and other similar technologies. During communications, We may process information about the interactions undertaken with us.

Who controls the personal data: Where (by agreeing to Off-Grid.Net’s terms and conditions) a Owner enters into an agreement with Off-Grid.Net and Off-Grid.Net provides services to the Owner, the Owner controls the purposes of the processing of personal data under the agreement and is a controller.

Who processes the personal data: Where Off-Grid.Net is acting upon the instructions of the Owner pursuant to the terms of their agreement, Off-Grid.Net is a processor. In addition, Owner personal data is processed by Off-Grid.Net and our website, email, CRM, marketing platform providers and third-party contractors, who process personal data on our behalf. This is undertaken in a manner that is consistent with the Regulation and the ePrivacy Directive.

Where personal data is stored; how personal data is used: Owner personal data is stored in our databases and is primarily used to allow us to deliver our services. It may also be used to send news and information about our services, to implement and improve our services, including format and content, to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, as part of our efforts to keep our website safe and secure, to measure or understand the effectiveness of any advertising We serve to you and others, and to deliver relevant information.

How long personal data is stored: Owner personal data is stored by Off-Grid.Net for the duration of the Owner’s contract with the Renter and thereafter in line with prescribed limitation periods under English law. Where the Owner withdraws consent to receive marketing material from Off-Grid.Net, or, retention of personal data is no longer necessary pursuant to the principles set out in Article 5 of the Regulation, personal data will either be deleted or archived. Where personal data is archived, it is kept to ensure that Off-Grid.Net does not lose its records with respect to marketing consent, or the fact of its withdrawal.

Renters

How personal data is collected: Renters interested in learning more about Off-Grid.Net’s services can enter their details into our website at https://www.Off-Grid.Net.com or any landing pages hosted at https://www.Off-Grid.Net.com or via an enquiry form; or Renters may email or call us directly using contact details provided on our website or elsewhere. Renters provide personal data to Off-Grid.Net for the purposes of accessing Off-Grid.Net’s services. Personal data is collected when the Renter populates their details online via the Off-Grid.Net website or an affiliate website run by partners such as Rightmove and Zoopla. During the course of the provision of Off-Grid.Net’s services to the Renter, the Renter may disclose additional personal data, which may involve more than one media.

Type of personal data collected: Data collected via the Off-Grid.Net website from Renters may include name, telephone number, home address and past addresses, employment status and employment history, email address and IP address from the device being used, online identifiers and location data. On occasion We may collect sensitive personal data. Where a Renter visits our website, We may collect and process information about their website usage (e.g. browsing history and information about their navigation through our website) using cookies and other similar technologies. During communications, We may process information about the interactions undertaken with us.

Who controls the personal data: When (by agreeing to Off-Grid.Net’s terms and conditions) a Renter discloses personal data to Off-Grid.Net with a view to using Off-Grid.Net’s services to assist the Renter in finding properties to rent, the resulting disclosure of personal data to Owners is controlled by Off-Grid.Net. When the data has been disclosed to the Owner for the purposes of further communication regarding renting the property, the Owner will then be the controller of the data. Where the Renter instructs Off-Grid.Net to assist the Renter with creating a tenancy for a particular property (for example, by placing a holding deposit through Off-Grid.Net’s website using our Rent Now service), the processing of personal data in this context is controlled by the Renter.

Who processes the personal data: Where the Renter, through Off-Grid.Net, commences discussions with the Owner with a view to agreeing a contract with the Owner; and Renter personal data has been disclosed to the Owner by Off-Grid.Net, Renter personal data is sent to the Owner through Off-Grid.Net under agreed terms with the Owner. Under these terms, Off-Grid.Net is the processor. Renter personal data may also be processed by Off-Grid.Net through our website, email, CRM, marketing platform providers and third-party contractors, who process personal data on our behalf. This is undertaken in a manner that is consistent with the Regulation and the ePrivacy Directive.

Where personal data is stored; how personal data is used: Renter personal data is provided for the purposes of obtaining Off-Grid.Net’s services and is stored in our databases and is primarily used to allow us to deliver our services. It may also be used to send news and information about our services, to implement and improve our services, including format and content, to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, as part of our efforts to keep our website safe and secure, to measure or understand the effectiveness of any advertising We serve to you and others, and to deliver relevant information.

How long personal data is stored: Renter personal data is stored by Off-Grid.Net for the duration of the Renter’s contract with the Owner and thereafter in line with prescribed limitation periods under English law. Where the Renter withdraws consent to receive marketing material from Off-Grid.Net, or, retention of personal data is no longer necessary pursuant to the principles set out in Article 5 of the Regulation, personal data will either be deleted or archived. Where personal data is archived, it is kept in order to ensure that Off-Grid.Net does not lose its records with respect to marketing consent, or the fact of its withdrawal.

Payment Data

How personal data is collected: Users provide payment details to Off-Grid.Net in the service on-boarding process, in order to purchase Off-Grid.Net services to set up automatic payments and to allow us to make payments to them (for example, rent and deposit funds).

Type of personal data collected: Payment data includes a name, address, bank account sort code, bank account number, payment card long number, payment card issue date, payment card expiry date and three-digit security number.

Who controls the personal data: Payment data is controlled by Users and processed by Off-Grid.Net under User instruction, subject to terms and conditions with Users.

Who processes the personal data: User payment data is processed by Off-Grid.Net and our third-party payment gateways.

How personal data is used: User payment data is used to charge for the use of our services, or to send rent collected by Off-Grid.Net on behalf of the Owner. Renter payment data may be used to debit the Renter’s account for payments required when the Renter uses Off-Grid.Net services; it may also be used where the Renter has overpaid rent (for example) and a record is required to ensure suitable reimbursement.

Employees

How personal data is collected: Off-Grid.Net employees provide Off-Grid.Net with their personal data though email, digital or paper-exchange, in order for the employee and Off-Grid.Net to undertake a normal employer-employee relationship.

Type of personal data collected: Personal data might include a name, mobile number, email address, home address, photo, post code and notes about their role and skills. We collect sensitive personal data with respect to health, as necessary and in a proportionate manner.

Who controls the personal data: Personal data of Off-Grid.Net employees is controlled by Off-Grid.Net.

Who processes the personal data: Off-Grid.Net processes employee personal data which is also processed within third party platforms used to help us provide standard employment requirements such as payment of the employee through a third-party payroll business; or dissemination of payment data to HMRC, as is required by law.

How personal data is used by the controller: All Off-Grid.Net employee data is used in accordance with the Regulation in order to ensure that the relationship between the employee and Off-Grid.Net is undertaken in a manner that is consistent with the legal expectations of the parties in addition to third parties (such as HMRC, as referred to above).

How long personal data is stored: Off-Grid.Net employee personal data is stored within Off-Grid.Net for the duration of the employee’s contract with Off-Grid.Net and thereafter in accordance with Off-Grid.Net’s data retention policy which shall take into account limitation periods under the general law.

Job Candidates

How personal data is collected: Candidates interested in applying for a role at Off-Grid.Net may provide their personal details by email or through our job application platform to express their interest in a role.

Type of personal data collected: Personal data inputs by job candidates may include: name, email, phone number, home address, place of work, education and work history alongside their skills. We will not collect sensitive personal data.

Who controls the personal data: Job candidate data is controlled by Off-Grid.Net.

Who processes personal the data: Job candidate data is processed by our software providers and consultants involved in helping us to recruit candidates and manage employees.

How personal data is used by the controller: Job candidate data is used by Off-Grid.Net to manage and communicate with candidates in relation to the role they have applied for at Off-Grid.Net.

How personal data is used by the processor: Job candidate data is used by our processors to enable us to accept and manage applications and to support decision making processes.

How long personal data is stored: Job candidate data is stored for as long as necessary. It is then archived or deleted pursuant to our data retention framework.

Third Party Contractors

How personal data is collected: Off-Grid.Net engages third parties to deliver some services, for example to carry out gas safety inspections. Off-Grid.Net uses a number of businesses in various geographies and collects the personal data of data subjects connected to the third-party businesses concerned.

Type of personal data collected: Personal data input by data subjects connected to third parties may include: name, email, phone number, home address, place of work, skill-set and work history alongside their skills. We will not collect sensitive personal data.

Who controls the personal data: Third party personal data is controlled by Off-Grid.Net.

Who processes the personal data: Third party personal data is processed by our suppliers where such third parties require instructions by email (for example); and where third parties are paid.

How personal data is used by the controller: Third party personal data is managed by Off-Grid.Net where it is required to assist in the provision of services.

How personal data is used by the processor: Third party personal data is used by our processors to ensure that third party contractors have the information they need to provide Off-Grid.Net with services; and be paid for doing so.

How long personal data is stored: Third party personal data is stored for as long as necessary. It is then archived or deleted pursuant to our data retention framework.

Sharing Information

We may share information with third parties so that they can assist us in providing our services; selected third parties could include:

  • Other Off-Grid.Net Users, for instance supplying your details to a User advertising a property if you request to view that property.
  • Suppliers and sub-contractors for the performance of a contract, or (by way of example) supplying your details to a gas engineer to allow them to contact you and arrange a date and time to visit the property at which the service has been ordered.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may also disclose your personal information to third parties:

  • If Off-Grid.Net or substantially all of its assets are acquired by a third party, in which case personal data held by Off-Grid.Net (in part or in whole) may be one of the transferred assets.
  • If We are under a duty to disclose or share personal data to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of Off-Grid.Net or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Transferring Out Of The EEA

Storing personal data: We use cloud providers to store our personal data. Occasionally, personal data may be transferred to and stored at a destination outside the European Economic Area (EEA).

Processing personal data: We may use third parties to help us deliver our services and they may be based outside the EEA. Where data is transferred outside the EEA, We adhere to compliance mechanisms that are identified by the European Commission, for example, the use of EU model contract clauses or conformity to US Privacy Shield. Where We use sub-processors acting on our behalf, We ensure that they adhere to compliance mechanisms that are identified by the European Commission.

Where We are the processor: We may transfer personal data to non-EEA (and non-adequate) jurisdictions where We are a processor, pursuant to the instructions of a third-party controller, such as a Owner. Where We do so, it is the third party’s responsibility to ensure that such transfer is consistent with GDPR.

Data Retention Periods

Off-Grid.Net has a data retention policy which sets out how long it will store personal data, which is consistent with Article 5 of the Regulation. Off-Grid.Net only keeps personal data for as long as is necessary. For example, Off-Grid.Net is required to retain certain information in accordance with the general law, where information is needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held beyond these periods depending on Off-Grid.Net’s business needs, which are balanced against the requirements of the Regulation and the rights of the individual.

Where We are the controller: We will retain personal data for as long as necessary. As described above, in some cases, We will have a legal or statutory obligation to retain information for a set period, such as the limitation period.

Where We are the processor: Personal data is stored as instructed by Owners in accordance with their approach to retention of personal data provided that this is within the Regulation. We recommend that you view (where applicable) their Terms of Use and Privacy Policy for more information.

Security Measures

We have implemented security measures that are designed to help protect the personal data We collect or receive in connection with our services, from unauthorised access or disclosure. For example, We use encryption techniques to ensure the security of data; We also use password protection. However, no transmission or storage of data can be guaranteed to be completely secure and We cannot ensure or warrant the security of any information which We collect and store.

Cookies

We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. By continuing to browse the website, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

Analytical/performance cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests.

First Party Cookies

How do I block first party cookies?

You block first party cookies by activating the settings on your browser that allow you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Third Party Cookies

We may use third party services such as Google Analytics cookies to track anonymous usage statistics but We do not collect any personal information that can be used to identify you. This data helps us analyse web page usage and improve our website to tailor it to our audience needs. Services such as Google Analytics store information about what pages you visit, how long you are on the website, how you got there and what you clicked on. These are cookies served by a third-party service provider and are usually used to identify your computer when it visits another website, for example, when you log in to a social media site to share an article.

How do I block third party cookies?

You block third party cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Further Information

More information about cookies can be found at: https://www.allaboutcookies.org

Internet Advertising Bureau: Guide to online advertising and privacy

International Chamber of Commerce United Kingdom: ICC UK cookie guide

Your Right To Complain

If you have a complaint about the way We process your personal data, you can register your concern by contacting the Information Commissioner of the United Kingdom (the Information Commissioner) and following the instructions set out at www.ico.org.uk. Where you wish to contact Off-Grid.Net about your concerns, please contact nick@off-grid.net.

Contacting You

The personal data We process is subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. We will get in touch with the supervisory authority (which in Off-Grid.Net’s case, is the Information Commissioner) and with affected data subjects where this is required under the Regulation.

Changes To This Privacy Statement

If We change this privacy statement, We will let you know about the changes by publishing the updated version on our website.

Your Rights

At the request of the data subject and where this is technically possible, We will confirm the information We hold about the data subject and how it is processed. As set out in the Regulation a data subject can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process personal data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Off-Grid.Net or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If We intend to transfer the personal data to a third country or international organisation, information about how We ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, We will ensure there are specific measures in place to secure information.
  • How long the personal data will be stored.
  • Details of data subject’s rights to correct, erase, restrict or object to such processing.
  • Information about the data subject’s right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether We are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Off-Grid.Net accepts the following forms of ID when information on your personal data is requested: passport, driving licence, birth certificate, utility bill from the previous 3 months. We reserve the right to request further information where your identification is not clear.

Contact Details

Off-Grid.Net Limited

Contact Name:

Data Protection Officer

Address:

6th Floor, 2 London Wall Place, London, United Kingdom, EC2Y 5AU

Email:

nick@off-grid.net

Summary Of Data Processors By Type

In order to provide our services to our Users, Off-Grid.Net works with carefully selected third parties in the sectors/disciplines set out in the non-exhaustive list below:

Description/Type

Nature of Processing

Hosting

Housing of personal and general organisational data

SMS Provider

Messaging; information

Financial and contractual management software

Accounting software; payroll services

Email Provision

Message and data transfer between parties

Banking Services

Financial services

Reference Services

Renter evaluation

Payment Services

Transfer of consideration/funds

Marketing and Customer Service Management Systems

Housing of Renter and Owner personal data within a hosted environment