1. Introduction
Aceox Properties ("Aceox", "we", "us", "our") is a property management and lettings company based in Portsmouth, providing residential lettings, tenant finding, and property/block management services across Hampshire, including student HMOs.
We take the privacy and security of personal data seriously. This policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and the rights you have over your data, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This policy applies to landlords, tenants and prospective tenants, contractors and suppliers, and visitors to our website at aceoxproperties.co.uk.
2. Who We Are
Aceox Properties is the "data controller" responsible for your personal data.
- Company name: CARDINAL ACEOX LIMITED
- Company registration number: 16925597
- Registered/trading address: High Hurstwood House, Chillies Lane, High Hurstwood, East Sussex, United Kingdom, TN22 4AD
- Phone: +44 7496 776195
- Website: aceoxproperties.co.uk
3. Personal Data We Collect
The personal data we collect depends on your relationship with us.
From landlords:
- Name, address, date of birth, contact details
- Bank account and payment details, for rent remittance
- Property ownership and mortgage/lender information (where relevant to letting the property)
- National Insurance number or tax details, where required for compliance (e.g. Non-Resident Landlord Scheme)
- Identity verification documents (e.g. passport, driving licence)
From tenants and prospective tenants:
- Name, date of birth, contact details, current and previous addresses
- Proof of identity and immigration/right to rent status (see Section 8)
- Employment and income details, references, and credit history (via referencing checks)
- Bank account and payment details, for rent collection
- Guarantor details, where applicable
- Emergency contact details
- Details of any reasonable adjustments needed (which may include health information, only where you choose to share it)
From contractors and suppliers:
- Contact details, business information, and payment details
From website visitors:
- Contact form submissions (name, email, phone number, message content)
- Technical data such as IP address, browser type, and pages visited (via cookies/analytics — see Section 10)
We collect this data directly from you (forms, email, phone, WhatsApp, in person), from third parties (referencing agencies, credit reference agencies, previous landlords or agents, and letting portals such as Rightmove or SpareRoom where you enquire through them), from publicly available sources (such as the local authority's public register of licensed HMOs and HM Land Registry), and automatically via our website.
4. How We Use Your Data and Our Legal Basis
Arranging and managing tenancies and property management agreements — Performance of a contractReferencing, credit and affordability checks — Performance of a contract / legitimate interestsRight to Rent checks — Legal obligationCollecting and remitting rent, managing arrears — Performance of a contractProtecting deposits with an approved scheme — Legal obligationArranging repairs and maintenance — Performance of a contract / legitimate interestsCompliance with HMO licensing and local authority requirements — Legal obligationResponding to enquiries and providing customer service — Legitimate interestsSending marketing communications (e.g. new listings) — Consent (you can opt out at any time)
Writing to landlords by post about our services, using names and addresses from public registers such as the council's HMO licence register (Legitimate interests: promoting our lettings and management services to property owners. You can ask us to stop at any time and we will add you to our suppression list so you are not contacted again.)Preventing fraud and financial crime — Legal obligation / legitimate interestsImproving our website and services — Legitimate interests
5. Who We Share Your Data With
We share personal data only where necessary, with:
- Referencing and credit reference agencies, to assess tenant suitability and affordability
- Deposit protection scheme providers, to safeguard tenancy deposits as required by law
- Client Money Protection (CMP) scheme provider, where applicable, as required for agents holding client money
- Redress scheme provider (such as The Property Ombudsman or the Property Redress Scheme), where applicable, as required for letting and managing agents.
- Local authorities, for HMO licensing, council tax, and statutory compliance
- The Home Office, where required for Right to Rent checks
- Contractors and tradespeople, to carry out repairs and maintenance you or your landlord have requested
- Professional advisors, such as accountants, solicitors, and insurers
- HMRC, where required (e.g. Non-Resident Landlord Scheme reporting)
- IT and software providers who host our systems and website (e.g. our website platform, CRM, email provider), acting as data processors under contract. WhatsApp (provided by Meta), which we use to communicate with landlords, tenants and applicants who contact us through it. Messages are processed by WhatsApp in line with its own privacy policy, and may be processed outside the UK.
- Law enforcement or regulators, where legally required
We do not sell personal data to third parties.
6. International Transfers
Some of our service providers store or process data outside the UK. For example, WhatsApp (Meta) and some email, website and software providers may process data in the United States or the European Economic Area. Where this happens, we rely on appropriate safeguards, such as UK adequacy regulations (including the UK-US Data Bridge where the provider is certified), the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes it was collected for, including to satisfy legal, accounting, or reporting requirements. As a general guide:
- Tenancy and landlord records are typically retained for 6 years after a tenancy or instruction ends, to meet limitation periods for contractual and tax-related claims.
- Prospective tenant/applicant data that does not result in a tenancy is typically deleted within 12 months, unless you ask us to keep it on file for future opportunities.
- Website enquiry data is retained only as long as needed to respond, unless you become a client.
Where we are no longer required to retain data, it is securely deleted or anonymised.
8. Right to Rent Checks
This data is processed on the basis of legal obligation. In line with Home Office requirements, we keep copies of Right to Rent documents for the duration of the tenancy and for one year after it ends, after which they are securely deleted.
9. Data Security
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse, including secure storage systems, access controls, and staff awareness of data protection obligations. While no system can be guaranteed 100% secure, we review our practices regularly.
10. Cookies and Website Analytics
Our website uses essential cookies that are needed for it to work, and, only with your consent, analytics cookies that help us understand how visitors use the site so we can improve it. We use Google Analytics. When you first visit, a cookie banner lets you accept or reject non-essential cookies, and you can change your choice at any time. You can also control cookies through your browser settings.
11. Your Rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erasure of your data, in certain circumstances
- Restrict processing of your data, in certain circumstances
- Object to processing based on legitimate interests or for direct marketing
- Data portability, to receive your data in a portable format
- Withdraw consent at any time, where processing is based on consent (e.g. marketing)
To exercise any of these rights, contact us using the details in Section 13. We will respond within one month, as required by law.
12. Marketing Communications
Where you have consented to receive marketing (such as new property listings or landlord updates), you can opt out at any time by contacting us or using the unsubscribe link in any email. We will not send marketing communications without a valid legal basis.
13. How to Contact Us
If you have any questions about this policy or wish to exercise your data protection rights, please contact us:
Email: info@aceoxproperties.co.uk
Phone: 07496 776195 | 07496 776232
Address: Port 57 Coworking Studio
57 Albert Road
Portsmouth
PO5 2SF