UNLEASE Privacy Policy

This Privacy Policy explains how UNLEASE collects, uses, shares and protects personal information when you use our website, create an account, complete a Diagnosis or tool, upload documents, receive reports or guidance, subscribe to communications, request an introduction or otherwise interact with UNLEASE.

It also explains how we use cookies and similar technologies. We do not maintain a separate Cookie Policy.

1. ABOUT UNLEASE AND THIS POLICY

1.1 UNLEASE is the trading name of:

UNLEASE LTD

registered in England and Wales under company number:

17539642

with registered office at:

124 City Road, London, United Kingdom, EC1V 2NX

1.2 UNLEASE LTD is the controller responsible for the personal information described in this Privacy Policy, except where another organisation is separately responsible for its own processing.

1.3 References to "UNLEASE", "we", "us" or "our" mean UNLEASE LTD.

1.4 This Policy applies to personal information processed through or in connection with the UNLEASE website, account portal, Leasehold Diagnosis, property profiles, tools, questionnaires, uploaded documents, reports, communications, third-party introductions and related Services.

1.5 Our Services are intended for people aged 18 or over.

1.6 Questions about this Policy or our use of personal information can be sent to:

team@unlease.co.uk

1.7 This Privacy Policy should be read alongside our Terms and Conditions and any additional privacy information we provide when collecting particular information.

2. INFORMATION WE COLLECT AND WHERE IT COMES FROM

2.1 The information we collect depends on how you use UNLEASE and may include:

• (a) account information, such as your name, email address, account identifiers and authentication information;

• (b) property and leasehold information, including information about a property or development, lease, ownership or occupancy, management arrangements, service charges, works, insurance, disputes, transactions and other leasehold-related circumstances;

• (c) Diagnosis and tool information, including answers, property-profile information, free-text responses, submissions, findings, scores, reports and suggested next steps;

• (d) documents, such as leases, service-charge information, accounts, invoices, notices, correspondence, insurance information, building information, professional reports and other documents you choose to provide;

• (e) communications, including enquiries, feedback, complaints, support requests and correspondence with us;

• (f) marketing information, including your email address, preferences, consent and unsubscribe records; and

• (g) technical and usage information, such as IP address, browser and device information, pages and features used, dates and times of access, session information, cookie or similar identifiers, analytics information and security or diagnostic logs.

2.2 We normally obtain information directly from you when you register, complete a form, use a tool, upload a document, contact us or use the Services.

2.3 We may also receive information from:

• (a) another UNLEASE user;

• (b) a person acting on your behalf;

• (c) documents supplied to us;

• (d) an independent provider involved in an introduction;

• (e) our technology and communications providers;

• (f) information generated through use of the Services; and

• (g) publicly available sources where appropriate.

Information about other people

2.4 Information and documents submitted to UNLEASE may contain personal information about other people, such as leaseholders, freeholders, landlords, managing-agent personnel, RMC or RTM directors, contractors or professional advisers.

2.5 We normally receive this information from an UNLEASE user or from a document that a user provides. It may include names, contact or professional details, property-related information, correspondence and other information relevant to the leasehold matter submitted to us.

2.6 We may process this information where reasonably necessary and lawful to understand, assess or deal with the matter submitted to UNLEASE.

2.7 Users should avoid providing unnecessary personal information about other people.

Sensitive information

2.8 UNLEASE does not ordinarily ask users to provide special category personal information, such as information about health, racial or ethnic origin, religion, political opinions, trade-union membership, sexual orientation, sex life, genetic information or biometric information used for identification.

2.9 Such information may occasionally appear in documents or correspondence supplied to us. Please avoid providing particularly sensitive information unless it is genuinely necessary and relevant.

2.10 If we receive special category information, we will only use or retain it where permitted by law. We may disregard, restrict, redact or delete information that is unnecessary for the relevant purpose. If we need intentionally to process special category information for a Service, we may provide additional information or obtain any additional permission required by law.

3. HOW AND WHY WE USE INFORMATION

3.1 We use personal information only where we have an appropriate legal basis.

3.2 Our legitimate interests include operating, protecting and improving UNLEASE; understanding how the Services are used; developing our business and Services; maintaining appropriate records; preventing fraud and misuse; protecting our intellectual property and commercial interests; dealing with disputes; obtaining professional advice; and establishing or defending legal rights.

3.3 Where required, we consider whether those interests are outweighed by your rights and interests.

3.4 You are not generally required by law to provide personal information to UNLEASE. However, if you do not provide information reasonably required for a Service, we may be unable to create or maintain your account, meaningfully assess a submission, provide a report or otherwise provide the requested functionality.

4. MARKETING COMMUNICATIONS

4.1 We may send you necessary account, security, legal and Service-related communications. These are not necessarily marketing and may continue even if you opt out of marketing.

4.2 Where you have consented, we may send occasional emails containing:

• (a) leasehold news;

• (b) reform updates;

• (c) practical guidance;

• (d) useful resources;

• (e) UNLEASE news; and

• (f) information about UNLEASE features and Services.

4.3 You may consent through an optional registration checkbox or by actively subscribing through the UNLEASE website.

4.4 You may unsubscribe at any time using the link in a marketing email or by contacting us.

4.5 Withdrawing consent does not affect processing that was lawful before withdrawal.

4.6 If you unsubscribe, we may retain limited information on a suppression list so that we can continue to respect your preference and avoid inadvertently sending further marketing.

5. ANALYSIS, AUTOMATION AND ANONYMISED INFORMATION

5.1 Some UNLEASE features automatically analyse information supplied by users. For example, the Leasehold Diagnosis may use predefined rules or scoring processes to interpret answers and generate scores, findings or suggested areas of attention.

5.2 These features provide information and guidance. UNLEASE does not currently use them to make solely automated decisions that determine your legal rights or otherwise produce legal or similarly significant effects on you.

5.3 We may use technology and analytical tools to assist the operation, assessment and improvement of the Services, provided our handling of personal information remains lawful and consistent with this Policy.

Anonymised and aggregated information

5.4 We may create statistical, aggregated, de-identified or anonymised information from information available to us.

5.5 We may use genuinely anonymised information for purposes including:

• (a) analytics and research;

• (b) understanding leasehold issues and trends;

• (c) benchmarking;

• (d) improving UNLEASE;

• (e) developing new products and Services;

• (f) creating datasets, statistics and commercial insights;

• (g) business planning; and

• (h) other lawful research, statistical or commercial purposes.

5.6 Where information has been genuinely anonymised so that an individual is no longer identifiable, it is no longer personal information under UK data-protection law. We may use, combine, disclose and retain such information on an ongoing basis.

6. WHO WE SHARE INFORMATION WITH

6.1 We may share personal information where reasonably necessary with:

• (a) technology and operational providers supporting hosting, databases, authentication, storage, communications, analytics, security, monitoring and other platform functions;

• (b) professional advisers, including lawyers, accountants, insurers, auditors, consultants and cybersecurity specialists;

• (c) independent providers where you ask or agree for UNLEASE to make an introduction;

• (d) regulators, courts, law-enforcement authorities and public bodies where required or permitted by law; and

• (e) investors, purchasers, lenders and advisers where reasonably necessary in connection with financing, investment, restructuring, a merger, acquisition or sale of all or part of UNLEASE, subject to appropriate protections where required.

6.2 We use technology providers to help us operate UNLEASE and provide the Services. Depending on how you use UNLEASE, these providers may process personal information on our behalf:

• Cloudflare, which helps deliver, host and protect our website and application;
• Supabase, which provides account authentication, database and document storage services;
• Resend, which helps us send account, service and other emails;
• MailerLite, which helps us manage and send our subscribed newsletter;
• PostHog, which helps us understand how our website and Services are used;
• Google Analytics, which helps us understand how our website and Services are used; and
• Sentry, which helps us monitor and investigate technical errors.

The providers used, and the information shared with them, depend on the Services you use and our operational requirements.

6.3 We may appoint, replace or stop using service providers as UNLEASE develops. We do not undertake to use a particular supplier indefinitely.

Third-party introductions

6.4 We do not ordinarily send your case information to an independent provider merely because we recommend that provider.

6.5 If you ask or agree for us to make an introduction, we will normally agree what information is appropriate to share before doing so. This may include your name, contact details, property information, a summary of the issue or relevant documents where agreed.

6.6 Once an independent provider receives information for its own professional or commercial purposes, it will normally act as a separate controller and be responsible for explaining how it uses that information.

7. INTERNATIONAL TRANSFERS

7.1 UNLEASE is based in the United Kingdom, but some of our technology and service providers may process personal information in other countries.

7.2 We do not promise that all personal information will be stored or processed exclusively in the UK.

7.3 Where UK data-protection rules restrict an international transfer, we will use an appropriate mechanism where required, such as:

• (a) UK adequacy regulations;

• (b) an applicable UK-US adequacy arrangement;

• (c) the UK International Data Transfer Agreement;

• (d) the UK Addendum to approved standard contractual clauses; or

• (e) another lawful safeguard or exception.

7.4 The providers and countries involved may change as our business and technology develop.

7.5 You may contact us for further information about safeguards applying to a particular transfer of your personal information.

8. HOW LONG WE KEEP INFORMATION

8.1 We keep personal information for as long as reasonably necessary for the purposes described in this Policy, including providing the Services, maintaining appropriate records, complying with law, handling complaints and establishing or defending legal claims.

8.2 Account, property-profile, Diagnosis, tool, report and related core records may generally be retained while your account remains active and, where reasonably necessary, for up to six years after the relevant account relationship or matter ends.

8.3 Uploaded documents may also be retained for up to six years where reasonably necessary to preserve the record on which an output was based, deal with complaints or claims, or meet another legitimate need. We may delete them earlier where continued retention is unnecessary.

8.4 Records showing acceptance of our Terms and Conditions, Privacy Policy and marketing choices may be retained for an appropriate evidential period, including for up to six years after the relevant relationship ends where reasonably necessary.

8.5 Complaint and dispute records may generally be retained for up to six years after conclusion and longer where an active legal or regulatory matter requires it.

8.6 Security and technical records will normally be retained for shorter periods, although relevant records may be retained longer where connected with an incident, fraud, misuse, investigation or legal matter.

8.7 Marketing opt-out information may be retained for as long as reasonably necessary to ensure that we continue to respect the opt-out.

8.8 Genuinely anonymised information may be retained indefinitely.

8.9 These are general retention periods, not commitments to retain every record for the maximum period. We may delete or anonymise information earlier, or retain it longer where reasonably necessary or required by law.

9. COOKIES AND SIMILAR TECHNOLOGIES

9.1 UNLEASE uses cookies, local storage and similar technologies that store information on, or access information from, your device.

9.2 We use these technologies to support sign-in and security, remember your preferences, operate essential parts of UNLEASE and, with your permission, understand how people use our website and Services.

9.3 Necessary technologies support functions you request or other essential functions. We use them without consent where applicable law permits.

9.4 We use PostHog and Google Analytics to help us understand how UNLEASE is used and improve the Services. We use optional analytics identifiers and similar technologies only with your permission.

9.5 You can accept or decline optional analytics through our cookie controls. You can change your choice at any time using Cookie settings.

9.6 You can also block or delete cookies and similar technologies through your browser or device settings. Blocking technologies needed for core functionality may prevent parts of UNLEASE from working as intended.

Technologies used

9.7 Individual cookies, identifiers and their durations may change as UNLEASE and its providers develop. We will review and update this information where appropriate.

10. SECURITY

10.1 We use technical and organisational measures designed to protect personal information against unauthorised access, unlawful use, accidental loss, alteration, disclosure or destruction.

10.2 Our safeguards may include access controls, authentication, infrastructure and supplier security, logging, backups and appropriate internal procedures.

10.3 We review and may change our security arrangements as UNLEASE, technology and risks develop.

10.4 No internet-based or electronic system can be guaranteed to be completely secure.

10.5 You are responsible for taking reasonable steps to protect your own account and login credentials.

11. YOUR RIGHTS

11.1 Depending on the circumstances, data-protection law may give you rights to:

• (a) obtain information about how your personal information is used;

• (b) request access to it;

• (c) request correction of inaccurate information;

• (d) request deletion;

• (e) request restriction of processing;

• (f) object to particular processing;

• (g) receive certain information in a portable format;

• (h) withdraw consent where we rely on consent; and

• (i) exercise rights concerning certain automated decisions where applicable.

11.2 These rights are not absolute and may be subject to legal conditions or exemptions.

11.3 In particular, asking us to delete an account does not necessarily require us immediately to delete information that we remain permitted or required to retain for legal obligations, complaints, security, fraud prevention, evidential purposes or establishing, exercising or defending legal claims.

11.4 To exercise a privacy right, contact:

team@unlease.co.uk

11.5 We may ask for information reasonably necessary to confirm your identity, locate relevant information and protect personal information from unauthorised disclosure.

11.6 We will respond in accordance with applicable data-protection law.

12. COMPLAINTS, CHANGES AND CONTACT

Complaints

12.1 If you have a concern about how UNLEASE handles personal information, please contact us first at:

team@unlease.co.uk

12.2 You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data-protection regulator. Further information is available at ico.org.uk.

12.3 Contacting UNLEASE first does not remove your right to complain to the ICO.

Changes to this Policy

12.4 We may update this Privacy Policy from time to time to reflect changes to:

• (a) law or regulatory guidance;

• (b) UNLEASE and its Services;

• (c) our purposes for using information;

• (d) technology and service providers; or

• (e) our privacy and security practices.

12.5 The current version will display its version number and effective date.

12.6 Where appropriate, we may notify users about material changes or provide additional privacy information when new processing begins.

12.7 We may retain historical versions for compliance and evidential purposes.

Contact

12.8 Questions, requests or concerns relating to this Privacy Policy may be sent to:

team@unlease.co.uk

or by post to:

UNLEASE LTD
124 City Road, London, United Kingdom, EC1V 2NX

Version: 2.1
Effective date: 27/10/2026