This Privacy Policy applies between you, the User of this Website, and FRV TECHNOLOGIES LIMITED, trading as tsuro (‘tsuro’), the owner and provider of this Website. tsuro takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
FRV Technologies Limited, trading as tsuro ('tsuro'), operates the tsuro website and services. The tsuro account (' tsuro Account') is the user’s interface for accessing these services.
This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: tsuro.co.uk/terms.
Please read this Privacy Policy carefully.
Definitions and Interpretation
1. In this Privacy Policy, the following definitions are used:
Data: collectively all information that you submit to tsuro via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR: the UK General Data Protection Regulation;
FRV TECHNOLOGIES LIMITED, tsuro, we or us: FRV TECHNOLOGIES LIMITED trading as tsuro (‘tsuro’), a company incorporated in England and Wales with registered number 15330527 whose registered office is at 15 RYE HILL ROA, HARLOW, ESSEX, CM18 7JE;
UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
User or you: any third party that accesses the Website and is not either (i) employed by tsuro and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to tsuro and accessing the Website in connection with the provision of such services; and
Website: the website that you are currently using, www.tsuro.co.uk and/or www.tsuro.app, and any sub-domains of those sites unless expressly excluded by their own terms and conditions.
2. In this Privacy Policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this Privacy Policy.
Scope of this Privacy Policy
3. This Privacy Policy applies only to the actions of tsuro and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, tsuro is the "data controller". This means that tsuro determines the purposes for which, and the manner in which, your Data is processed.
Data Collected
5. We may collect the following Data, which includes personal Data, from you:
a. name;
b. date of birth;
c. gender;
d. job title;
e. profession;
f. contact Information such as email addresses and telephone numbers;
g. demographic information such as postcode, preferences and interests;
h. financial information such as credit / debit card numbers;
i. IP address (automatically collected);
j. web browser type and version (automatically collected);
k. operating system (automatically collected);
l. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
m. all information relating to the property transaction with your law firm;
in each case, in accordance with this Privacy Policy.
How We Collect Data
6. We collect Data in the following ways:
a. data is given to us by you;
b. data is received from other sources; and
c. data is collected automatically.
6.1 f you subscribe to Property Alert Protect, we will collect and use your property-related data to monitor and provide notifications related to your property’s status, as outlined in this policy and our Subscription Terms.
Data That is Given to Us by You
7. tsuro will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
c. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
d. when you enter a competition or promotion through a social media channel;
e. when you make payments to us, through this Website or otherwise;
f. when you elect to receive marketing communications from us;
g. when you use our services;
h. when you use the Home Setup Service, which is provided in partnership with Just Move In. This service is automatically included as part of your tsuro account to assist with change of occupancy notifications and other home-related services. To facilitate this, we will share your contact information with Just Move In. You have the right to opt out of this service at any time before your data is shared by selecting the opt-out option on the Just Move In page during the transaction process or by contacting us at support@tsuro.co.uk, allowing you to control whether or not your contact information is shared with Just Move In;
i. when you use survey services provided in partnership with Arnold and Baldwin. As part of your tsuro account, tsurocollaborates with Arnold and Baldwin to provide property surveys where applicable. To enable this, we will share your contact information with Arnold and Baldwin. You have the right to opt out of this service at any time before your data is shared by selecting the opt-out option during the transaction process or by contacting us at support@tsuro.co.uk. This ensures you can control whether or not your contact information is shared with Arnold and Baldwin.
in each case, in accordance with this Privacy Policy.
Data That is Received From Third Parties
8. tsuro will receive Data about you from the following third parties:
a. The Law Firm or Referrer involved in your transaction;
b. Arnold and Baldwin, a property surveyors that will provide you with a detailed survey of your property where applicable if you do not opt out;
c. Just Move In: In cases where you engage with the Home Setup Service provided by Ethical Introductions Limited (T/A Just Move In), they may provide feedback or updates regarding the service status or completion. This information will be used to ensure the quality of service and to assist with any follow-up actions required as part of your tsuro account.
d. Stripe, our payment provider in order to process all payments made using tusro;
e. Yoti, our Identity and address verification and e-signature provider.
Data That is Collected Automatically
9. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our Use of Data
10. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this Privacy Policy.
11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
12. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
13. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
14. We may use your Data to show you tusro adverts and other content on other websites. If you do not want us to use your data to show you tsuro adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).
Who We Share Data With
15. We may share your Data with the following groups of people for the following reasons:
a. any of our group companies or affiliates - to enhance operational efficiency, maintain consistency, comply with legal requirements, and support business purposes;
b. our employees, agents and/or professional advisors - to obtain advice from professional advisers;
c. third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website and applications runs as expected;
d. third party payment providers who process payments made over the Website - to enable third party payment providers to process user payments and refunds;
e. relevant authorities - to facilitate the detection of crime or the collection of taxes or duties;
in each case, in accordance with this Privacy Policy.
Third-Party Service Providers
To enhance your experience and provide additional services as part of your tsuro account, tsuro collaborates with trusted third-party providers. These partners help deliver specialized services, such as property surveys and home setup assistance. We may share your personal data with these companies for the specific purposes outlined below.
As part of Property Alert Protect, we may integrate with additional third-party providers in the future. Any third-party integrations will adhere to our data-sharing principles, and personal data will only be shared as necessary to support the monitoring service
Below are the third-party providers we currently work with:
Just Move In Home Setup Services: As part of your tsuro account, tsuro collaborates with Ethical Introductions Limited (T/A Just Move In) to offer 'Home Setup Services' at no extra cost. Your contact information will be shared with Just Move In unless you opt out. This service includes change of occupancy notifications and setup of optional home-related services. We will share your contact information with Just Move In, who may contact you via telephone, email, and SMS to arrange your Home Setup. You can opt out of this service during the transaction process or by contacting us at support@tsuro.co.uk before data sharing occurs. Opting out of the Home Setup Service will not impact other aspects of your tsuro account. You can find their privacy policy here.
Arnold and Baldwin: As part of your tsuro account, tsuro collaborates with Arnold and Baldwin, a national firm of property surveyors, to offer property surveys (where applicable to your transaction). Your contact information will automatically be shared with Arnold and Baldwin, who may contact you by telephone, email, and SMS to arrange your survey for this purpose unless you opt out during the transaction process or by contacting support@tsuro.co.uk. Opting out will not affect other aspects of your tsuro account. You can find their privacy policy here.
Yoti Identity Verification: tsurointegrates with Yoti, a secure identity and address verification and electronic signature provider, to facilitate your onboarding and transaction with your solicitor. You can find the Yoti privacy policy here. As part of this integration, we share your personal information with Yoti to verify your identity, address, and e-signature. Your data, including the verification report, will be securely processed and shared with your solicitor in compliance with GDPR standards. You have the right to manage your consent and data handling preferences directly. If you do not wish to proceed with identity verification via Yoti, please contact your solicitor.
Rightmove: tsuro integrates with Rightmove as part of the Property Alert Protect service to monitor property listings that match the property associated with any active subscriptions. This integration enables us to notify you of any updates or changes related to your property on Rightmove. Your personal data may be shared with Rightmove only to the extent necessary to facilitate this monitoring service.
Stripe Payment Processing: tsuro uses Stripe as a secure payment processor to handle subscription payments for the Property Alert Protect service. When you provide your payment details, they are securely stored and processed by Stripe in accordance with their privacy and security standards. tsuro does not store or have access to your complete payment information.
For more information on how Stripe handles and protects your data, please refer to the Stripe Privacy Policy.
tsuro may receive a commission from these third parties for services provided, but this will not affect the price of your service.
Keeping Data Secure
16. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
c. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
d. tsuroregularly reviews its security practices to protect your Data from unauthorized access and ensure compliance with the latest industry standards.
17. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@tsuro.co.uk.
18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
19. Please be advised that Property Alert Protect is intended as a supplementary alert service. We strive to ensure the accuracy and reliability of notifications, but we cannot guarantee uninterrupted or complete alerts due to factors outside our control, including technical issues or data availability from third-party providers.
Data Retention
19. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.
20. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your Rights
21. You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
g. Right to Opt Out of Data Sharing with Third Parties: You have the right to opt out of the Home Setup Service provided through Ethical Introductions Limited (T/A Just Move In) before any data is shared. To exercise this right, please use the opt-out option during the service interaction or contact us at support@tsuro.co.uk. For details on how to exercise your right to opt out of third-party data sharing, please see the 'Third-Party Service Providers' section of this Privacy Policy
h. Right to cancel your Property Alert Protect subscription: This can be done at any time, which will end any ongoing property monitoring and associated notifications.
22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@tsuro.co.uk.
23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to Other Websites
25. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.
Changes of Business Ownership and Control
26. tsuro may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of tsuro. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
27. We may also disclose Data to a prospective purchaser of our business or any part of it.
28. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
29. This Website may place and access certain Cookies on your computer. tsuro uses Cookies to improve your experience of using the Website and to improve our range of services. tsuro has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
30. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
31. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling tsuro to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
32. This Website may place the following Cookies:
Type of Cookie
Purpose
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
Targeting cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
33. You can find a list of Cookies that we use in the Cookies Schedule.
34. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.
35. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
36. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
37. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
General
38. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
39. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
40. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
41. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to This Privacy Policy
42. tsuro reserves the right to change this Privacy Policy as we may deem necessary from time to time or as required by law. Any significant changes, especially those involving new third-party integrations for services like Property Alert Protect, will be communicated to you via email and/or a notice on our website. Please review any updates carefully, as continued use of our services after notification will constitute your acceptance of the revised terms. You may contact tsuro by email at info@tsuro.co.uk.
This Privacy Policy was last updated 12th December, 2024.