LanTeno — Privacy Policy

Effective date: [DATE] Version: [1.0]

LanTeno Limited ("LanTeno", "we", "our", "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store and share your information when you use our platform and related services (the "Platform"), and your rights under data-protection law.

This policy should be read together with our Terms of Service. Words defined in the Terms have the same meaning here. We are the data controller for the personal data described in this policy, except where we act as a processor on a customer's behalf (see section 3).

1. Who we are

LanTeno Limited, a company registered in England and Wales (company number [NUMBER]).

• Registered office: Northgate Business Centre, Newark Upon Trent, Nottinghamshire, NG24 1EZ
• Privacy contact: privacy@lanteno.co.uk
• ICO registration number: [NUMBER]

2. Scope

This policy applies to our website and applications, all services provided through the Platform, and communications via email, SMS and in-app messaging. It covers the personal data of Property Managers (landlords and letting agents), Tenants, Trade Professionals, Legal Service Providers, and other visitors and contacts.

3. Our role: controller and processor

We act as a data controller or a data processor depending on the context:

Where we act as a processor, the customer (for example, the landlord or letting agent) is the controller of that data and is responsible for having a lawful basis to provide it and for giving the relevant individuals (such as tenants) their own privacy information.

4. The personal data we collect

We do not intentionally collect special-category data. Please do not upload health, biometric or other special-category data unless strictly necessary and you have a lawful basis to do so.

5. How we collect your data

• Directly from you — during registration, subscription and use of the Platform.
• From other users — for example, a Property Manager may enter a Tenant's details, or a Tenant may report an issue shared with a Trade Professional.
• Automatically — via cookies, log files and analytics tools.
• From third parties — for example, our payment processor (confirmation of payment), or providers that help us verify information.

6. Why we use your data, and our legal basis

Where we rely on legitimate interests, we have balanced those interests against your rights. You can ask us about this assessment at any time.

7. Sharing of data between users

The Platform connects different users, which necessarily involves sharing some personal data between them. In particular:

• Tenant and Property Manager details may be shared with Trade Professionals — to arrange, quote for, attend or carry out works (for example, property address, access details, contact information and a description of the issue).
• Trade Professional and Legal Service Provider details may be shared with Tenants and other Trade Professionals — to allow discovery, assessment and arranging of services (for example, business name, services, service area, ratings, reviews, verification status and contact details).

When personal data is shared in this way, the receiving user becomes an independent controller of that data and is responsible for using it lawfully and only for the purpose for which it was shared. You must not use data obtained via the Platform for any other purpose, such as unsolicited marketing.

8. Service providers and sub-processors

We use trusted third-party providers to operate the Platform. They act as our sub-processors under written contracts that require them to protect personal data and process it only on our instructions. Our current sub-processors are:

We keep this list up to date as our providers change. We may also share data with regulators, law enforcement or other authorities where required by law or to prevent or detect fraud or crime; with professional advisers (lawyers, accountants, auditors, insurers) under confidentiality; and with a buyer or successor if we sell or reorganise our business, under appropriate safeguards.

We do not sell your personal data.

9. International transfers

Most of your personal data is stored and processed in the United Kingdom or the European Economic Area (the EEA is covered by UK "adequacy"). A limited amount of data is processed by providers in the United States — principally payment data (Stripe), SMS data (Twilio), and certain email-handling. Where we transfer personal data outside the UK to a country without adequacy status, we put an appropriate safeguard in place, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.

You can ask us for details of the safeguards applied to a specific transfer by emailing privacy@lanteno.co.uk.

10. How long we keep your data

We keep personal data only as long as necessary for the purposes in this policy and to meet our legal obligations:

• While you are a customer: we retain your data so you can use the Platform.
• If you leave the subscription service or your account is closed: we give you a limited period (the "Download Window", currently 30 days) to download your own data. During the Download Window your account stays open with limited, read-only access — you can sign in to view, export and download your data, and if you resubscribe within this period your account and data are restored and not deleted. After the Download Window, your operational account data may be permanently and irreversibly deleted.
• If your Property Manager leaves but you (a Tenant) still have a live account: where a Property Manager (landlord or agent) cancels or closes their account, we may retain the tenancy and property records for any tenancy on which a tenant still holds a live LanTeno account, so that tenant can continue to access their own tenancy information. When we do this, we remove or redact the former Property Manager's personal contact details from the retained records, and the rest of that Property Manager's portfolio is deleted in the ordinary way.
• Records we must keep: certain records are retained longer where the law requires or permits — in particular audit logs and financial/tax records, which we retain for a minimum of 7 years — after which they are permanently deleted.
• Ratings and reviews: reviews and ratings you post, and reviews about a Trade Professional or other business, may be retained or anonymised (rather than deleted) when an account is closed, so that ratings remain accurate and cannot be manipulated through account deletion.

A full retention schedule is available on request.

11. How we protect your data

We use appropriate technical and organisational measures, including:

• encryption of data in transit and at rest;
• access controls — staff access is limited to what is necessary, logged, and subject to confidentiality; our support and engineering teams may access your information where reasonably necessary to provide support, fix faults or secure the Platform;
• two-factor authentication and secure password handling (passwords are hashed);
• malware scanning of uploaded files before they are stored; and
• monitoring, logging and regular security reviews.

No system is completely secure, so we cannot guarantee absolute security, but we work to protect your data and to respond quickly to any incident.

12. Your rights

Under UK GDPR you have the right to: access your data; request correction of inaccurate or incomplete data; request erasure; object to or request restriction of processing; request data portability; withdraw consent where we rely on it; and not be subject to solely automated decisions with legal or similarly significant effects.

To exercise any right, email privacy@lanteno.co.uk. We will respond within one month (extendable by two months for complex requests, where we will tell you).

Exceptions to deletion requests. If you ask us to delete your data but we are required to retain some of it (for example for legal obligations, ongoing transactions, or fraud prevention and audit logs), we will restrict processing of that data (archive or anonymise it) until the retention period expires, explain the reason and timeline, and offer restriction instead of full deletion where appropriate. If you are not satisfied, you can complain to the ICO (see section 15).

13. Cookies

We use cookies and similar technologies for essential functionality, security and analytics. Non-essential cookies are used only where permitted. You can manage your preferences via our cookie banner and your browser settings.

14. Data Processing Agreement

Where we act as a processor for a customer (for example, processing tenancy and property data on behalf of a landlord or agent), we commit to: complying with UK GDPR and the Data Protection Act 2018; processing only on the controller's documented instructions; keeping personnel under confidentiality; engaging sub-processors only under equivalent written protections; applying the security measures in section 11; assisting with data-subject rights requests; notifying the controller of any breach without undue delay; using appropriate safeguards for international transfers; and returning or deleting personal data on termination. Our full Data Processing Agreement is available on request at privacy@lanteno.co.uk.

15. Data breaches, complaints and the ICO

If a personal-data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours where required, and inform affected users without undue delay where the risk to them is high.

If you have a concern about how we handle your data, please contact us first at privacy@lanteno.co.uk. You also have the right to complain to the Information Commissioner's Office (ICO) — https://ico.org.uk — helpline 0303 123 1113.

16. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new effective date and, where changes are material, give you reasonable notice. Continued use of the Platform after changes take effect indicates your acceptance of the updated policy.

17. Contact

LanTeno Limited Northgate Business Centre, Newark Upon Trent, Nottinghamshire, NG24 1EZ Email: privacy@lanteno.co.uk