Welcome to Homeppl's Privacy Policy
Last updated on 29 May 2025
Privacy Policy overview
We take privacy seriously and want to make it easy for you to understand what we do with your data.
This Privacy Policy explains what personal information is collected by us, Thirdfort Limited (which owns the Homeppl brand), a company registered in England and Wales with number 10757456 and registered office at Belle House, Platform 1 Victoria Station, London, England SW1V 1JT (“Homeppl”, “we”, “us”, “our”), as part of our activities, and how we use that information.
If you have any questions or comments about this Privacy Policy, or if you would like to exercise your data protection rights, please don’t hesitate to contact us:
by email at privacy@thirdfort.com or
by writing to us at c/o DPO, Belle House, Platform 1 Victoria Station, London, England SW1V 1JT.
Definitions in this Privacy Policy:
“Agreement” means an agreement between Homeppl and a Homeppl Client for the provision of Homeppl Services.
“Consumer” means an individual using the Homeppl Portal.
“Data Protection Laws” means the relevant data protection and privacy legislation, regulation and guidance applicable from time to time including the Data Protection Act 2018, UK GDPR and EU GDPR.
“EU GDPR” means the General Data Protection Regulation ((EU) 2016/679).
"Homeppl Client" means a client of Homeppl which has purchased Homeppl Services.
“Homeppl Client Account” means an account created by a Homeppl Client (or created by Homeppl for the benefit of the Homeppl Client) to enable the Homeppl Client to use Homeppl Services.
“Homeppl Portal” means Homeppl’s web platform that may be accessed by Homeppl Clients at https://crm.homeppl.com/ and Consumers at https://www.application.homeppl.com/otl, or such other URLs as Homeppl may from time to time designate. The Homeppl Portal enables Consumers to:
(i) upload and share personal ID, financial and other information; and
(ii) use and benefit from such additional features and functionality that may from time to time be made available by Homeppl.
“Homeppl Services” means the services made available by Homeppl via the HomepplPortal to enable Homeppl Clients to:
(i) request and obtain ID verification reports;
(ii) request information for Know Your Client (KYC) and Anti Money Laundering (AML) purposes; and
(iii) benefit from such additional services that may from time be made available by Homeppl.
“Homeppl Website” means Homeppl’s website at https://www.homeppl.com, or such other URLs as Homeppl may from time to time designate.
“Personal Information” means information relating to an identified or identifiable individual, including all information that is considered to be “personal data” under Data Protection Laws.
“UK GDPR” has the meaning given to it in the Data Protection Act 2018.
Privacy Policy structure
To make it easier for you to review those parts of the Privacy Policy which apply to you, we have divided it up into the following sections:
Section 1 – General: This Section 1 applies to everyone who may visit the Homeppl Website, use the HomepplPortal or otherwise interact with us.
Section 2 – Consumer: In addition to Section 1, this Section 2 also applies if you are an individual who is using the Homeppl Portal to carry out the verification requested by your letting agent.
Section 3 – Homeppl Clients: In addition to Section 1, this Section 3 also applies if you are a letting agent making use of the Homeppl Services.
Accessing Homeppl via a partner platform
If you are a Homeppl Client accessing our Services via one of our third party partners e.g. Flatfair Limited or Yardi Systems Limited (“Homeppl Partners”), then the personal information that you provide in the course of accessing or using our services will also be subject to that partner’s privacy policy, in addition to this one.
Section 1: General
This section applies to everyone who visits or interacts with the Homeppl Website or the Homeppl Portal.
Personal Information we collect
When you visit the Homeppl Website, email us, contact our Support team, or interact with us in general terms, we may collect:
your name
your email address
your phone number
any additional personal information you share with us
We process this Personal Information:
to respond to your enquiries
to provide you with information about Homeppl Services
to make our site better and make sure it is presented in the most effective way
to manage risk or prevent other illegal or prohibited activities
to resolve issues or fix problems on the Homeppl Website or the Homeppl Portal
for internal operations, analysis, testing and research and to generally improve the services we provide
In all cases, where data is provided for us to provide Homeppl Services, we are a processor of that data and the Homeppl Client is the controller.
Legal basis for processing Personal Information
Our legal basis for collecting and using Personal Information will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect Personal Information from you only where:
the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms;
we have your consent to do so; or
we need the Personal Information to perform a contract with you.
In some cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).
Who do we share your Personal Information with?
We will never sell your Personal Information. We may disclose your Personal Information to the following categories of recipients:
1. Our third party service providers who provide services to us, for example, to:
support the delivery of, provide functionality on, or help to enhance the security of the Homeppl Website or the Homeppl Portal, or
process Personal Information for content customisation, personalisation, ad selection and delivery, reporting, and measurement purposes. This may also include our data analytics providers and cloud-based data processing and hosting providers. If we share this Personal Information with these parties, we will only do so insofar as it is reasonably necessary for the purpose(s) for which we have collected it.
Our third party service providers, as well as details about what types of information we share with them are listed in Schedule 1.
2. Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person;
3. An actual or potential buyer of our business (and their agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer they must use your Personal Information only for the purposes disclosed in this Privacy Policy;
4. Other relevant parties in order to enforce or defend our rights under an Agreement, or to protect the rights, property, or safety of Homeppl, Homeppl Clients, Consumers, or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.
How do we keep your Personal Information secure?
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the use of the Homeppl Website or the Homeppl Portal, taking into account the likelihood and severity those risks might pose to your rights and freedoms.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the Personal Information transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of the Homeppl Website and the Homeppl Portal and your Personal Information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your Personal Information with us, you accept this and provide your information at your own risk.
Further information regarding our security can be found here.
Your data protection rights
You have the right to:
withdraw your consent to our processing of your Personal Information.
be told what Personal Information we hold about you on our database and how we process that data.
request that we provide you with a copy (in a commonly used electronic format) of all the Personal Information that we hold about you. Unless you make repeated requests which are manifestly unfounded or excessive, we will not charge a fee for providing you with a copy of this data.
request that we correct any inaccurate or incomplete Personal Information that we hold about you.
request that we irretrievably delete all Personal Information that we hold about you (the so-called “right to be forgotten”). Please note that there are limited circumstances in which we are legally entitled to refuse to comply with this request.
request that we transmit all the Personal Information that we hold about you (in a structured, commonly used and machine-readable form) to another organisation’s IT environment. Note that we are only legally obliged to comply with this request if it is technically feasible for us to do so.
opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or by replying to any marketing text messages with the word “STOP”.
complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact the UK Information Commissioner’s Office at: https://ico.org.uk/concerns.
You can exercise any of the rights in 1–7 above at any time by contacting us using our details set out at the beginning of this Privacy Policy.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with Data Protection Laws.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments, so please review it frequently. If we update our Privacy Policy and the amendments involve a material change to the way we collect, use, share, store or otherwise process your Personal Information then we will take appropriate measures to inform you, consistent with the significance of the changes we make.
Further queries in relation to your data protection rights
You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/your-data-matters.
Where we process personal data concerning those in the European Union, we have appointed IT Governance Europe Limited to act as our EU GDPR Representative. If you wish to exercise your rights under GDPR, or have any queries in relation to your rights or privacy matters generally, please:
email our representative at eurep@itgovernance.eu; or
post your request or query to: EU Representative, IT Governance Europe, Third Floor, The Boyne Tower, Bull Ring, Lagavooren, Drogheda, Co. Louth, A92 F682
When contacting our representative please ensure you include our company name (Thirdfort Limited) in any correspondence.
Section 2: Consumers
This section describes what information is collected by Homeppl from Consumers, how that information is used by Homeppl, and for how long Homeppl keeps the information. You are a Consumer if you have been invited to provide Personal Information to Homeppl so that we can carry out verifications on you for the benefit of the Homeppl Client (i.e. letting agent you engaged), and this section will apply to you.
What Personal Information do we collect from Consumers?
When you share information with us in the Homeppl Portal we will ask you to provide some or all of the following Personal Information, depending on the type of request that the Homeppl Client has made:
your full name
your email address
your address history
your telephone number(s)
your date of birth
your IP address
employment information (e.g. employer, occupation, how long you have worked there)
photographic proof of identity (e.g. passport, driving licence, identity card)
biometric data (e.g. photo)
financial personal details (e.g. bank details, transaction details, account balance information)
What do we do with the Personal Information that we collect from Consumers?
We will process the information that we have collected for the following purposes:
to enable you to use the Homeppl Portal to fulfil a request made by a Homeppl Client.
to perform our contract with Homeppl Clients for the provision of ID verification, Know Your Client (KYC) and Anti-Money Laundering (AML) checks.
to conduct source of funds checks using open banking data technology to access and analyse your financial and banking information.
to cross reference your banking information and salary payments with your employer and employment history.
to respond to your enquiries and provide assistance.
Who do we share Consumers’ Personal Information with?
Your professional advisor
We will share your Personal Information with the Homeppl Client(s) you have engaged.
Our partners
If the Homeppl Client has purchased Homeppl Services via Homeppl Partners, then we may share your Personal Information with that Homeppl Partner to the extent reasonably necessary in order for us to provide the Homeppl Services.
Third party service providers
We may also share your Personal Information with third party service providers, such as external open banking data aggregators, credit reference and reporting providers, to enable us to provide Homeppl Services (including but not necessarily limited to identity verification checks and source of funds checks).
Where we share your Personal Information with third parties, we will only do so as far as it is reasonably necessary for the purposes described in this Privacy Policy. Our third party service providers, as well as details about what types of information we share with them, are listed in Schedule 1.
The third party service providers may check your Personal Information against databases that they have access to in order to verify your identity, and may also keep a record of the search. Where the third party service provider is Onfido Limited, then Onfido’s collection and use of your Personal Information for identity verification purposes is described in the Onfido Privacy Policy which can be accessed at https://onfido.com/privacy/.
Note that where we share your Personal Information with a credit reference agency for the purpose of carrying out an identity or credit check, the credit reference agency may keep a record of the search being made but this should not impact your credit score.
Transfers outside the United Kingdom
Our servers, with Amazon Web Services, are located in Ireland and the Personal Information that we collect directly from you will be stored on these servers.
We may also transfer your Personal Information to one or more of our third party service providers listed in Schedule 1, some of which may be located outside of the UK or EEA, appoint subprocessors outside the UK or EEA, or operate from multiple locations (including non-EU locations). If the Homeppl Client is located outside the UK or EEA then we may also transfer your Personal Information to them.
We take all steps reasonably necessary to ensure your Personal Information is processed securely and in line with this Privacy Policy as well as the Data Protection Legislation. We will only transfer your Personal Information to third parties outside the UK if:
it is located in a country confirmed by the UK government to provide adequate protection to personal data;
a contract is in place to protect the personal data as required under Data Protection Legislation. This may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses; or
we have another legal basis for doing so.
How long do we keep Consumers’ Personal Information?
We will store your Personal Information only for the period of time that is necessary to conduct the relevant checks and provide Homeppl Services to the Homeppl Client in line with our contract with them. We endeavour to remove the personal data shared with us directly in its native form as soon as the relevant checks have been performed.
Upon request by a Homeppl Client or when we or any of our third party service providers no longer need to process the Personal Information, we will cease to process it and it will be deleted, unless retention is required by applicable law.
Section 3: Homeppl Clients
This section describes what information is collected by Homeppl from Homeppl Clients, how that information is used by Homeppl, and for how long Homeppl retains the information. You are a Client if you use Homeppl Services to carry out verifications on your clients, and this section will apply to you.
What Personal Information do we collect from Homeppl Clients?
During the client onboarding process we will collect the following Personal Information:
names and contact details of your personnel who will be using Homeppl Services
usernames and passwords
We will also collect Personal Information that you provide to us in connection with Homeppl Services:
your client’s name
mobile phone number
postal address of the property
email address
What do we do with the Personal Information that we collect from Homeppl Clients?
We will use the information that you provide during the onboarding process for the following purposes:
to create and maintain your Homeppl Client Account
to provide Homeppl Services and otherwise perform the Agreement with you
to respond to your enquiries and provide assistance
If you provide us with Personal Information relating to your client in connection with Homeppl Services, we will use the Personal Information you provide for the purpose of providing the Homeppl Services in accordance with our Agreement.
Who do we share Homeppl Clients’ Personal Information with?
The third party service providers that we engage for the purposes of collecting, exporting, storing and otherwise processing our data, including your Personal Information, are listed in Schedule 1.
How long do we keep your Personal Information?
As stated above, we keep your Personal Information for as long as you have a contract with us or as we reasonably need it to fulfil the purposes for which the data was collected.
