Privacy Policy
3 Win Investor Limited | ICO Registration: ZB060185 | UK GDPR & Data Protection Act 2018 | Last updated June 2026
1. Introduction
3 Win Investor Limited trading as 3 Win Property is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data in connection with our property management, lettings, and transitional housing services. We are registered with the Information Commissioner's Office under registration number ZB060185.
2. Who We Are
| Legal Entity | 3 Win Investor Limited |
|---|---|
| Trading Name | 3 Win Property |
| Registered Address | Coventry, United Kingdom |
| ICO Registration Number | ZB060185 |
| Contact Email | info@3win.co.uk |
3. What Personal Data We Collect
3.1 Tenants
- Full name and date of birth
- Current and previous addresses
- National Insurance Number
- Email address and telephone number
- Next of kin and emergency contact details
- Employment and income details
- Bank account details
- Identity documents
- Right to Rent documentation
- References
- Photographs for identification
- Maintenance requests and communication history
3.2 Transitional Housing Residents
In addition to the above:
- Risk assessment information from referring agency
- Support needs and vulnerabilities where shared by referral partners
- Case worker or probation officer details
- Special category data including health information only where shared by a statutory referral partner and only where strictly necessary
3.3 Landlords and Property Owners
- Full name and contact details
- Home address
- Bank details for rental payments
- Tax information
3.4 Website Visitors
- Name and email via contact forms
- IP address and cookie data
- Enquiry content
4. Legal Basis for Processing
| Data Category | Legal Basis | Purpose |
|---|---|---|
| Tenant data standard | Art 6(1)(b) Contract | To perform the tenancy agreement |
| Tenant data standard | Art 6(1)(c) Legal obligation | Right to Rent checks and statutory landlord obligations |
| Transitional housing special category data | Art 9(2)(g) Substantial public interest | Safe housing provision for vulnerable individuals |
| Landlord data | Art 6(1)(b) Contract | To perform the management agreement |
| Website enquirer data | Art 6(1)(a) Consent | To respond to enquiries |
5. How We Use Your Data
- To manage tenancy agreements and rental properties
- To carry out Right to Rent checks
- To communicate with tenants regarding maintenance and payments
- To register tenancy deposits
- To provide transitional housing services
- To respond to enquiries
- To manage business operations
- To comply with legal obligations
6. Data Retention
| Record Type | Retention Period | Legal Basis |
|---|---|---|
| Tenancy records active | Duration plus 6 years | Limitation Act 1980 |
| Tenancy deposit records | Duration plus 6 years | Legal obligation |
| Right to Rent checks | Duration plus 2 years | Immigration Act 2014 |
| Financial records | 6 years from year end | HMRC |
| Transitional housing records | 3 years post-departure | Safeguarding |
| Job applicant data unsuccessful | 6 months | ACAS |
| Website enquiry data | 12 months | To respond then deleted |
| CCTV footage if applicable | 31 days | ICO guidance |
7. Who We Share Your Data With
- Tenancy deposit protection schemes
- Referral partners including local authorities, RSLs and support organisations
- HMRC and regulatory bodies
- Property maintenance contractors
- Cloud software platforms used in operations including Monday.com, Google Workspace, Stripe and Lovable
- Legal advisors or debt recovery agents
We do not sell personal data. We do not transfer personal data outside the United Kingdom.
8. Your Rights
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights related to automated decision-making — we do not carry out automated decision-making
To exercise any rights contact info@3win.co.uk. We will respond within one calendar month.
9. Data Security
- Password protected devices and accounts
- Secure encrypted cloud platforms
- Locked physical storage for paper documents
- Access restricted to those who need it
- Data processing agreements with third-party processors
10. Data Breach Procedure
- Contain and assess immediately
- Notify ICO within 72 hours if breach likely to result in risk
- Notify affected individuals where breach is high risk
- Record all breaches in our Record of Breaches log
11. Complaints
If unhappy with how we handled your data contact the ICO at www.ico.org.uk, helpline 0303 123 1113, address ICO Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF.
12. Policy Review
This policy will be reviewed annually. Next review due June 2027. Approved by Director, 3 Win Investor Limited June 2026.