Hometrack Data Systems Limited (“Hometrack”, “we” or “us”) is committed to protecting and respecting your privacy.
This policy explains how we use any personal information that you provide to us through our website. Please read it carefully. We may change this policy. We will post any changes on this page, so please check back frequently.
For the purposes of data protection law, the controller is Hometrack Data Systems Limited of The Cooperage, 5 Copper Row, London SE1 2LH. Hometrack is part of the ZPG Limited group of companies, comprising ZPG Limited and its subsidiaries (the “ZPG Companies”).
Our Data Protection Officer is Michelle Riddick. You can contact her at firstname.lastname@example.org or via our postal address below. Please mark the envelope ‘Data Protection Officer’.
Information we collect from you
We may collect and process the following information about you:
Information you provide to us
You may provide us with information in several ways, including by filling in forms on our website or by corresponding with us by phone, email and live chat. This includes information you provide when you register for an account, subscribe to or buy any of our products or services, enter a competition, promotion or survey, provide feedback or report a problem with our website.
This information may include your name, address, email address, phone number, payment details and any other information you provide to us.
Information we collect about you
When you use our website, we automatically collect information about your device, including your IP address, information about your visit (including how you got to our websites) and how you use our services. We may combine this information with other information you have provided to us or which we have received from other sources.
Information we receive from other sources
If you use any of the other websites or services provided by the ZPG Companies, we may receive information about you or your device in relation to that use, including your IP address, information about your visits how you use the services of the ZPG Companies.
We work closely with third parties (for example, business partners, advertising networks, analytics providers and search information providers) and may receive information about you from them. This could include socio-demographic information and information about your likely interests based on your previous web browsing and purchases. We may combine this information with other information you have provided to us or which we collected about you.
How we use your personal information
We use your personal information for the following purposes:
Providing our services to you and fulfilling your requests
- Providing you with the information, products and services you request from us or another ZPG Company.
- Completing any transaction you are undertaking with us or another ZPG Company.
- promotions or competitions that you enter with us or another ZPG Company.
- Allowing you to participate in our interactive features when you choose to do so.
Marketing and advertising
- Providing you and others with information about goods and services that we, other ZPG Companies and selected third parties offer that may interest you or them, which may be based on inferences about your or their likely interests based on your activity on websites operated by ZPG Companies or third parties.
- Customising or enhancing your experience of our services, which may use inferences about your likely interests based on your activity on websites operated by ZPG Companies or third parties.
- Delivering relevant advertising to you on websites operated by ZPG Companies or third parties or in direct communications from us, which may use inferences about your likely interests based on your activity on websites operated by ZPG Companies or third parties.
- Measuring and understanding the effectiveness of advertising we serve to you and others.
Service improvement and account management
- Ensuring that our content is presented in the most effective manner for you and your device.
- Administering our websites and apps and for internal business administration (for example, troubleshooting, data analysis, testing, research, statistical and survey purposes).
- Protecting our interests and those of third parties and as part of our efforts to keep our services safe and secure.
- Managing and operating your account with us.
Legal basis for processing
Our legal basis for processing your personal information for the purposes described above will typically be one of the following:
It is necessary for us to process your personal information to perform a contract to which you are a party, or to take steps at your request prior to you entering into a contract.
You have consented to us using your personal information for this purpose (for example, when you create an account with us, agree to receive marketing emails from us or create an alert). You can withdraw your consent at any time by deleting the information from your account or updating your marketing preferences.
It is in our legitimate interests to use your personal information to operate, improve and promote our services (for example, when we customise your experience of our services or use your information for analytics purposes) and to protect our business. Sometimes, we may process your personal information when it is in the legitimate interests of another company, such as another ZPG Company.
It is necessary for us to use your personal information for us or another ZPG Company to comply with a legal obligation.
Sharing your personal information
We share IT infrastructure with other ZPG Companies, and so we may share your personal information with those ZPG Companies to help store your data efficiently and securely. Other ZPG Companies may access your personal information to help provide you with services that you request from those ZPG Companies (for example, to help you manage your home) and to provide you with relevant recommendations of other ZPG services and products. These recommendations may use inferences about your interests based on your activity on our websites and apps and on other websites and apps operated by other ZPG Companies.
We may also share your personal information with third parties in the following circumstances:
Our service providers: to help us run our business and perform services you request
We may provide your personal information to our business partners, suppliers and subcontractors who provide services to us or where necessary to perform a service that you have requested.
Advertisers and advertising networks: to serve relevant adverts to you and others
We may provide your personal information to our partner advertisers and advertising networks that require that information to select and serve relevant adverts to you and others.
Analytics and search engine providers: to help us improve our services
We may provide information about your visit to analytics and search engine providers to help us improve and optimise our services. We generally only share this information in a form that does not directly identify you.
We may also share your personal information with third parties for the following reasons:
If we sell or buy any business or assets
If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of that business or those assets, along with its professional advisers. If Hometrack (or substantially all of its assets) is acquired, personal information held by it about its users will be one of the transferred assets.
To obtain professional advice
We may disclose your personal information to obtain professional advice (for example, from lawyers or financial advisors).
To comply with a legal obligation
We may disclose your personal information if required to do so by law or in response to a request from law enforcement or another regulatory authority. We may disclose your personal information to enforce our agreements with you or to protect the rights, property or safety of Hometrack, its users or others. This includes sharing personal information with other organisations for fraud prevention purposes.
Storing your personal information
We may transfer, store or process your personal information outside of the European Economic Area (“EEA”). The laws in some countries may not provide as much legal protection for your personal information as in the EEA.
By submitting your personal information, you agree to this transfer, storing or processing. Where we use service providers outside the EEA, we rely on approved data transfer mechanisms (for example, the EU Standard Contractual Clauses and the EU-US Privacy Shield) to ensure that your personal information is adequately safeguarded in the recipient country.
Where you have a password to enable you to access some parts of our websites or apps, you are responsible for keeping that password confidential. You must not share your password with anyone.
Unfortunately, transmission of information over the internet is not completely secure. We will do our best to protect your personal information, but we cannot guarantee its security and any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.
We keep your personal information for as long as is necessary for the purposes for which it is processed. These periods vary depending on the nature of the information and your interactions with us. If you would like to delete your Hometrack account, please contact us using the details below.
Opting out of collection of information by third party advertisers
You have the right to ask us not to process your personal information for marketing purposes. You can do this at any time by updating your email preferences in your Hometrack account or by clicking on the “unsubscribe” link in any marketing email we send you.
Data protection law gives you the right to access your personal information, to object to the use of your personal information for certain purposes, and the right to erase, restrict or receive a machine-readable copy of your personal information. You can access, update and delete your Hometrack account information by logging into your Hometrack account. If you cannot fulfil your request using these tools, please email email@example.com or contact us using the address below.
We will handle your request in accordance with the law. This means there may be legal reasons why we cannot fulfil all requests.
Links to third party websites
Post: Data Protection Officer, Hometrack Data Systems Limited, The Cooperage, 5 Copper Row, London SE1 2LH
We hope that we will be able to resolve any questions or concerns you have. However, you may at any time raise your concern with the UK Information Commissioner at:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Last updated: 26 Sept 2019