Privacy Policy
This policy explains what personal data Tenholm collects, why we hold it, who else can see it, how long we keep it, and what you can ask us to do about it. It is written to be read. Where the law requires a particular form of words we have used it, and everywhere else we have said what we actually do.
1. Definitions
In this policy the following words have the following meanings.
- Personal data
- Any information relating to an identified or identifiable living person.
- Processing
- Anything done with personal data, including collecting it, storing it, looking at it, sharing it and deleting it.
- Controller
- The person who decides why and how personal data is processed, and who is answerable for it.
- Processor
- Someone who processes personal data on a controller's instructions rather than for their own purposes.
- You, your
- The landlord or other individual whose personal data we hold.
- The service
- The Tenholm software, including the landlord application, the tenant portal, the partner portals for accountants and letting agents, and our website.
- Partner
- An accountant, accountancy practice, letting agent or managing agent that a landlord has authorised to access some or all of their account.
- Support session
- A period during which a member of Tenholm staff is signed in to a landlord's account in order to help them. Described in section 8.
- UK GDPR
- The United Kingdom General Data Protection Regulation, read together with the Data Protection Act 2018.
2. Who we are and how to contact us
Tenholm is operated by Joseph Kelieff, a sole trader trading as Tenholm, in the United Kingdom. For the personal data described in this policy, that sole trader is the controller.
We are registered with the Information Commissioner's Office, the United Kingdom's data protection regulator, under registration number C2005660.
For any question about this policy, about the personal data we hold, or to exercise any of the rights in section 16, write to hello@tenholm.co.uk. We aim to reply within five working days, and we will always reply within the one month the law allows for a formal request.
3. Who this policy covers
This policy applies to:
- landlords who hold a Tenholm account;
- accountants and letting agents who hold a partner account;
- tenants who use the tenant portal;
- anyone who contacts us or visits our website.
It does not cover any other website you reach from ours. If you follow a link away from Tenholm, the policy of that site applies instead of this one.
4. The information we collect
4.1 Information you give us
- Account details. Your name, email address, telephone number and, if you give one, your business name.
- Tax details. Your Unique Taxpayer Reference and National Insurance number, where you choose to record them so that your figures can be prepared for Making Tax Digital.
- Property records. Addresses, purchase and value figures, mortgage details, letting type and rent.
- Financial records. Income and expense entries, receipts and other documents you upload.
- Compliance records. Gas, electrical, energy and other certificates, and their expiry dates.
- Tenancy records. Described separately in section 5.
- Anything you write to us. Support tickets, replies and emails.
4.2 Information we collect automatically
- Sign-in records. When you signed in, and from where, so that we can secure your account.
- Technical information. Your internet protocol address, browser type and device type, collected by our hosting and security providers as part of serving the site.
- Activity records. A record of changes made to your account, described in section 10.
4.3 Information we do not collect
We do not ask for and do not want your bank card details. Payments are taken by our payments provider, and card numbers never reach Tenholm's systems.
5. Information about your tenants
When you record a tenancy you provide personal data about someone else: their name, contact details, rent, tenancy dates and, if you record them, right to rent check details.
For that information, you are the controller and we are your processor. You decide what to record and why. We hold it on your behalf and act on your instructions. You are responsible for telling your tenants what you hold about them and why, which is an obligation you have as a landlord whether or not you use Tenholm.
Where a tenant uses the tenant portal, we also hold their sign-in details, and for those we are the controller.
6. How we use your information, and our lawful bases
We must have a lawful basis for everything we do with your personal data. The table sets out each purpose and the basis we rely on.
| What we do | Why | Lawful basis |
|---|---|---|
| Provide the service | Store your records, calculate figures, produce reports | Performance of our contract with you |
| Send reminders | Certificate expiry, mortgage deals ending, rent not recorded | Performance of our contract with you |
| Prepare and, where you ask, submit figures to HMRC | Making Tax Digital for Income Tax | Performance of our contract, and compliance with a legal obligation |
| Take payment | Subscriptions and billing | Performance of our contract with you |
| Answer support requests | Help you use the service and fix problems | Performance of our contract, and our legitimate interest in supporting our customers |
| Look at your account to help you | Diagnose a problem you have reported (section 8) | Our legitimate interest in providing support, subject to the permission you control |
| Keep an activity log | Accountability, security, and answering "who changed this" | Our legitimate interest in operating a secure and auditable service |
| Share with your accountant or agent | So they can do the work you have engaged them for (section 9) | Your consent, given and withdrawn in the service |
| Keep records after you leave | Tax and accounting obligations | Compliance with a legal obligation |
| Protect the service | Prevent fraud, abuse and unauthorised access | Our legitimate interest in keeping the service secure |
Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights and freedoms, and concluded that it is not. You can object to any processing based on legitimate interests: see section 16.
7. Reading receipts with AI
If you upload a receipt, you can ask Tenholm to read it for you. The image is sent to a third party artificial intelligence provider, which returns the merchant, date, amount and a suggested category. You confirm or correct the result before anything is saved.
- The feature runs only when you choose to use it. Uploading a receipt does not send it anywhere on its own.
- We have contracted so that images sent for this purpose are not used to train the provider's models.
- The suggestion is a starting point, not advice. You remain responsible for the figures on your return.
- If you would rather not use it, enter the details by hand. Nothing else in the service depends on it.
8. Access by Tenholm staff
To answer a support question we sometimes need to see what you see. This section explains exactly what that means, because you are entitled to know it before it happens rather than afterwards.
8.1 What our staff can do
- View your account. A member of our support team can open your records to understand a problem you have raised.
- Sign in as you. Where a problem cannot be understood any other way, an administrator can start a support session and see the service exactly as you see it.
8.2 You decide whether we can
There is a switch in your settings, under Privacy and support, that turns staff access off. When it is off we cannot open your records and cannot sign in as you, and any session already running ends immediately. You can turn it off at any time and for any reason, and you do not have to tell us why.
It is on by default, because a support desk that cannot see anything cannot help with much. With it off we can still see how your account is doing in general terms, answer your support tickets and reply to your messages.
8.3 What happens during a support session
- A member of staff must record a written reason before it starts.
- The session ends automatically after thirty minutes and cannot be extended.
- A banner appears at the top of every page for as long as it lasts, so you can see it happening whether or not you are online at the time.
- Submitting figures to HMRC and any change to your billing are blocked throughout.
- Everything done is recorded against the staff member, not against you, in the log described in section 10.
8.4 Who can do it
Viewing an account is available to our support team. Signing in as a customer is restricted to administrators, and is deliberately narrower.
8.5 What we do not do
We do not read your records for curiosity, for marketing, or to build any profile of you. We do not sell access to anyone.
8.6 One limitation we want you to know about
During a support session we block filing and billing, as described above. We are not currently able to block a change to your password or email address by the same means. We do not make such changes, and any attempt would appear in your activity log, but we would rather tell you the limit of the control than imply it covers more than it does.
9. Access by your accountant or letting agent
You can give an accountant or a letting agent access to your account. Nobody gets access unless you have granted it.
9.1 Accountants
An accountant you authorise can see your whole account, including properties, transactions and the tax details you have recorded, so that they can prepare your return. An accountant cannot change anything.
9.2 Letting agents
A letting agent sees only the properties you name, not your portfolio. You decide separately whether they may record anything, such as rent received or a new certificate, or whether they may only look. An agent can never delete a transaction.
9.3 If a partner invited you to Tenholm
An accountant or agent may invite you to join Tenholm. An invitation gives them nothing. When you first sign in we ask whether that firm may access your account, and they see nothing at all unless and until you say yes.
9.4 Withdrawing access
You can withdraw a partner's access at any time in your settings, without telling them and without telling us. It takes effect immediately. Anything they recorded while they had access remains in your records, because it is part of your history.
A partner is a separate controller for the information they take out of Tenholm and hold in their own systems. What they do with it after that is governed by their own privacy policy and their engagement with you.
10. Your account activity log
We keep a record of every change made to your account: what changed, when, and who did it, whether that was you, a partner you authorised, a member of our staff, or an automatic process.
- You can run and download this log at any time from your settings, under Privacy and support.
- It records which fields changed, not the values. It says that a rent figure was changed, not what it was changed from.
- Actions taken by our staff during a support session are recorded against that staff member, not against you.
- Entries cannot be edited or removed by anyone, including us. That is the point of keeping it.
11. Who else we share information with
We do not sell your personal data, and we never will. We share it only in the following circumstances.
- Partners you have authorised. As described in section 9.
- HM Revenue and Customs. Only the figures you review and choose to submit.
- Service providers acting on our instructions. By category: cloud hosting and database services; a payments provider; an email delivery provider; an artificial intelligence provider for the feature in section 7; and error monitoring. Each is bound by contract to process personal data only as we instruct. We will give you the current list of named providers on request.
- Professional advisers. Our accountants and lawyers, where they need it to advise us.
- Where the law requires it. In response to a valid legal obligation, court order or regulatory request.
- If the business is sold or transferred. To the buyer, who would be bound by this policy until they lawfully changed it, and we would tell you before that happened.
12. Marketing
We send you emails about your account, such as reminders and replies to your support tickets, because they are part of the service you have asked for. You can change which reminders you receive in your settings.
We will only send you marketing email if you have asked for it, and every such email carries a one click unsubscribe. Unsubscribing from marketing does not stop the emails you need in order to use the service.
13. Where your information is held
Your records and documents are stored in the United Kingdom.
Some of our service providers operate outside the United Kingdom. Where personal data is transferred outside the UK, we rely on an adequacy decision by the UK government, or on the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses, together with any additional measures the transfer requires. You can ask us for details of the safeguards that apply to a particular transfer.
14. How long we keep information
| What | How long | Why |
|---|---|---|
| Your account and records | While your account is open | To provide the service |
| Financial and tax records after you close your account | Five years after the 31 January following the relevant tax year | The period HMRC requires records to be kept |
| Support tickets and correspondence | Three years | To handle any follow up or dispute |
| Account activity log | While your account is open, then six years | Accountability, and any claim arising from it |
| Records of staff access to your account | Six years | Accountability |
When a retention period ends we delete the personal data or anonymise it so that it no longer identifies anyone.
15. How we protect information
- All data is encrypted in transit and at rest.
- Database level rules isolate each customer's data, so that one customer's account cannot return another customer's records. This isolation is tested independently and the results are documented.
- Access by our staff is limited by role, recorded, and controlled by you as described in section 8.
- Documents are stored privately and reached only through short lived links that expire.
- Payment card details never reach our systems.
No system is perfectly secure. If a personal data breach ever put your rights at risk, we will tell you and the Information Commissioner's Office within the time the UK GDPR requires.
16. Your rights
Under the UK GDPR you have the following rights, free of charge.
- To be informed. To know what we do with your personal data, which is what this policy is for.
- Of access. To get a copy of the personal data we hold about you.
- To rectification. To have inaccurate data corrected. Most of it you can correct yourself in the service.
- To erasure. To have your data deleted, except where we must keep it to meet a legal obligation such as the tax record keeping in section 14.
- To restrict processing. To ask us to stop using your data while a question about it is resolved.
- To data portability. To receive your data in a common, machine readable format. You can export your records at any time without asking us.
- To object. To object to processing based on legitimate interests, and to object to direct marketing at any time.
- Not to be subject to automated decision making. We do not make decisions about you by automated means that produce legal or similarly significant effects.
- To withdraw consent. Where we rely on consent, such as partner access under section 9, to withdraw it at any time without affecting anything done before you did.
To exercise any of these, write to hello@tenholm.co.uk. We may ask you to confirm your identity before we act, so that we do not give your data to somebody else.
17. Cookies and similar technologies
We use only what the service needs to work: a cookie that keeps you signed in, and local storage that remembers your preferences. These are strictly necessary, so they do not require your consent.
We do not use advertising cookies and we do not allow third parties to track you across other websites through Tenholm.
18. Changes to this policy
We may update this policy as the service changes or the law does. The date at the top always shows the current version.
If a change materially affects how we use your personal data, we will tell you by email at least thirty days before it takes effect, so that you have time to consider it and, if you wish, to close your account.
19. How to complain
If you are unhappy with how we have handled your personal data, please tell us first at hello@tenholm.co.uk so that we have the chance to put it right.
You also have the right to complain to the Information Commissioner's Office, the United Kingdom's data protection regulator, at ico.org.uk, or by telephone on 0303 123 1113. You do not have to come to us first, but we would rather you did.