Privacy Policy

Introduction

HolaHome (or “we” or the “Company”) undertakes to protect the privacy of all users when they use our services or when they contact us (the “Users” or “you”). This Privacy Policy explains our practices regarding how personal data collected and processed through our services is used.

All communications related to the processing of your personal data should be addressed to us via email at hola@holahome.com

HOLAHOME AS A DATA CONTROLLER

1. DATA CONTROLLER

HolaHome is Easy End SL, with Tax ID (CIF) No. B67157792 and address at Carrer del Sol, 3, 08172, Sant Cugat del Vallés (“HolaHome”), the company responsible for processing the data mentioned below.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

HolaHome, as a Data Controller, collects the following information about you.

2.1 Data collected on the HolaHome website and from electronic communication

  • Contact us. When you contact us through the form, we collect your name, email address, phone number, the zip code of your property if you’re a tenant, landlord or agent, and your message.
  • General website users. Due to internet communication standards, when you visit our website we automatically receive the URL of the site you came from and the site you visit after you leave our website. We also receive the internet protocol (“IP”) address of your computer and the type of browser you are using. Except for the aforementioned and what is stated in our cookie policy, we do not collect any type of personal data if you are simply browsing the website.
  • Data collected from electronic communication. When we exchange messages through email, we will ask you for some information in order to provide you with our services. The data we collect includes but is not limited to the following, and we could potentially request more information:
  1. If you are a tenant or potential tenant:
    • Full name
    • Telephone number
    • Email
    • Address
    • National ID Card (DNI)/Residence Permit (NIE)/Passport
    • Bank account
    • Monthly net income
    • Date of seniority
    • Employment status
    • End date of your employment status, if applicable
    • Last three pay stubs
    • If you have a contract lasting less than one year: employment history report
    • For self-employed workers: income tax statement
    • Type of tenant (guarantor or tenant)
    • Rental amount
  2. If you are a property owner:
    • Full name
    • Telephone number
    • Email
    • Address
    • National ID Card (DNI)/Residence Permit (NIE)/Passport
    • Bank account
    • Exact address of the property (Country, Province, City, Postal Code, Neighborhood, District, Region, Acronym, Address, Number, Block, Staircase, Floor, Door)
    • Year of construction
    • Floor plan
    • Usable space area
    • Constructed area
    • Land area
    • Photographs
    • Number of rooms
    • Number of bathrooms
    • Description of the kitchen
    • Home appliances
    • Type of flooring
    • Utility status
    • Community costs
    • Other expenses
    • Certificate of fitness for occupancy
    • Energy certificate
    • Land registry reference for the property
    • Land registry reference for parking, storage, if applicable
    • Title summary/Housing deed
    • Monthly rent and contract length
    • Water, electricity and gas meter readings
    • Last water, electricity and gas bills
    • Last property tax bill
    • Property inventory
    • Certificate of Electrical Installation (CIE) and, if the property is in Catalonia, also the Recognition of Electrical Installation certificate (BRIE).
  3. If you are an agent or are interested in working with HolaHome as an agent:
    • Full name
    • Telephone number
    • Email
    • Address
    • National ID Card (DNI)/Residence Permit (NIE)/Passport
    • Bank account
    • Property management license or real estate agent (API) number
  4. If you are a professional (both self-employed and companies) that would like to collaborate with us:
    • Full name
    • Telephone number
    • Email
    • Address
    • National ID Card (DNI)/Residence Permit (NIE)/Tax Identification Number (NIF)
    • Name and details of the company, if applicable
    • Bank account

It is important that the personal data we have for you is accurate and up-to-date. You are responsible for the accuracy of the information you provide to us, and you are expected to update that information.

2.3. Data use, purposes

General. We use your personal information for the following purposes related to the services we provide:

  • Your contact information: to answer your requests for information and get in touch with you, as well as send you notifications regarding the service we are providing and, if you give us your consent, send you commercial communications.
  • The data you provide to us through electronic communication: to provide you with our services and, specifically:
    • If you are a tenant: to find the apartment that best meets your needs, to assess your credit status and manage tasks prior to signing the lease.
    • If you are a landlord: to publish an advertisement for your apartment on several rental platforms, manage the viewing calendar for your apartment and carry out activities prior to signing the lease.
    • If you are an agent: to identify you and register you in our system as a real estate portfolio manager.
    • If you are a professional: to identify you, to allow you to access or manage incidents, repairs or other services that customers may need.
  • Data automatically collected through the web: to perform internal analyses on our website, to improve the website and our services according to user preferences.

2.4. Legal basis

Our legal bases for processing your personal data are as follows:

  • Provision of the contracted service and the execution of the contract of which you are a party, or to take action when requested.
  • Express informed consent to receive commercial communications about us and our services.
  • The legal interest of our company in directing and managing our business in order to provide you with the best service and the best and safest experience. We make sure to consider and balance any possible impact (both positive and negative) on you and your rights before processing your personal data for our legal interests.

In certain circumstances, we may process your data in order to comply with a legal or regulatory obligation to which we are subject.

3. DATA WE PROCESS FOR YOU AND IN YOUR NAME

In the event that you communicate third-party information to us, including but not limited to data from previous tenants or third-parties who will attend an apartment viewing with you, etc., HolaHome will be responsible for processing the third-party personal data you share with us (“Third-Party Data”) in order to process the information on your behalf so as to provide you with our services.

4. HOLAHOME’S OBLIGATIONS AS A DATA CONTROLLER

As established in the General Data Protection Regulation (GDPR), HolaHome, in its capacity as Data Controller, undertakes to:

  1. Process Third-Party Data only by following your documented instructions, including those regarding transferring personal data to a third country or an international organization, unless we are obligated to do so under Union Law or the laws of Member States; in this case, we will inform you of this legal requirement prior to processing your data unless prohibited under legislation for reasons of public interest.
  2. Ensure that those authorized to process personal data have committed to respect confidentiality or are subject to a duty of confidentiality.
  3. Take all appropriate technical and organizational measures to ensure a level of security that is appropriate to the risk of processing.
  4. Respect the conditions for referring to another Data Controller, as established in current regulations on the Protection of Personal Data.
  5. Assist the Data Controller, taking into account the nature of the processing, through appropriate technical and organizational measures whenever possible, so that the latter is able to comply with their obligation to respond to requests to exercise the rights of interested parties established in the GDPR.
  6. Help the person accountable, which is you, to ensure the fulfillment of their obligations, taking into account the nature of the processing and the information available to them.
  7. Should you choose, to delete or return all personal data once the processing is complete, and to delete existing copies unless the Third-Party Data is required to be preserved under Union Law or the laws of Member States.
  8. Make any information available to you that is required in order to demonstrate compliance with the obligations established in this article, and to allow and contribute to audits, including inspections, being carried out by the Data Collector.
  9. Treat Third-Party Data in such a way that ensures that the person responsible for said data follows your instructions.
  10. Ensure that our Privacy Officer participates appropriately and in a timely manner in all matters related to the protection of Third-Party Data.
  11. Adhere to the Code of Conduct approved by the corresponding Commission or body, if applicable.
  12. Keep a record of processing activities when processing personal data that poses a risk to the rights and freedoms of the interested party and/or involves the processing of special data categories and/or data related to convictions and infractions.
  13. Indiscriminately heed the legal exercises established in the GDPR.

5. DISCLOSURE OF DATA

We process your personal data confidentially in accordance with the applicable legislation. Unless otherwise stated, your personal data will not be provided to third parties.

In particular, we will disclose specific data as follows:

  • In order to provide HolaHome services, we may disclose your data to other HolaHome customers who, for example, are interested in renting your apartment, are the owners or managers of an apartment that interests you or could be of interest to you, are professionals who will carry out work or repairs to your apartment, etc.
  • In order to provide HolaHome services, if you are a landlord, we can publish your property information on several rental announcement platforms, including but not limited to Idealista.com, Fotocasa.com and pisos.com.
  • We may provide your data to companies who ask us to share it with them such as utility companies, etc.
  • We can make personal data available to any company that is purchasing or interested in purchasing the Company or part of its business and, consequently, give access to any national or international auditors in order to carry out their due diligence.
  • Third parties with whom we are required to share your information in order to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or website policy. These third parties include the investigative bodies that act by judicial or administrative request.

We can give our service providers who are under contract for the provision of Company services access to User personal data. We require that all third parties respect the security of your personal data and process it in accordance with the law. We do not allow our external service providers to use your personal data for their own purposes and we only allow them to process your personal data for specific purposes and in accordance with our instructions

6. INTERNATIONAL TRANSFERS (EXTERNAL SERVICE PROVIDERS)

We use various third parties to provide our Services, one of which, Google Inc., is located in the US, a country that does not generally provide adequate guarantees for the protection of personal data. However, this company is part of the Privacy Shield, which you can check using the following link. The Company has signed an agreement with these suppliers with the contractual guarantees required by law. You can contact us with any questions or to obtain copies of this agreement.

7. DATA RETENTION

In our role as Data Controller, HolaHome retains the personal data that you have provided to us for the time necessary to fulfill the purposes for which it was collected, including but not limited to the contract execution period with HolaHome customers. Once this personal data is no longer used for the aforementioned purposes, it will be stored for a period of 6 years for legal or administrative purposes such as our legal defense and to fulfill mandatory legal obligations subject to the applicable law. Keep in mind that the data will be kept anonymously and in aggregate form for an unlimited period of time.

In case of cancellation, resolution or termination of the service contract with us, HolaHome will not retain Third-Party Data unless it is legally required to do so. Otherwise, upon cancellation, resolution or termination, or when it is no longer legally required to store the data, HolaHome will destroy or return all Third-Party Data and its copies.

8. SECURITY MEASURES

We implement security measures and personal data protection systems in accordance with the applicable regulations in order to preserve the confidentiality and integrity of the data and protect against unauthorized access, modification or destruction.

9. YOUR RIGHTS

Under data protection laws, you have the right to: request access to your personal data (commonly known as an access request from an interested party); request the correction of personal data we possess about you; request the deletion of your personal data; refuse the processing of your personal data; request that the processing of your personal data be restricted; request the transfer of your personal data to yourself or to a third party, and withdraw consent at any time for the processing of your data in cases where we depend on consent to process personal data.

You can exercise the aforementioned rights by contacting us at hola@holahome.com.

You also have the right to file a complaint with the relevant authority, in this case the Spanish Agency for Data Protection, C/. Jorge Juan, 6, 28001 Madrid, Spain.

10. GENERAL

We reserve the right to modify the terms of this Privacy Policy and we will inform you clearly about such changes by email, on our website and in this Privacy Policy. If you continue to use our Services after such an update, you will be considered as having accepted the new terms. If you do not accept the update, let us know and we will delete your personal data (except when it is necessary to keep it for legal purposes).

Unless a specific local regulation states otherwise, this Privacy Policy is governed under Spanish law.

Date: Feb 20, 2020.