BMP LETTING LTD ("we", "us") — HMO Assistant Last updated: 9 August 2026 · Version: 1.0 (draft — not yet reviewed by a solicitor)
HMO Assistant is a WhatsApp-based assistant that helps private landlords manage property maintenance, compliance, tenancies and rent.
Two different roles. This matters, and we state it plainly:
From landlords: name, WhatsApp number, email, property addresses and rooms, billing details (handled by Stripe — we never see full card numbers), and the content of your messages to the assistant.
From tenants, applicants and contractors (on the landlord's behalf): name, phone number, the content of WhatsApp/email messages, photographs and videos of maintenance issues, tenancy details (room, rent, deposit, payment status), and — for applicants — the information they volunteer when enquiring about a room.
Automatically: message timestamps and delivery status, and technical logs needed to run and debug the service.
Bank data (optional, landlord-initiated only): if you connect your bank, we receive read-only access to incoming transaction data through TrueLayer, an FCA-authorised open-banking provider. We use it solely to match rent payments to tenancies. We cannot move, send or take money, and we never see your online banking credentials. You can disconnect at any time, and the consent expires automatically every 90 days under Open Banking rules.
| Purpose | Lawful basis |
|---|---|
| Providing the assistant to a landlord (handling reports, quotes, reminders) | Contract |
| Handling tenant/contractor messages on a landlord's instructions | The landlord's basis (legitimate interests / contract / legal obligation); we act as processor |
| Rent reconciliation from connected bank data | Contract, plus your explicit consent given through TrueLayer |
| Compliance records (gas, EICR, EPC, licensing) | Legal obligation of the landlord; legitimate interests |
| Billing, fraud prevention, service security | Contract; legitimate interests |
| Improving reliability (aggregated, non-identifying) | Legitimate interests |
We do not sell personal data, and we do not use it for advertising.
Special category data. We do not ask for health, ethnicity or similar data. A tenant may volunteer it in a message (for example explaining why a repair is urgent). We do not use it for any decision, and we ask landlords not to solicit it.
Automated decisions. The assistant uses AI to draft replies, classify urgency and rank enquiries. It does not make final decisions about a tenancy. A human landlord approves lettings decisions and any spending. If a decision meaningfully affects someone, they may ask for human review at xuyongdeng@hotmail.com.
| Provider | Purpose | Where |
|---|---|---|
| Amazon Web Services (Lightsail) | Hosting the application | London (eu-west-2), UK |
| Twilio Ireland Ltd | WhatsApp message delivery | EU/US |
| Meta Platforms Ireland (WhatsApp) | The messaging channel itself | EU/US |
| Airtable | Database of jobs, tenancies, compliance records | US |
| DeepSeek (via the AI proxy operator) | AI understanding and drafting | [TO BE CONFIRMED] |
| TrueLayer Ltd | Open-banking read access (only if you connect a bank) | UK |
| Stripe Payments Europe Ltd | Subscription billing | EU/US |
| GoCardless Ltd | Direct Debit rent collection (only if enabled) | UK |
| Google (Gmail) | Backup email channel | EU/US |
Where a provider processes data outside the UK, we rely on UK International Data Transfer Agreements / the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision.
| Data | Retention |
|---|---|
| Maintenance jobs, quotes, contractor records | 6 years (limitation period for contract claims) |
| Compliance certificates and dates | 7 years, or as long as the law requires them to be evidenced |
| Rent and tenancy records | 6 years after the tenancy ends (HMRC and deposit-dispute needs) |
| WhatsApp conversation history | 24 months, then deleted |
| Unsuccessful applicant enquiries | 6 months, then deleted |
| Bank transaction data | 24 months |
| Account and billing records | 7 years after the account closes |
When a landlord closes their account we delete or return their data within 90 days, except where we must keep it by law.
You may request access, correction, erasure, restriction, portability, or object to processing. To exercise them, contact xuyongdeng@hotmail.com; we respond within one month.
If you are a tenant, applicant or contractor, your landlord is the controller of your data — please contact them first. Ask us and we will pass your request to them and help them answer it.
You may complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113) at any time.
Data is encrypted in transit (TLS). Credentials are held outside the application repository and are never stored in code or in version control. Access to the production system is restricted to the operator by SSH key. Administrative and diagnostic endpoints are reachable only from the server itself, not from the internet. Bank access is read-only by design and cannot initiate a payment. We keep an audit trail of messages and actions so a landlord can evidence what was reported and when.
Breaches. If a breach is likely to risk people's rights, we notify the ICO within 72 hours and tell affected landlords without undue delay.
The assistant works through WhatsApp, operated by Meta. Your use of WhatsApp is also governed by Meta's own terms and privacy policy. Messages are delivered via Twilio. Do not send us payment card details or passwords over WhatsApp — we will never ask for them.
We will post any change here and, if it is significant, tell you on WhatsApp or by email at least 14 days before it takes effect.