Privacy Policy

1. Introduction

This Privacy Policy explains how Maccrose Ltd (“we”, “us”, “our”, or “Hut24”) collects, uses, shares and protects your personal data when you use the Hut24 mobile application and related services (the “Platform”).

Hut24 is an online marketplace that connects Hosts who advertise rooms and properties with Renters looking for accommodation in the United Kingdom. Protecting your personal data is important to us, and we are committed to handling it responsibly and in line with the law.

This Policy applies to all users of the Platform, including Hosts and Renters, and to visitors to our website. It should be read together with our Terms and Conditions. Please read it carefully so that you understand your rights and how we use your information.

2. Who We Are: Data Controller

For the purposes of UK data protection law, the data controller responsible for your personal data is Maccrose Ltd, a company registered in England and Wales (company number 16776777) with its registered office at 48 Harwill Crescent, Nottingham NG8 5JQ.

If you have any questions about this Policy or how we handle your data, you can contact us at info@briggrtech.com.

3. Personal Data We Collect

We collect personal data in several ways: information you give us directly, information we collect automatically when you use the Platform, and information we receive from third parties. The categories of data we collect include the following.

3.1 Information you provide to us

• Account and profile data: your name, email address, mobile phone number, password, profile photo, and whether you are registering as a Host or a Renter.
• Identity verification (KYC) data: information and documents used to verify your identity, which may include photo identification, proof of address, and the results of verification checks.
• Listing data: if you are a Host, the details, photographs, videos, descriptions, location, rent, availability and house rules of the properties you advertise.
• Search and preference data: if you are a Renter, your search filters, saved or favourite listings, and accommodation preferences.
• Communications and content: messages you send through in-app messaging, enquiries, booking interest submissions, reviews and ratings, and any content you upload.
• Payment-related data: records of paid features you purchase and transaction history. Payments are processed by third-party providers; we do not store full payment card numbers.
• Support and correspondence: information you provide when you contact us, submit a report, or raise a complaint.

3.2 Information we collect automatically

• Device and technical data: device type, operating system, app version, unique device or advertising identifiers, and IP address.
• Usage data: how you interact with the Platform, including pages and listings viewed, features used, clicks, and listing analytics such as views and enquiries.
• Location data: approximate location derived from your IP address, and, where you grant permission, more precise location used for map and search features. You can control location permissions through your device settings.
• Notifications: if you enable push notifications, we process the identifiers needed to deliver real-time alerts such as new messages and promotions.

3.3 Information from third parties

We may receive information about you from identity verification providers, payment providers, app store platforms, and other users (for example, if another user reports content or leaves a review involving you).

3.4 Special category and children's data

We do not intentionally collect special category data (such as data about health, race or religion). Please do not include such information in listings, messages or reviews. The Platform is not intended for anyone under 18, and we do not knowingly collect data from children. If we become aware that we have collected data from someone under 18, we will delete it.

4. How and Why We Use Your Data

Under UK data protection law, we must have a lawful basis for processing your personal data. The table below explains what we use your data for and the lawful basis we rely on for each purpose.

Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and freedoms. You can ask us for more information about this assessment.

5. Marketing Communications

Where you have agreed, we may send you marketing messages about promotions, offers and features that may interest you. You can opt out of marketing at any time by using the unsubscribe link in our emails, adjusting your notification settings in the app, or contacting us. Opting out of marketing does not stop service messages that are necessary to operate your account.

6. How We Share Your Data

We do not sell your personal data. We share personal data only in the following circumstances:

• With other users: certain profile and listing information is shown to other users so the Platform can function. For example, a Host's listing details are visible to Renters, and limited profile information is shared between users who message each other.
• With service providers: we use trusted third parties that process data on our behalf, such as cloud hosting providers, identity verification providers, payment processors, analytics providers, and customer support tools. They may only use your data on our instructions.
• With payment and app store providers: such as the Apple App Store, Google Play Store, and payment gateways, where you make a purchase.
• For legal and safety reasons: with law enforcement, regulators, courts or other authorities where required by law, or to protect the rights, property or safety of Hut24, our users or others.
• In a business transfer: if our business is sold, merged or reorganised, your data may be transferred to the new owner, who must continue to protect it.

6.1 Categories of third-party providers

We rely on the following categories of third-party providers to operate the Platform: cloud hosting and infrastructure providers; identity verification providers used for KYC checks; payment providers, which may include Stripe, PayPal, Google Pay and Apple Pay; analytics providers used to measure and improve the Platform; and customer support and communications tools. Each provider acts on our instructions where they process data on our behalf, and each has its own privacy policy governing its use of data.

7. International Data Transfers

We are based in the United Kingdom and aim to store and process personal data within the UK or the European Economic Area (EEA). Some of our service providers, however, may process data in other countries.

Whenever personal data is transferred outside the UK, we make sure it is protected by appropriate safeguards. This may include transfers to countries the UK government has decided provide an adequate level of protection, or the use of standard contractual clauses approved for use under UK law (such as the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses). You can contact us for more information about these safeguards.

8. Your Right to Request Account and Data Deletion

You have the right to request the deletion of your Hut24 account and the personal data associated with it at any time.

How to request deletion

You can request deletion in either of the following ways:

• In-app: open the Hut24 app, go to Settings > Account > Delete My Account, and follow the on-screen instructions.
• By email: send a deletion request from the email address registered to your account to info@briggrtech.com, with the subject line “Account Deletion Request”.

We may ask you to verify your identity before processing the request to protect your account from unauthorised deletion.

What will be deleted?

Once your request is verified and processed, we will delete or irreversibly anonymise the personal data we hold about you, including your account and profile information, your listings (if you are a Host), your saved searches and favourites (if you are a Renter), your uploaded photographs and videos, and your in-app messages.

What may be retained, and why

Certain information may be retained for a limited period after account deletion, only where we have a legal basis to do so. This includes:

• Transaction and payment records: retained for up to 6 years to comply with UK tax, accounting and financial record-keeping laws.
• Identity verification (KYC) records: retained for the period required by applicable anti-fraud and legal obligations.
• Reports, moderation records, and safety-related content: retained where necessary to protect other users, prevent fraud, or defend legal claims.
• Reviews and messages sent to other users may remain visible to those users in an anonymised form to preserve the integrity of the review system and other users' records of their own conversations.
• Backup copies: deleted data may persist in secure backups for a limited period before being overwritten in the normal course of business.

Any retained data is stored securely, access is restricted, and it will be deleted once the retention period ends.

Timeframe

We will action verified deletion requests within 30 days of receipt, and confirm to you by email once your account has been deleted.

Alternative to deletion

If you would prefer to keep your account but stop receiving communications or temporarily pause your listings, please contact us. We can help you adjust your settings or deactivate your account without permanently deleting it.

9. How Long We Keep Your Data

We keep your personal data only for as long as necessary for the purposes set out in this Policy, including to provide the Platform, comply with our legal, accounting and reporting obligations, resolve disputes and enforce our agreements.

As a general guide, we keep account data for as long as your account is active. After you close your account, we will delete or anonymise your personal data within a reasonable period, except where we need to retain certain information for longer, for example, transaction and tax records, or information needed to handle a dispute, prevent fraud, or meet a legal obligation. Listings, reviews and messages may be retained where required for safety, moderation or legal reasons.

Our specific retention periods are set out in our internal retention schedule.

10. How We Protect Your Data

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or alteration. These measures may include encryption of data in transit, access controls, secure hosting, and staff training. No system can be guaranteed to be completely secure, so while we work hard to protect your data, we cannot guarantee absolute security. You also have a role to play by keeping your password confidential and not sharing your account.

11. Your Data Protection Rights

Under the UK GDPR, you have a number of rights in relation to your personal data:

• Right to be informed: to know how your data is used, as set out in this Policy.
• Right of access: to request a copy of the personal data we hold about you.
• Right to rectification: to ask us to correct inaccurate or incomplete data.
• Right to erasure: to ask us to delete your data in certain circumstances.
• Right to restrict processing: to ask us to limit how we use your data in certain circumstances.
• Right to data portability: to receive certain data in a structured, commonly used format, or have it transferred to another provider.
• Right to object: to object to processing based on our legitimate interests, and to object to direct marketing at any time.
• Rights relating to automated decision-making: to not be subject to solely automated decisions that have a legal or similarly significant effect on you.
• Right to withdraw consent: where we rely on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at info@briggrtech.com. We will respond within one month, although this may be extended for complex requests. Exercising your rights is free of charge in most cases. We may need to verify your identity before acting on a request.

12. Automated Processing and Moderation

We use automated tools as part of our content moderation and safety processes, including filtering listings, messages and reviews for prohibited keywords or phrases. These tools support our human moderators rather than replace them; decisions that significantly affect you, such as removing a listing or suspending an account, involve human review. If you believe a decision about your content or account was wrong, you can contact us to ask for it to be reviewed.

13. Cookies and Similar Technologies

The Platform and our website may use cookies and similar technologies, such as software development kits (SDKs) and device identifiers, to operate the app, remember your preferences, measure usage and improve performance. Some of these are necessary for the Platform to work, while others are optional and used for analytics or marketing.

Where required by law, we will ask for your consent before using non-essential cookies or similar technologies, and you can manage your preferences through the app or your device settings.

14. Third-Party Links and Services

The Platform may contain links to, or integrate with, third-party websites and services. This Privacy Policy does not apply to those third parties. We encourage you to read the privacy policies of any third-party service you use.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we will notify you through the app or by email. The date at the top of this Policy shows when it was last updated. We encourage you to review it periodically.

16. Complaints and the Information Commissioner's Office

If you have a concern about how we handle your personal data, please contact us first at info@briggrtech.com so we can try to resolve it.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, although we would appreciate the chance to deal with your concerns first. You can contact the ICO via its website at ico.org.uk, or by telephone on 0303 123 1113.

17. How to Contact Us