App Privacy Policy
PRIVACY POLICY
6 - Personal Data
Mandatory data; your email address is the only personal data required for the operation of the app, and is limited to the initial account set up and verification, and linking to the relevant property and in-home technology, in accordance with your tenancy agreement.
Broadford Life is committed to full compliance with applicable UK data protection law, including the UK GDPR and the Data (Use and Access) Act 2025, and keeps its data protection practices under regular review.
The BL App provides access to an external communication link, with the Property Manager. Any subsequent information shared via this route / with the Property Manager will be subject to the Property Manager’s own GDPR and privacy policy, and is not the responsibility of Broadford Limited.
The business will only collect the information needed so that it can provide you with the services it provides; Broadford Life does not sell or broker your personal data.
7 - Legal basis for processing any personal data
We process your personal data on the following lawful bases:
Performance of a contract: we process your email address and account credentials to create and verify your account and grant you authorised access to the BL App. This processing is necessary to deliver the App service to you as a Resident (pursuant to your tenancy agreement) or as an Installer (pursuant to the relevant installation engagement). Without this data, we cannot provide the App service.
Legitimate interests: we process technology event data (including account identifiers, operational signals, energy management data, alarm triggers, device health and audit logs) on the basis of our legitimate interests in operating, securing and maintaining the App and connected smart home hardware. We have assessed that these interests are proportionate and not overridden by your rights and freedoms, given the limited scope of the data involved and the direct operational benefit to you as an App user.
Legal obligation: we may process personal data where required to do so by law or by a regulatory obligation applicable to us.
Where we rely on legitimate interests as the basis for processing, you have the right to object to that processing. Please see Section 13 for a full description of your data subject rights.
Broadford Life shares your personal data with the categories of third party identified in this Privacy Policy only where necessary to provide the App service, to fulfil its legitimate interests, or where required by law. Third parties are not permitted to use your personal data for purposes other than those specified by Broadford Life. Broadford Life does not sell, rent or otherwise transfer personal data for commercial gain.
8 - Legitimate interests pursued by the business
Broadford Life has identified the following legitimate interests in processing personal data in connection with the App: (i) verifying and managing authorised access by Residents (linked to valid tenancy agreements) and Installers (linked to specific commissioning engagements), to protect the security of the App and connected hardware; (ii) operating and maintaining the smart home technology functionality delivered through the App, including monitoring device health and connectivity; (iii) ensuring the security of the App and connected systems, detecting and preventing fraud, misuse or unauthorised access; and (iv) maintaining accurate audit and operational records for compliance and dispute resolution purposes. In each case, Broadford Life has assessed that these interests are not overridden by your rights and interests, given the limited scope and nature of the data processed and the direct operational benefit to you of a secure and functional App.
9 – Your Agreement
This Privacy Policy sets out how and why Broadford Life processes your personal data in connection with the BL App. Most processing described in this Privacy Policy is carried out on the basis of contract or legitimate interests – it does not require your separate consent. If you believe we are processing your data unlawfully or wish to exercise your data subject rights, please refer to Section 13 or contact us using the details in Section 3. The lawful basis for any processing will not change without prior notification to you.
10 – Disclosure
Broadford Life will keep your personal data safe and secure. The following categories of third party may receive or access personal data in connection with the App: (i) the Property Manager, who requires access to your contact details to manage your tenancy account and facilitate your use of the App; (ii) Cloud and Hosting Suppliers, who process data as part of the App’s technical infrastructure under data processing agreements with Broadford Life; and (iii) where applicable, Installers, who have temporary, limited access during the commissioning of smart home technology only.
The Broadford Life team will not have active access to any of your data during your tenancy. Some of the services used to support the business such as technology management, cloud storage or account identifiers are outsourced from third-party suppliers. Broadford Life will always put in place with these third-party suppliers a processing agreement and will only share personal information with them where required to meet your requirements or to support our legitimate interests or contractual obligations.
In certain circumstances the business may need to disclose your Personal Information to meet legal, regulatory or valid governmental requests. Broadford Life may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
11 - Retention Policy
Broadford Life retains personal data only for as long as necessary for the purposes described in this Privacy Policy. Resident data (including email address and account identifiers) is retained for the duration of the tenancy and deleted within 30 days of the tenancy ending, subject to any longer retention required by law or for the resolution of disputes or legal claims. Installer data is deleted promptly following confirmed completion of the relevant commissioning engagement. Technology event data and audit logs may be retained for up to six years where required for security, legal compliance or dispute resolution purposes. If we are required to retain your data beyond the applicable period due to a legal obligation, we will inform you where required by law.
12 - Data Storage
Data is predominantly processed within the UK or EU, using Cloudflare. For your protection Cloudflare and Broadford have signed Standard Contractual Clauses to allow data transfers and ensure security standards.
13 - Your rights as a data subject
At any point whilst Broadford Life is in possession of or processing your personal data, all data subjects have the following rights:
• Right to information - you can ask for information about what data is being processed and the rationale for such processing.
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Broadford Life refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, Broadford Life can confirm what information it holds about you and how it is processed.
14 - You can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• 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 Broadford Life and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, restrict, object to processing and rights to erasure.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• 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 you 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.
16 - Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Broadford Life you have the right to complain to us. If you do not get a response within 30 days you can complain to the ICO.
The details for each of these contacts are:
Broadford Limited
Attention: The Data Protection Administrator
34 & 36 Queen Anne Street, London W1G 8HE
Email: info@broadfordlife.com
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113 or email: Contact us | ICO