Privacy Policy

1. Who We Are

1.1 This Privacy Policy explains how LLCR Technologies Ltd (“LLCR”, “we”, “us”, or “our”) collects, uses, stores, and shares your personal data when you use our Platform and visit our website.

1.2 LLCR Technologies Ltd is the data controller for the personal data described in this Policy. This means we decide why and how your personal data is processed.

1.3 Our details:

1.4 We have not appointed a Data Protection Officer as we are not required to do so under Article 37 of the UK GDPR. If you have any questions about this Policy or our data practices, please contact us at [email protected].

2. What This Policy Covers

2.1 This Policy applies to personal data we collect when you:

(a) visit our marketing website at llcr.uk;

(b) create an account and use our Platform at llcr-app.uk;

(c) subscribe to a paid Plan or use the Free plan;

(d) contact us by email or through the Platform;

(e) interact with our AI assistant, Ava;

(f) upload documents for automated data extraction;

(g) request an export of your data; or

(h) request deletion of your account.

2.2 This Policy does not cover third-party websites or services linked from our Platform. We encourage you to read the privacy policies of those third parties before providing them with your personal data.

3. The Personal Data We Collect

Swipe or scroll horizontally to see all columns.

3.1 We do not ask you for special category data. None of our forms request racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, and we have no field anywhere in the Platform for recording a tenant’s health, disability, or vulnerability.

3.2 However, several parts of the Platform have free-text boxes, and you may upload documents containing information we did not ask for. The description field when you report a property issue is the most likely example: a note explaining why a hazard is urgent may describe an occupant’s health. Please do not enter special category data unless it is genuinely necessary. Where you do, it is processed in the same way as the rest of that entry, including being sent to our AI provider in the circumstances described at clause 11.

3.3 Right to Rent checks involve immigration-related information. This is not a special category of data under Article 9 of the UK GDPR, but we recognise that it is sensitive and we handle it accordingly. We record that a check was made, when, and by what method. We do not record a person’s immigration status or nationality as a structured field.

3.4 We do not knowingly collect personal data from anyone under the age of 18. The Service is intended for adult landlords and letting professionals only.

4. How and Why We Use Your Personal Data

The UK GDPR requires us to have a lawful basis for each way we use your personal data.

Swipe or scroll horizontally to see all columns.

4.1 Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms and are satisfied that our interests do not override them. If you would like more information about how we have done this for a particular purpose, contact us at [email protected].

4.2 Where we rely on your consent, you may withdraw it at any time by contacting us or changing your settings in the Platform. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

5. Who We Share Your Data With

5.1 We do not sell your personal data to anyone. We never have and we never will.

5.2 We share your personal data with the following processors, who act only on our instructions and under a written contract meeting the requirements of Article 28 of the UK GDPR:

Swipe or scroll horizontally to see all columns.

5.3 We also use the following services, which do not act as our processors:

Swipe or scroll horizontally to see all columns.

5.4 We may also disclose your personal data if required to do so by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5.5 If LLCR is acquired, merges with another company, or sells substantially all of its assets, your personal data may be transferred to the successor entity. We will notify you of any such transfer and any choices you may have regarding your data.

5.6 The table at clause 5.2 is our current list of processors. If we engage a new processor, we will update this Policy and give at least 30 days’ notice before the new processor begins processing your data, so that you have an opportunity to raise any objection.

6. International Data Transfers

6.1 Your Platform data, including all uploaded documents, is stored in the United Kingdom. Our database and file storage are hosted on Amazon Web Services in London.

6.2 Our encrypted offsite backup is stored in the Netherlands, and our error monitoring data is stored in Germany. The United Kingdom has adequacy regulations covering the European Economic Area, so no additional safeguard is required for those transfers.

6.3 Some of our other service providers are based in the United States. When we transfer personal data outside the United Kingdom, we ensure appropriate safeguards are in place as required by Chapter V of the UK GDPR. The safeguards we rely on are:

(a) the UK Extension to the EU-US Data Privacy Framework, for providers certified under it;

(b) the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, where the Data Privacy Framework does not apply; and

(c) UK adequacy regulations, where the destination has been assessed by the UK Government as providing an adequate level of protection. This covers transfers to the European Economic Area.

6.4 The specific safeguard relied on for each provider is set out in the table at clause 5.2.

6.5 You may request a copy of the relevant safeguards by contacting us at [email protected].

7. How Long We Keep Your Data

7.1 Retention periods

We do not keep your personal data for longer than necessary.

Swipe or scroll horizontally to see all columns.

7.2 Pausing is not deletion

Some properties in your Workspace may be paused, for example when your account is on the Free plan. Pausing a property does not erase or archive any of its data off the system. All of its records, documents, certificates, history, tenant information, and audit trail entries remain stored and remain viewable by you, and are included in your data export and in the audit trail. What changes is processing, not storage: paused properties are excluded from compliance monitoring, scores, reminders, and related notifications. We also use your stored document sizes and each property’s active or paused status to apply the storage limits of your plan.

7.3 What happens when data is deleted

When you delete a document from your vault, the file is removed from our live storage immediately.

When you delete a certificate record, the record is marked as deleted and is no longer shown to you or included in your compliance score. The underlying evidence file is retained for as long as your account remains open. This is deliberate: the value of a compliance record lies in being able to demonstrate what was in place and when, and a certificate deleted in error should not destroy the evidence of a period during which you were compliant.

When your account and Workspace are deleted, the process at clause 9 applies: your data is permanently deleted from our live systems at the end of the 30-day notice period.

7.4 Backups

We maintain an encrypted offsite backup of Platform data, including uploaded files, with a storage provider separate from our main infrastructure. This exists so that we can restore your compliance evidence if our primary systems fail, are corrupted, or suffer data loss.

Backups work differently from live systems, and we want to be clear about what that means for you:

(a) When data is deleted from our live systems, a copy may remain in the backup for a period afterwards.

(b) Backup data is held beyond use. We do not access, search, analyse, or use it for any purpose other than restoring the Service following a failure. It informs no decision about you or about anyone else.

(c) We have implemented an automated process to remove deleted files from our backups on a defined schedule. Under that schedule, a file deleted from our live systems is removed from backup approximately 90 days after its deletion, and never earlier than 35 days, because our backups are held in immutable storage with a minimum retention period as a protection against tampering and ransomware. That process is presently operating in a reporting-only mode while we complete verification testing. Until it is fully enabled, backup copies are retained and held beyond use as described above. We will update this Policy when the deletion schedule takes effect.

(d) If you ask us to erase your data, we will confirm both that it has been erased from our live systems and how it is being handled in backup. The Certificate of Deletion described at clause 9 relates to our primary systems; backup copies expire separately on the schedule above.

7.5 When a retention period expires, we securely delete or anonymise the data so that it can no longer be linked to you.

8. Getting a Copy of Your Data: The Export Feature

8.1 You can request a complete export of your Workspace data at any time from the settings area of the Platform. This is how we give practical effect to your rights of access (Article 15) and data portability (Article 20): you do not need to email us to get a copy of your data, although you can if you prefer (clause 13).

8.2 The export is prepared in the background and you are notified by email when it is ready. It is a ZIP archive containing your Workspace data, including:

(a) active and paused properties, certificates, deposits, compliance checks, documents and their files, notices and service evidence, reported issues, tenancy and rent records;

(b) your Ava conversations;

(c) your activity and audit trail records, together with the daily anchor receipts; and

(d) a manifest, a checksum file, and an offline verification script, so that you can independently confirm that the archive is complete and has not been altered.

8.3 For security, the export does not include live credentials or payment plumbing: invitation tokens, payment processor identifiers, bank connection tokens, and calendar access tokens are withheld. If you are a member of a team Workspace, the export contains a directory of member names, email addresses, and roles rather than other members’ full profiles.

8.4 Each export archive is retained for 7 days after it is generated and is then deleted automatically. Download links are valid for about 5 minutes each time one is issued; you can generate a fresh link at any time while the archive is retained.

8.5 Export requests, completions, and failures are recorded on your audit trail.

8.6 The export feature remains available while a deletion of your Workspace is scheduled, up to the point the deletion takes place. We recommend downloading an export before deleting your account.

9. Deleting Your Account and Workspace

9.1 The owner of a Workspace can request deletion of the Workspace and account from the settings area of the Platform. To protect against accidental deletion, the owner is asked to confirm by typing the Workspace name.

9.2 Deletion is scheduled for 30 days after the request. This is a cooling-off period: you can cancel the deletion at any time before it takes place, and you can continue to use your Workspace and download an export during it. We send a confirmation email when the deletion is scheduled, a reminder 7 days before it takes place, and a final reminder 1 day before. If you have a paid subscription, it continues during this period so that you keep full access, and it is cancelled automatically when the deletion is carried out.

9.3 When the deletion is carried out, we permanently delete from our live systems: your properties (whether active or paused) and all of their records, your uploaded documents and files, your certificates, deposits, checks, notices, issues, tenancy and rent records, your Ava conversations, your activity and audit trail records and anchor receipts, and any stored export archives. If your login is not associated with any other Workspace, your login is deleted too.

9.4 On completion, we email you a Certificate of Deletion confirming that your data has been deleted from our primary systems, together with the integrity details of your audit trail at the point of deletion. Backup copies expire separately, as described at clause 7.4.

9.5 After a deletion is carried out, we retain a limited deletion record so that we can evidence that the erasure was performed. That record contains: a one-way hashed (SHA-256) form of the account email address, the dates the deletion was requested and carried out, counts of the categories of records deleted, the final integrity hash of the audit trail, the result of the pre-deletion integrity check, and a hash of the Certificate of Deletion. It contains no name, no plaintext email address, no property or tenant data, and no document content. We keep this record for 6 years (clause 7.1) and use it for no other purpose.

9.6 We also retire workspaces that are genuinely inactive, so that we do not hold personal data (including tenant data) indefinitely for accounts that nobody uses. Throughout this clause, “inactive” means that no member of the workspace has signed in; automated system activity on a workspace never counts as a sign-in. A workspace can be scheduled for automatic deletion only in the following situations:

(a) Unused expired trial: the free trial ended, no paid subscription was ever taken out, at least 90 days have passed since the trial ended, and no member has signed in since it ended.

(b) Lapsed paid subscription: a paid subscription has ended, at least 90 days have passed since the end of the paid period, and no member has signed in since that period ended. If you cancel with time remaining, you keep access until the end of the period you have paid for, and the 90 days begin only when that access actually ends.

(c) Dormant free account: the workspace is on the Free plan and no member has signed in for 24 months.

9.7 We never automatically delete: an active paid subscription; a trial that is still running; a cancelled subscription that is still within its paid period; a workspace operated under a separate signed services agreement (for example, letting agency clients); or any workspace where a member has signed in within the periods described above.

9.8 An automatically scheduled deletion follows the same 30-day process described in this clause: we email the workspace owner a warning 30 days before the deletion date, a reminder 7 days before, and a final reminder 1 day before, and the deletion runs only once those notices have been sent. You can stop it at any time before it takes place. For an unused expired trial or a dormant free account, any member simply signing in cancels the scheduled deletion. For a lapsed paid subscription, sign in and choose one of the options shown: keep one property active on the Free plan, resubscribe, or cancel the deletion. The export feature (clause 8) remains available throughout the notice period, and clauses 9.3 to 9.5 (what is deleted, the Certificate of Deletion, and the deletion record) apply in the same way. The shortest possible automatic path is therefore around 120 days of inactivity (90 days plus the 30-day notice period), or 24 months plus 30 days for a dormant free account.

10. Tenant Data: Your Responsibilities as a Data Controller

10.1 When you enter personal data about your tenants into the Platform, you are acting as a data controller for that data within the meaning of the UK GDPR. We act as a data processor on your behalf.

10.2 As a data controller, you are responsible for:

(a) having a lawful basis for entering your tenants’ personal data into the Platform;

(b) informing your tenants about how their data is processed, including that you use LLCR as a data processor; and

(c) responding to any data subject requests from your tenants.

10.3 We process tenant data only on your documented instructions, which are given by your use of the Platform, and in accordance with our obligations as a processor under Article 28 of the UK GDPR.

10.4 We will assist you in responding to data subject requests to the extent that the relevant data is within our systems, and we will notify you without undue delay if we receive a request directly from one of your tenants.

10.5 Please note that pausing a property is not a deletion instruction: tenant data on a paused property remains stored (clause 7.2). Because audit trail records are append-only and are retained to preserve the integrity of your compliance evidence, erasing an individual tenant’s personal data from within a Workspace’s audit trail is not technically possible without deleting the Workspace; if one of your tenants exercises their right to erasure, contact us at [email protected] and we will work through the options with you.

10.6 We will notify you without undue delay after becoming aware of any personal data breach affecting data we process on your behalf, and will provide the information you reasonably need to meet your own obligations under Articles 33 and 34 of the UK GDPR.

10.7 We engage the processors listed at clause 5.2 as sub-processors in relation to tenant data. By using the Platform you give general authorisation for us to do so. We will give at least 30 days’ notice before engaging any new sub-processor, as described at clause 5.6.

10.8 On deletion of your account, we will delete tenant data in accordance with clauses 7 and 9. If you require the data to be returned rather than deleted, use the export feature (clause 8) or contact us before requesting deletion.

10.9 If you require a formal Data Processing Agreement, please contact us at [email protected] and we will provide one.

11. Artificial Intelligence: How Your Data Is Used

We use Anthropic’s Claude models in five places in the Platform. Anthropic acts as our processor. Anthropic does not use your data to train its models. This clause sets out each use and what is sent.

11.1 Ava, the AI assistant

Ava is not sent a fixed summary of your account. It is given tools that let it look up your data while answering, so what reaches Anthropic depends on what you ask.

With every message we send:

(a) your message and recent conversation history;

(b) your first name, your workspace identifier, your role in that workspace, and your subscription tier; and

(c) a summary of your portfolio, comprising property labels, compliance status, certificate expiry dates and aggregate counts.

In addition, Ava can retrieve further information from your account in order to answer you. Depending on your question, this can include property addresses and identifiers, detailed compliance state, the history and timeline of reported issues, and metadata about documents you hold. Anything Ava retrieves in order to answer a question is sent to Anthropic as part of producing the answer.

Ava reads your data. It cannot change it, and it cannot act on your account.

We do not send Anthropic your password or your payment card details.

On the Free plan, Ava is limited to 10 messages per calendar month. We count your messages in order to apply this limit; the count is usage data (clause 3) and is not shared with Anthropic.

11.2 Reading uploaded certificates

When you upload a certificate, we first try to read it on our own systems. Most PDFs contain a machine-readable text layer, and where that works the document is processed entirely within our infrastructure and is not sent to Anthropic.

Where a document has no readable text layer, or where you upload a photograph or a scan, we send the complete file to Anthropic so that the compliance details can be extracted.

We want to be clear about what that means. Although we ask only for particular fields, such as the issue date, the certificate number and the assessor name, the model receives the whole document. Anything printed on it may therefore be processed, including the property address and any tenant or occupier names appearing on the certificate. We do not crop or redact documents before sending them.

The request contains the file and our instructions for reading it. We do not add your workspace or user identifiers, your property records, your tenant list, or your landlord profile to it.

11.3 Compliance Defence Packs

When you generate a Compliance Defence Pack, the document itself is produced on our systems. We use Anthropic only to draft the executive summary.

For that purpose we send a structured summary containing:

(a) the property address, type, jurisdiction and HMO status;

(b) certificate types, issue and expiry dates, and whether evidence is held;

(c) the deposit amount, scheme, scheme reference and protection dates;

(d) compliance check outcomes and dates;

(e) counts of documents, notices and activity records; and

(f) audit chain verification results.

We do not send the underlying document files, certificate reference numbers, assessor names, tenant names, your legal name or registered address, filenames, notice contents, or the detail of your activity log.

11.4 Hazard Response Packs

When you generate a Hazard Response Pack for a reported issue, we send Anthropic a structured summary of that issue so that it can draft the narrative. This includes the issue description as you wrote it, the entries on its timeline, and the filenames of any evidence attached.

This is the AI feature most likely to receive free text, and therefore the one most likely to receive information you have typed rather than selected. If you have written something in an issue description or timeline entry that you would not want processed outside our systems, do not generate a Hazard Response Pack for that issue. Please see clause 3.2.

11.5 Section 8 notice wording

If you ask us to improve the wording of the grounds you have written for a Section 8 notice, we send the text you wrote to Anthropic and return a revised version. Nothing else about the property, the tenancy or the tenant is sent with it. This only happens when you actively ask for it.

11.6 What Ava and the other AI features never do

None of the five features above makes any decision about you. They produce text and extract data for you to review. You remain responsible for checking anything they produce before you rely on it, and a Defence Pack, Hazard Response Pack or notice remains your document, not ours.

11.7 Retention of AI conversations

Your conversations with Ava are stored on our systems so that you can return to them. They are kept for as long as your account is open and are deleted with the rest of your data when your account is deleted, in accordance with clauses 7 and 9. You can delete any individual conversation yourself at any time from within the Platform.

11.8 Automated decision-making

Neither Ava nor any other automated process makes decisions about your access to the Service, your subscription, or your legal rights. Compliance scores and status indicators are calculated from your certificate dates and are informational tools. They do not produce legal effects or similarly significant effects within the meaning of Article 22 of the UK GDPR. The automatic selection of your active property when a trial ends is applied by a simple, published rule (the property you added first) and can be changed by you in the Platform.

12. Cookies and Similar Technologies

12.1 This clause covers cookies and other technologies that store information on your device, including browser local storage and session storage. Our Cookie Policy at llcr.uk/cookies.html sets out the same information in more detail and explains how to manage your preferences.

12.2 On our marketing website (llcr.uk) we use only strictly necessary cookies.

12.3 On the Platform (llcr-app.uk) we store the following on your device:

Swipe or scroll horizontally to see all columns.

12.4 The referral identifier is the only item above that requires your consent, because it exists for our benefit rather than to deliver something you asked for. If you arrive through a partner referral link we will ask you before storing it. Declining will not affect your access to the Platform, the features available to you, or the price you pay. You can withdraw your consent at any time in your account settings.

12.5 Our product analytics operate without cookies. We do not use advertising cookies, and we do not share data with advertisers.

13. Your Rights Under the UK GDPR

Under the UK GDPR you have the following rights. These rights are not absolute and may be subject to exemptions.

Swipe or scroll horizontally to see all columns.

13.1 To exercise any of these rights, email [email protected]. We will respond within one month. If your request is complex we may extend this by a further two months, and will tell you within the first month if so.

13.2 We will not charge a fee, except where a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request.

13.3 We may need to verify your identity before acting on a request.

13.4 If you are a tenant and your landlord or letting agent uses LLCR, they are the controller of your data and we are their processor. Please direct your request to them in the first instance. If you contact us directly, we will forward your request to them without undue delay and will tell you that we have done so.

14. Data Security

14.1 We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include:

(a) encryption of data in transit and at rest;

(b) role-based access controls and workspace isolation, so that each customer can access only their own data;

(c) secure password hashing;

(d) database-level access policies enforcing separation between customer workspaces;

(e) a tamper-evident audit trail of activity on your account;

(f) encrypted offsite backups held with a separate provider, retained in immutable storage;

(g) short-lived, signed download links for export archives;

(h) automated error monitoring; and

(i) use of established third-party infrastructure providers who maintain recognised security certifications.

14.2 No system is completely secure, and we cannot guarantee absolute security.

14.3 If we become aware of a personal data breach, we will:

(a) notify the Information Commissioner’s Office without undue delay and, where feasible, within 72 hours of becoming aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals;

(b) notify you without undue delay where the breach is likely to result in a high risk to your rights and freedoms; and

(c) where we process data on behalf of a landlord or agency, notify that customer without undue delay so that they can meet their own obligations.

15. Changes to This Policy

15.1 We may update this Policy to reflect changes in our data practices, legal requirements, or the Service.

15.2 If we make material changes, we will notify you by email at least 14 days before they take effect, and will update the “Last updated” date at the top of this Policy.

15.3 We encourage you to review this Policy periodically.

16. How to Contact Us

16.1 If you have questions about this Policy, wish to exercise your rights, or have a concern about how we handle your data:

16.2 If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office: