This notice explains how Landlord Pulse (operated by IWNA) handles your personal data. It is the document you accept when you sign up. We have kept it short and direct on purpose.
Who we are
Landlord Pulse is a property portfolio management app for UK landlords. It is operated by IWNA, a small UK accountancy. Our ICO Data Protection registration number, registered address and full registered name are listed on this page once registration is complete — if any of that information is missing today, the trial has not yet opened. Our privacy contact is privacy@landlordpulse.co.uk and our account contact is support@landlordpulse.co.uk.
We are the Data Controller for your personal data on Landlord Pulse. There is no separate Data Protection Officer — we are too small to be legally required to appoint one — but Richard Hamlyn is the named privacy lead and the person who answers the privacy mailbox.
What data we collect, why, and our lawful basis
We collect only what we need to run the service. Under UK GDPR every piece of processing has to have a lawful basis. The full set is:
Account data
Your name, email and a hashed password. We use it to create your account and let you log in. Our lawful basis is contract performance.
Properties you add
UK addresses, purchase price, mortgage details, rental income and expenses. We use it to show you your portfolio and run the calculations you signed up for. Lawful basis: contract performance.
Financial data from Xero, QuickBooks or Sage (if you connect it)
Transactions and balances. We use it to produce your reports and AI insights. Lawful basis: contract performance.
Compliance dates
Gas safety, EICR, EPC certificate dates. We use them to remind you when certificates expire. Lawful basis: contract performance.
Login times and IP address
We log them to detect compromised accounts. Lawful basis: legitimate interest in your account security.
In-app actions
We capture which features you use to understand which features work and where users get stuck. Lawful basis: legitimate interest in product improvement, with opt-out available via the cookie banner.
Billing data
Stripe customer ID and billing address, captured when paid plans launch. Lawful basis: contract performance plus legal obligation for HMRC record-keeping.
Support messages
Messages you send us. Lawful basis: contract performance and legitimate interest in helping you when something breaks.
Getting-started emails
A short series of emails in your first weeks showing you how to set up and use Landlord Pulse. Which ones you receive depends on what you've already done in the app (for example, we don't ask you to connect Xero if you already have), so we use your account activity to decide what to send. We count clicks on the links in these emails, but we don't track whether you open them. Lawful basis: legitimate interest in helping you get value from the service you signed up for. You can stop them at any time via the unsubscribe link in every email or in Notifications settings.
Marketing emails
Only if you opt in. Lawful basis: consent, which you can withdraw at any time via the unsubscribe link in every email.
Device push token
Only if you install our iOS app and allow notifications. Your device gives us a push token — an identifier for that device, not for you — which we store against your account so we can send you compliance reminders. Lawful basis: contract performance, because reminders are part of the service you signed up for. The reminder names the obligation and may name the property, for example "Gas safety certificate expires in 30 days"; it never contains portfolio figures, tenant details or documents. Getting it to your phone means passing the token and that text through Google's Firebase Cloud Messaging and Apple's Push Notification service, both in the United States under the UK International Data Transfer Agreement. Turn notifications off at any time in the app or in iOS Settings; signing out deletes the token from your account.
What we do not collect
We do not collect special-category data under UK GDPR Article 9 — health, race, religion, biometrics — and we ask you not to enter any. We do not collect children's data; the app is for adults only. We do not collect your tenants' personal details; the app is not designed to hold tenant data and you should not enter it. We do not see your full payment card number; Stripe handles that and we never receive it.
AI insights
When you use chat or generate a strategy plan, we send your relevant portfolio data to an AI model. The default model is Google Gemini, processed in the UK / EU at the europe-west2 region under Google's Data Processing Addendum. The AI returns insights for you to read. AI suggestions are advisory only — the app never takes a financial or legal action automatically based on AI output. You are in control. Section 8 below covers automated decision-making in detail.
Each conversation you have with Pulse, the in-app AI assistant, is saved so you can reopen and continue it later on the web or in the iOS app. Our lawful basis is contract performance. Only you can see your saved chats: if you work on a client's portfolio as an adviser, or give an adviser access to yours, neither of you can see the other's chats. They are stored in the UK / EU with the rest of your data. You can rename or delete a chat, or delete them all, from the History tab in Pulse; we delete each saved chat automatically 12 months after its last message, and all of them when you close your account. They are included when you download your data.
How long we keep your data
Your account and portfolio data is kept while your account is active, then 30 days after you close it, then deleted. Saved Pulse AI chats are kept for 12 months after the last message in each chat, or until you delete them or close your account, whichever is sooner. The LLM audit log — hashed records of AI calls with no prompt text and no response text — is kept for 24 months. Login and access logs are kept for 12 months. Billing records, when paid plans launch, are kept for 7 years to meet HMRC requirements. Support tickets are kept for 24 months after resolution. Backups are kept on a 30-day rolling basis.
When you close your account we hard-delete from live systems within 30 days and from backups within the next backup cycle, so the worst-case end-to-end is around 60 days. The only things we keep longer are anonymised audit log entries that contain no personal data, and statutory billing records.
Who we share your data with
We use a small set of trusted sub-processors. Each one has a written data-protection agreement with us. The full live list with what each one does and where they process data is at /legal/sub-processors. The headline is that Google Cloud and Firebase host the app and store your data — your portfolio, financial data and documents — in the UK / EU at europe-west2; Google Vertex AI processes your AI insights in europe-west2; Xero (UK), QuickBooks Online (US) or Sage Accounting (processing region to be confirmed) is the source of your accounting data if you connect it; Stripe takes payment once paid plans launch; an email provider sends you transactional email; Sentry captures error reports if the app crashes; Zoho Desk (EU) handles support tickets if you contact us; a product analytics provider tracks anonymised event data; and, if you use our iOS app with notifications on, Google Firebase Cloud Messaging and Apple's push service (both US) deliver those notifications to your phone. One exception applies to your login: the Firebase Auth login system (your email, the hashed form of your password, and your sign-in history) is processed by Google in the United States, because Google does not yet offer a UK/EU-only option for it — this transfer is protected by the Standard Contractual Clauses in Google's data-processing agreement, and we keep what is held there to the minimum needed to sign you in.
We do not sell your data. We do not share it with advertisers. We do not use your data to train any AI model.
If you create your account through an introducer's referral link or by entering their referral code, we will tell that introducer that you have signed up, and later that you have become a paying customer, so their referral commission can be calculated. We show you this — naming the introducer — on the sign-up page before your account is created; if that notice was not shown, the introducer only ever sees your sign-up counted anonymously, never your name or email. We share only the fact and date of your sign-up and of your becoming a paying customer, plus your name and email where the notice was shown — never your portfolio, financial or property data. You can ask us to stop this at any time via privacy@landlordpulse.co.uk.
If you arrive through one of our own campaign links (an email, social post, event or flyer — the link carries a short campaign code), we record which campaign brought you when you create your account, and then count what accounts from that campaign go on to do (starting a trial, becoming a paying customer, adding a property, connecting accounting software and similar) so we can see which campaigns work. This is internal reporting only: nothing is shared with anyone outside Landlord Pulse, and staff see campaign totals, not a list of who came from which campaign. Visits to a campaign link are counted without identifying you. We only remember the campaign code on your device if you accept analytics cookies. You can object to this at any time via privacy@landlordpulse.co.uk.
We currently have the option in our code to send certain high-stakes outputs to Anthropic's Claude model in the US, but this is disabled for the trial. If we ever enable it we will give you 30 days' advance notice and update this page, and we will only do so once we have a signed Data Processing Agreement with Anthropic that includes Zero Data Retention, so Anthropic does not keep or train on your data.
Where any sub-processor is outside the UK or EEA we rely on the UK International Data Transfer Agreement (IDTA) or the Addendum to the EU Standard Contractual Clauses, together with the encryption and access controls described below.
Your rights
You have the following rights under UK GDPR. To exercise any of them, email privacy@landlordpulse.co.uk. We respond within 30 days, usually much faster.
You can see what we hold (right of access, Article 15) via a one-click export at /account/export. You can correct anything wrong (rectification, Article 16) by editing most fields yourself in the app or emailing us. You can delete your account and data (erasure, Article 17) — self-serve at /account/delete; until that is live, email us and we delete within 30 days. You can restrict processing (Article 18) while a dispute is resolved. You can take your data with you (portability, Article 20) via the same JSON export. You can object to processing based on legitimate interests (Article 21), including objecting to analytics telemetry. You can withdraw consent for marketing emails at any time via the unsubscribe link.
You can complain to the Information Commissioner's Office at ico.org.uk if you think we have handled your data wrongly. We would appreciate you raising it with us first, but you do not have to.
You will not be charged for any of these requests and we will not make it difficult.
How we keep your data safe
The technical detail lives in our internal Data Security Policy, which we use to drive engineering work. The short version is that we use HTTPS everywhere with HSTS preload and no HTTP fallback; AES-256 encryption at rest, managed by Google Cloud in their UK / EU data centres; access controls that lock your data to your account, enforced by the server on every request and by a default-deny database rule; AI calls that carry your tenant identifier and only ever see your own portfolio data, with the default provider in the UK / EU; logging of AI calls, admin actions and access to personal data, without logging the content of your AI prompts or responses (your saved chats are kept separately, for you, and deleted after 12 months); daily encrypted backups kept for 30 days; staff access limited to the people who need it, with admin actions logged; and a breach notification policy that tells the ICO within 72 hours and tells you without undue delay if your data is affected.
No system is invulnerable. We size our controls to the risk of the data — financial, not health or biometric — and the scale of the operation — small accountancy, trial cohort. If we ever scale into enterprise territory we will add more.
Cookies and tracking
The full cookie list is on the Cookie Policy page linked from the cookie banner and at /cookies. The summary is that we set strictly necessary cookies for login, security and your active tenant — these are always on and do not require consent under PECR; analytics cookies for product event telemetry without any third-party advertising — these are opt-in via the cookie banner; and no advertising cookies and no third-party trackers.
You can change your cookie choices any time at /account/cookies.
AI and automated decision-making
We use AI to generate suggestions, for example a portfolio strategy or an answer to a chat question. AI suggestions are advisory only. The app does not take any binding decision about you, your finances or your properties automatically. UK GDPR Article 22 — the right not to be subject to a decision based solely on automated processing — is therefore not engaged.
We do not use your data to train any AI model. We have configured our AI provider settings to opt out of training where the provider supports this. For any future provider where opt-out is not standard, we negotiate Zero Data Retention before sending live user data.
Changes to this notice
If we materially change how we handle your data — adding a new sub-processor, changing retention periods, opening a new processing purpose — we will update this page with a new version and date at the top, and notify you by email or an in-app banner at least 30 days before the change takes effect for material changes. For non-material changes such as typos or restructuring we will just update the page.
If you are not happy with a change you can delete your account before it takes effect.
Business customers
If you are a business customer — a Ltd-company landlord, an accountant managing client data, a letting agent — and you require a signed Data Processing Agreement, email privacy@landlordpulse.co.uk and we will provide our standard DPA. Most individual landlords do not need one and we do not push one at signup.
Contact
privacy@landlordpulse.co.uk is the privacy mailbox. We aim to acknowledge within 2 working days and resolve within 30 days. For account or product questions, support@landlordpulse.co.uk. For complaints we have not resolved to your satisfaction, the Information Commissioner's Office at ico.org.uk.