PRIVACY POLICY

This privacy policy sets out how WhichPad UK LTD uses and protects your Personal Data. You should read this privacy policy carefully so that you understand how and why we use your Personal Data when you use our website.

  1. Important information and who we are Privacy policy

This privacy policy explains how WhichPad UK LTD collects and uses your Personal Data when you use our website, including any information you provide when you register an account, submit a review, contact us, or interact with any of the features offered through www.whichpad.com and WhichPad UK LTD collectively.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

WhichPad UK LTD is the controller and is responsible for your personal data. When this privacy policy refers to “WhichPad”, “we”, “us” or “our”, it is referring to WhichPad UK LTD as the legal entity responsible for managing your Personal Data in accordance with UK data protection law.

If you have any questions about this privacy policy or if you wish to exercise your legal rights, please contact us using the details set out in paragraph 10 of the privacy policies.

2.               The types of Personal Data we collect about you

Personal Data means any information about an individual from which that person can be identified.

We collect, use and store the following types of Personal Data when you use our website or submit a review:

  • Identity Data: This includes your first name, last name, and the display name you choose to appear alongside your review. Students may choose an alias or nickname for privacy reasons. We retain the name you provide at registration and the display name you select for your public- facing review.
  • Contact Data: This includes your email address and any other contact information you choose to provide to us, such as your address and telephone numbers. We usually verify student eligibility using a university email If you contact us from a different email address, we will use that address to respond to your enquiry.
  • Financial Data: This includes bank account and payment card details where you choose to purchase paid services from us.
  • Transaction Data: This includes details about payments to and from you and other details of products and services you purchase from us, where you use any paid features or services that we offer.
  • Technical Data: This includes your IP address, browser type and version, device information, time zone setting, and other technology used to access our website. This data is collected automatically through cookies and similar technologies.
  • Profile Data: This includes your username and password, a record of reviews you have submitted, and, where applicable, any purchases or orders you make, together with any interests, preferences, feedback and survey responses you choose to provide.
  • Usage Data: This includes information about how you interact with and use our website, products and services.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3.               How is your Personal Data collected?

We use different methods to collect data from and about you including through:

Your interactions with us.

You may give us your Personal Data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact
  • Automated technologies or interactions. As you interact with our website, we automatically collect Technical Data about your device, browsing patterns and We collect this data using cookies and similar technologies. For more information, please see our cookie policy.
  • Third parties or publicly available sources. We may receive Technical Data about you from analytics providers such as Google Analytics. Otherwise, we do not obtain Personal Data about our users from external sources. Reviewers are verified directly through their university email addresses, which are provided by you at registration and not obtained from any third party.

  1. How we use your Personal Data Legal basis

The law requires us to have a legal basis for collecting and using your Personal Data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to, including any orders for disclosure. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your Personal Data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your Personal Data

We set out below how we use your Personal Data and the legal bases we rely on for each type of processing.

 

Purpose/Use Type of data Legal basis [and retention period]
To register you as a new user (a)  Identity

(b)  Contact

 We use your Identity Data and Contact Data to create and verify your account using your university email address. This is necessary for the performance of a contract with you.
To process and deliver your order where you choose to purchase paid services from us, including:

(a)  managing payments, fees and charges, and

(b)       collecting and recovering money owed to us.

 (a)  Identity

(b)  Contact

(c)  Financial

(d)  Transaction

(e)             Marketing            and Communications

 (a)  Performance of a contract with you

(b)   Necessary for our legitimate interests (to recover debts due to us)
To allow you to submit reviews and manage your interactions with the platform. (a)  Identity

(b)  Contact

(c)  Profile

(d)  Usage Data

 We use your Profile Data, Content Data and Usage Data to publish reviews, manage your profile, and ensure reviews meet our moderation standards. This is necessary for the performance of a contract with you and for our legitimate interests in maintaining a trustworthy review platform.

 

To     verify     that         reviews are submitted by genuine students. (a)  Identity

(b)  Contact

 We use your university email address to confirm reviewer eligibility and protect the integrity of the platform. This is necessary for our legitimate interests in preventing fraudulent or misleading content.
To contact you regarding your account, your review, or a request you have made. (a)  Identity

(b)  Contact

 We may contact you if you ask us to amend or remove a review, or if further information is required to verify your identity when responding to such requests. This is necessary for the performance of a contract with you and for our legitimate interests in ensuring the accuracy and security of the platform.
To analyse usage and improve our website. (a)            Technical                       Data

(b)                Usage                    Data

(c)  Aggregated Data

 We may use aggregated Technical Data and Usage Data to assess how students interact with the platform, identify trends, and develop and improve our services. This is necessary for our legitimate interests in improving the website and supporting the student community.
To              send                 marketing communications where you have agreed to receive them. (a)              Contact                     Data

(b)             Marketing            and Communications Data

 If you have opted in, we may use your Contact Data and Marketing and Communications Data to send you information about updates to the platform or related services. We rely on consent for this processing.
To manage our relationship with you which will include:

(a)   Notifying you about changes to our terms or privacy policy

(b)    Dealing with your requests, complaints and queries

 (a)  Identity

(b)  Contact

(c)  Profile

(d)             Marketing            and Communications

 (a)  Performance of a contract with you

(b)     Necessary to comply with a legal obligation

(c)   Necessary for our legitimate interests (to keep our records updated and manage our relationship with you).
To enable you to partake in a prize draw, competition or complete a survey (a)  Identity

(b)  Contact

(c)  Profile

(d)  Usage

(e)             Marketing            and Communications

 (a)  Performance of a contract with you

(b)   Necessary for our legitimate interests (to study how users use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a)  Identity

(b)  Contact

(c)  Technical

 (a)   Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

 

(b) Necessary to comply with a legal obligation
To deliver relevant website content              and   online advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a)  Identity

(b)  Contact

(c)  Profile

(d)  Usage

(e)             Marketing            and Communications

(f)  Technical

 Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, user relationships and experiences and to measure the effectiveness             of  our communications and marketing (a)  Technical

(b)  Usage

 Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data (a)  Identity

(b)  Contact

(c)  Technical

(d)  Usage

(e)  Profile

(f)              Marketing           and Communications

 Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications
To carry out market research through your voluntary participation in surveys (a)  Identity

(b)  Contact

(c)  Profile

(d)  Usage

(e)             Marketing            and Communications

 Necessary for our legitimate interests (to study how users use our products/services and to help us improve and develop our products and services).

 

Direct marketing

You will only receive marketing communications from us if you have actively chosen to receive them, such as by opting in to email updates when creating your account. You can withdraw your consent at any time.

Third-party marketing

We will not share your Personal Data with third parties for their own marketing purposes unless you give us express consent

Opting out of marketing

You may ask us to stop sending marketing communications at any time by contacting us or by following the opt-out instructions in any marketing email. You will still receive essential service communications relating to your account.

Cookies

For information about how we use cookies, please see our cookie policy.

5.               Disclosures of your Personal Data

We may share your Personal Data only where this is necessary and always in accordance with the law. We do not sell your Personal Data and we do not share reviewer information with letting agencies unless we receive a valid court order requiring us to do so.

We may share your Personal Data with the following categories of recipients.

  • Service providers who support our website.

We may share Technical Data and limited account information with trusted third-party service providers who assist us in hosting, maintaining or securing our website, or in providing analytics services. These providers are only permitted to process your Personal Data in accordance with our instructions and must keep it confidential.

  • Professional advisers.

We may disclose Personal Data to our legal representatives, accountants, insurers or other advisers where necessary for compliance, legal advice, insurance arrangements or the management of risk.

  • Regulators and law enforcement.

We may disclose your Personal Data if required to do so by law or where we are obliged to comply with a lawful request, including from courts, regulators, or law enforcement agencies. As advised to you during the consultation, we will only disclose reviewer identity information where legally required and typically only following a valid court order.

  • Third parties involved in a business transaction.

If we sell, transfer or merge part of our business or our assets, the new owner may use your Personal Data in the same way as set out in this privacy policy.

We require all third parties who receive Personal Data from us to respect the security of your Personal Data and to treat it in accordance with UK data protection law. They must not use your Personal Data for their own purposes and may only process it for the purposes specified by us.

6.               International transfers

We do not transfer your personal data outside the United Kingdom. If this position changes in the future, for example if we use a service provider that stores data outside the UK, we will ensure that any such transfer complies with the relevant data protection legislation. This may include using the UK approved International Data Transfer Agreement or ensuring that the destination country has been recognised as providing an adequate level of protection for Personal Data. We will update this privacy policy and notify users accordingly of such an update.

7.               Data security

We have put in place appropriate technical and organisational measures to protect your Personal Data and to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include access controls, encrypted connections, password protection, and restricted administrative access to the systems where your data is stored.

We limit access to your Personal Data to employees, contractors and service providers who have a genuine business need to access it. They will only process your Personal Data on our instructions and are subject to confidentiality obligations.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.               Data retention

How long will you use my Personal Data for?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which we collected it. This includes retaining data to provide our services to you, to maintain the integrity of our review platform, and to meet any legal, accounting or reporting requirements.

When deciding how long to retain Personal Data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which the data is processed and whether those purposes can be achieved through other means, and the applicable legal requirements.

By law, we must keep certain basic information about our users for a minimum period for tax and accounting purposes. This may include limited Contact Data and Identity Data.

In some circumstances, you may ask us to delete your Personal Data. Further information on your rights can be found in paragraph 9.

In certain cases, we may anonymise Personal Data so that it can no longer be associated with you. We may then use this information indefinitely without further notice to you.

9.               Your legal rights

You have a number of rights under data protection laws in relation to your personal data. These rights allow you to understand and control how we use your personal information.

You have the right to request access to your Personal Data. This is often referred to as a subject access request. It enables you to obtain a copy of the Personal Data we hold about you and to check that we are processing it lawfully. We will treat such requests with care and will respond within one month of receiving such a request. Should further time be required, we will notify you of this before the expiry of the one-month period.

You have the right to request correction of any Personal Data we hold about you that is incomplete or inaccurate. We may need to verify the accuracy of the new information you provide.

You have the right to request the erasure of your Personal Data in certain circumstances. This includes situations where there is no good reason for us to continue processing it, where you have successfully exercised your right to object, or where we are required by law to erase the data. We may not always be able to comply with a request for erasure for specific legal reasons. If this applies, we will explain this to you at the time of your request.

You have the right to object to the processing of your Personal Data where we rely on a legitimate interest as the legal basis for using your data. We will consider your objection and assess whether we have compelling legitimate grounds which override your rights and freedoms. You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.

You have the right to request the restriction of processing of your Personal Data in certain circumstances. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy, if our use of the data is unlawful but you do not want it erased, or if you need us to retain it to establish, exercise or defend legal claims.

You have the right to request the transfer of your Personal Data to you or to another party. We will provide your data in a structured, commonly used, machine readable format. This right applies to data that you provided to us and which we process using automated systems based on your consent or based on a contract with you.

You have the right to withdraw consent at any time where we rely on consent to process your Personal Data. Withdrawing consent does not affect the lawfulness of processing that took place before the withdrawal. If you withdraw consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw consent.

If you wish to exercise any of these rights, please contact us using the details set out in paragraph 10 of this privacy policy. We may need to request specific information from you to confirm your identity and to ensure that personal data is not disclosed to anyone who has no right to receive it. This is an important security measure.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.            Contact details

If you have any questions about this privacy policy or about the use of your Personal Data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: hello@whichpad.com
  • Postal address: WhichPad UK LTD, 40 Fredora Avenue, Hayes, Middlesex, UB4 8RD

11.            Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK regulator for data protection. The ICO’s website is www.ico.org.uk.

Before doing so, we would appreciate the chance to deal with your concerns directly. If you have any questions about this privacy policy or our handling of your Personal Data, please contact us using the details in paragraph 10 and we will do our best to resolve the matter. The ICO will expect you to have raised your concerns with us before contacting them.

12.            Changes to the privacy policy and your duty to inform us of changes

 We keep this privacy policy under regular review to ensure it remains accurate and up to date. This version was last updated on 28 November 2025.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, including changes to your university email address or contact information.

13.            Third-party links

This website may include links to third-party websites, plugins or applications. Selecting those links or enabling those connections may allow the third party to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.