Complaints Procedure

Blackwellen Limited (Blackwellen, we, us) provides Propvora. We want to know when something has gone wrong, so that we can put it right and stop it from happening again. This procedure explains how to complain, how we handle complaints, and what you can do if you are not satisfied with our response.

We will treat every complaint seriously, fairly and in confidence. Making a complaint will not affect how we treat you or your account. We will not close or restrict an account because someone has complained.

Blackwellen Limited is registered in England and Wales under company number 16482166. Our registered office is 61 Bridge Street, Kington, Herefordshire, HR5 3DJ, United Kingdom.

• Complaint means any expression of dissatisfaction, whether spoken or written and whether justified or not, about the Service, our conduct or our handling of personal data, that requires a response.
• Complainant means the person or organisation making a Complaint, or someone acting on their behalf with their authority.
• Customer means the business or individual who holds a subscription for a Propvora workspace.
• Consumer means an individual acting wholly or mainly outside their trade, business, craft or profession.
• Service means the Propvora software platform, websites, portals and related services.
• Working day means a day other than a Saturday, Sunday or bank holiday in England.
• Data Protection Complaint means a Complaint about how we have processed, or responded to a request about, personal data, as described in section 9.

You can use this procedure to complain about anything for which Blackwellen is responsible, including:

• the Service: faults, errors, lost or incorrect data, availability, features not working as described, or the quality of our support;
• billing and subscriptions: charges, renewals, failed or duplicate payments, refunds, cancellations, plan changes and VAT where it applies;
• data protection: how we have collected, used, shared, kept or secured personal data, or how we have handled a request to exercise a data protection right (see section 9 (Data protection complaints));
• AI features: Outputs from the Agent or other AI features that are inaccurate, offensive, discriminatory or harmful, or that appear to have used data they should not have (see section 10 (Complaints about AI features));
• accessibility: barriers to using the Service, including where we have not provided an accessible format or made a reasonable adjustment (see our Accessibility Statement);
• our partner programme: the conduct of our partner programme, or of partners promoting Propvora, including misleading or unsolicited promotion; and
• our people: the conduct of our staff or contractors.

Anyone affected by our actions may complain, including Customers, their team members, people who use our portals, partners, website visitors, and individuals whose personal data is processed in the Service.

Propvora is software that landlords, letting and managing agents, property managers and other businesses use to run their own operations. Blackwellen is not a landlord, letting agent, managing agent or property manager, and is not a party to any tenancy, lease, management agreement or works contract. We do not decide whether repairs are done, whether a deposit is returned, what rent is charged, or whether a tenancy ends.

This procedure therefore does not cover disputes between landlords, tenants, leaseholders, agents, contractors, guarantors or applicants about the property or the relationship between them, even where those parties use Propvora to communicate or to keep records. Examples include complaints about:

• repairs, damp and mould, safety certificates or the condition of a property;
• rent, rent increases, arrears, fees or service charges;
• deposits and deposit deductions;
• notices, possession proceedings or the ending of a tenancy;
• the outcome of a rental application or referencing decision;
• the conduct of a landlord, agent or contractor; or
• the content of messages sent by a landlord or agent through the Service.

If your complaint is about one of these matters, you should complain to the landlord, agent or other business concerned, using their own complaints procedure. Section 14 (Help with housing and tenancy issues) lists organisations that can help.

If you are not sure whether your complaint is about us or about a landlord or agent, contact us anyway. We will tell you, and where the complaint is about how a Customer has used your personal data in the Service, we will explain who to contact (see section 9.2).

This procedure is also not the right route for reporting a security vulnerability (see section 16 of our Security Statement) or for exercising a data protection right such as access or erasure, although you may complain under this procedure if you are unhappy with how such a request was handled.

You can complain in any of the following ways:

• By email: legal@propvora.com. Putting "Complaint" in the subject line helps us route it quickly.
• By post: Complaints, Blackwellen Limited, 61 Bridge Street, Kington, Herefordshire, HR5 3DJ, United Kingdom.
• Through the Service: using the support or help options in the app, where available. If you raise a concern through support and say you want it treated as a complaint, we will treat it as one.

You do not need to use any particular wording or form. We will treat an expression of dissatisfaction as a Complaint if it is clear that you want us to respond to it as one, and we will ask you if we are not sure.

Please complain as soon as possible after the problem arises, ideally within six months, as it becomes harder to investigate older events. We will still consider later complaints where it is reasonable to do so, and this time guide does not affect any legal time limits or rights you have.

You may ask someone to complain on your behalf, such as a colleague, friend, relative or adviser. We will need your confirmation that they are authorised to act for you before we share personal information with them.

To help us investigate quickly, please tell us:

1. your name and the best way to contact you;
2. the name of the workspace or account concerned, and the email address you use to sign in, if any;
3. what went wrong, and when;
4. any relevant references, such as an invoice number, record name, error message or the date and time of a message;
5. screenshots or documents that support your complaint, if you have them;
6. how the problem has affected you; and
7. what you would like us to do to put things right.

Please do not send passwords, full card numbers or other authentication details. If you need to send special category personal data, such as health information, only include what is necessary.

If you need help making your complaint, or need us to communicate with you in a particular way, such as by phone call arranged by email, in large print or with more time, please tell us (see section 15 (Reasonable adjustments)).

7.1 Acknowledgement

We will acknowledge your complaint in writing within 5 working days of receiving it. Our acknowledgement will tell you who is handling your complaint and when you can expect a full response. If we need more information, we will ask for it at this stage.

7.2 Investigation

The person handling your complaint will review the relevant records, which may include account information, support correspondence, billing records and system logs, and may speak to the people involved. Where your complaint concerns the content of a Customer's workspace, we will look only at what is necessary to investigate, and in accordance with our Data Processing Agreement.

Where possible, the complaint will be handled by someone who was not directly involved in the matter complained about.

7.3 Quick resolution

Many problems, such as a billing error or a technical fault, can be fixed straight away. If we resolve your complaint to your satisfaction within the acknowledgement period, we will confirm this in writing and close the complaint, but you can ask us to reopen it if the problem comes back or you change your mind.

We aim to send you a full written response within 20 working days of receiving your complaint. Our response will:

• explain what we found and the reasons for our conclusions;
• say whether we uphold your complaint in full, in part or not at all;
• set out what we will do to put things right, if anything;
• tell you about any changes we will make as a result; and
• explain how to ask for a review under section 11 (Escalation to a director) and the external options in section 13 (If you are still not satisfied).

If your complaint is complex and we cannot respond fully within that time, we will write to you before it expires to explain why, tell you what we have done so far, and give you a new date. Delay will not be used to avoid dealing with a complaint.

Different timescales apply to Data Protection Complaints, as described in section 9.

9.1 Where Blackwellen is the controller

Where we decide how and why personal data is used, for example for account, billing, website, marketing, security and partner programme data, we are the controller and you can complain to us about how we have handled your personal data. The Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025, requires controllers to facilitate complaints about the processing of personal data, to acknowledge them within 30 days, to take appropriate steps to respond without undue delay, including making appropriate enquiries, and to tell the complainant the outcome. We will meet those requirements and, in practice, will apply the shorter acknowledgement target in section 7.1. Data Protection Complaints are handled by our data protection lead, who can be contacted at legal@propvora.com.

9.2 Where a Customer is the controller

Where personal data is held in a Customer's workspace, for example a tenant's details held by their landlord or agent, the Customer is the controller and we process that data on the Customer's behalf. If your complaint is about how the landlord, agent or other Customer has used your data, you should complain to them first, as they decide how the data is used. If you contact us, we will tell you who the controller is where we can do so, pass your complaint to the Customer where appropriate, and help the Customer respond as required by our Data Processing Agreement. If your complaint is about something we did as processor, such as a security incident at our end, we will investigate it under this procedure.

9.3 The Information Commissioner

If you are not satisfied with how your Data Protection Complaint has been handled, you can complain to the Information Commissioner's Office at ico.org.uk. The ICO generally expects you to have raised your concern with the organisation first and may ask to see our response. You do not have to wait for our procedure to finish before contacting the ICO, but giving us the opportunity to respond often resolves matters more quickly.

Our ICO registration number is ZC160806. More information about how we use personal data, and your rights, is in our Privacy Notice.

You can complain about an Output from the Agent or any other AI feature, for example where it was inaccurate, offensive, discriminatory or harmful, where it appears to have drawn on data it should not have seen, or where you believe it was used to make a decision about you.

When we investigate an AI complaint, we may review the relevant input and output, the configuration and safeguards in place, and any related approval in the Service. We will tell you what we found and what we have changed, such as adjusting safeguards or restricting a feature. Our AI Disclaimer and AI Use Policy explains how the AI features work and their limits.

Under that Policy, Customers must not use AI features to make solely automated decisions with legal or similarly significant effects on tenants or applicants. If you believe a landlord or agent made such a decision about you, you have the right to ask that landlord or agent for human review and to contest the decision, and you may complain to them and to the ICO. We will cooperate with the Customer and the ICO as appropriate.

If you are not satisfied with our full response, you can ask for your complaint to be reviewed by a director of Blackwellen. Please email or write to us within 30 days of our response, explaining why you remain dissatisfied and what you would like to happen. We will accept a later request where there is a good reason for the delay.

The director will review the complaint, the investigation and our response, and may carry out further enquiries. We aim to send you the director's written decision within 20 working days of receiving your request, and will tell you if we need longer and why.

The director's decision is our final response to your complaint. It will explain the external options available to you.

Where we uphold a complaint, we will try to put you back in the position you would have been in if the problem had not happened, as far as that is reasonable. Depending on the circumstances, this may include:

• an apology and explanation;
• correcting an error, restoring data where possible, or fixing a fault;
• correcting a bill, issuing a refund or credit, or cancelling a charge, in line with our Refund and Cancellation Policy and Terms of Service;
• changing our processes, training or the Service to stop the problem happening again; and
• for Consumers, any remedy to which you are entitled by law.

Any payment we offer is made in accordance with our Terms of Service, including its liability provisions. Accepting an apology or a remedy does not prevent a Consumer from relying on their statutory rights.

13.1 Data protection

You can complain to the Information Commissioner's Office at ico.org.uk about how we have handled your personal data (see section 9.3).

13.2 Alternative dispute resolution for Consumers

Alternative dispute resolution (ADR) is a way of resolving disputes without going to court, using an independent body. Blackwellen is not currently a member of an ADR scheme and is not required by law or any trade association to use one, unless we say otherwise in our final response. If a dispute with a Consumer cannot be resolved through this procedure, our final response will give details of a certified ADR provider that could deal with it and will say whether we agree to use that provider for your complaint. Using ADR is voluntary and does not stop you going to court.

13.3 The courts

Our Terms of Service are governed by the law of England and Wales. If you are a Consumer living in Scotland or Northern Ireland, you can also bring proceedings in your local courts. Lower-value claims can be dealt with by simplified procedures:

• in England and Wales, through the small claims track of the County Court, which generally deals with money claims of up to £10,000, and which can be started online through HM Courts and Tribunals Service;
• in Scotland, through the simple procedure in the Sheriff Court, generally for claims of up to £5,000; and
• in Northern Ireland, through the small claims court, generally for claims of up to £5,000.

Court fees and procedures can change, so please check the current position on the relevant official website before starting a claim. Business Customers can bring claims as set out in our Terms of Service.

13.4 Other help for Consumers

Consumers can get free, impartial advice about their rights from Citizens Advice (consumer helpline in England and Wales), Advice Direct Scotland in Scotland, and Consumerline in Northern Ireland.

As explained in section 4, we cannot resolve disputes between landlords, tenants, leaseholders and agents. If you have a problem with your home, the following organisations may be able to help:

• Your landlord or agent's own complaints procedure: this should usually be your first step. The landlord or agent is responsible for the property and for their own conduct.
• Property redress schemes: in England, letting agents and property managers must by law belong to a government-approved redress scheme. The two schemes are The Property Ombudsman and the Property Redress Scheme. Once you have been through the agent's complaints procedure, you can ask their scheme to look at your complaint. The agent must tell you which scheme it belongs to.
• Private landlords: the Renters' Rights Act 2025 provides for a new ombudsman for private landlords in England. Once it is set up, private landlords will be required to join it and tenants will be able to use it.
• Social housing: tenants of councils and housing associations can complain to the Housing Ombudsman Service in England after using their landlord's complaints procedure.
• Your local council: the council's private housing or environmental health team can investigate serious hazards, disrepair, overcrowding, unlicensed HMOs and harassment or illegal eviction.
• Shelter (England), Shelter Cymru (Wales), Shelter Scotland and Housing Advice NI: free expert advice on housing problems, including eviction and repairs.
• Citizens Advice: free, confidential advice on housing, money and consumer issues.
• Tenancy deposit schemes: disputes about deposit deductions can usually be referred to the free dispute resolution service of the scheme protecting the deposit.

Arrangements differ in Wales, Scotland and Northern Ireland, and the advice organisations above can tell you what applies where you live.

We want everyone to be able to complain easily. If you have a disability or another reason why our usual process is difficult for you, tell us what would help and we will make reasonable adjustments. For example, we can communicate in a particular format, allow more time, arrange to call you at an agreed time, or deal with someone you nominate to act for you. Our Accessibility Statement explains how to request information in an alternative format.

We understand that people who complain may be frustrated or upset, and we will be patient. However, we will not tolerate abusive, threatening or discriminatory behaviour towards our staff.

If a complainant's behaviour is unacceptable, or if a person repeatedly raises the same complaint after we have given our final response without providing new information, we may restrict how they contact us, for example by asking them to communicate only in writing or through one named person. We will explain any restriction in writing and review it periodically. We will not restrict anyone's ability to use external routes such as the ICO or the courts.

We keep a record of every complaint we receive, including the date received, the nature of the complaint, the steps we took, our responses, and the outcome. We use these records to manage the complaint, to identify recurring problems and improve the Service, and to demonstrate how we handle complaints, including to the ICO where it asks.

Complaint records are kept securely, are only accessible to the people who need them, and are retained for 6 years after the complaint is closed, unless we need to keep them longer because of a legal claim or regulatory enquiry. Information about how we use personal data in complaint records is in our Privacy Notice.

We will only share information about your complaint with people who need to see it to investigate or respond, such as the staff member concerned, our professional advisers, a Customer where the complaint concerns their workspace, or the ICO or an ADR provider if you take your complaint to them.

This procedure does not affect your statutory rights, including your rights as a Consumer under the Consumer Rights Act 2015 and your rights under data protection law. Using this procedure does not prevent you from taking legal action, although we hope it will make that unnecessary.

We review this procedure at least once a year and when the law changes. Questions about it can be sent to legal@propvora.com.

Additional terms for marketplace payments made through Stripe are in Complaints Policy (marketplace update): marketplace payments.