Last update: 13 May 2020
For your information, SPOTAHOME S.L.U is the legal person responsible for the processing of data, i.e., is in charge of protecting the privacy and security of your personal information.
The address of SPOTAHOME S.L.U (hereinafter “Spotahome”) is calle Vizcaya No. 12, postal code 28045, Madrid, and holds the following tax identification code (CIF): B-87004511.
You may contact at [email protected]. For any matter related to the processing of your personal data, please contact us via email at [email protected], and our Privacy team (or the Data Protection Officer, where applicable) will reply to your query at the earliest convenience.
2.1 Data provided by you
a) Registration as a tenant and information required to make a booking request: In order to create a user account, you need to provide us with your name, last name(s) and email address. You may as well register via Facebook or Google. If you make a booking request you will have to provide us with additional data such as name, surname, date of birth, gender, nationality, professional or academic information, a short description about yourself, phone number, salary (if applicable) and your card details or PayPal details (payment method). Additionally, in certain cases, we may ask you to provide (or upload) your Government ID Card , Driving License or passport, proof of funds and residency. If in order to be eligible you require a guarantor (e.g your parents) you shall provide the latter information from them. By providing this information, you guarantee that your guarantor(s) consent to the disclosure of this information.
b) Registration as a landlord and advertisement of the property: In order to create your landlord account, which can be done over the phone or through the website, you need to provide us with your name, surname, email address, phone number, address, ID, the address(es) of the property(ies) you wish to advertise and your bank details (bank account). If you opt in for the self service, you shall also provide photos and listing videos from the property(es) you wish to advertise. In case you want us to issue an invoice, you shall provide us with your Tax ID number (except in the UK) and your postal code, in case you are operating as an individual without a legal entity, or your tax identification number (NIF), your company name and your business address, if you are a business with a registered legal entity or is taxed registered.
c) Required documents (only applicable in Germany and France): Additionally, if you register as a tenant and wish to proceed with a booking request in those territories, you shall upload to our platform a proof of identity, residency and solvency. As in letter a) If in order to be eligible you require a guarantor, you shall provide the latter information from the guarantor.
d) Other data or documents requested ad-hocly: In some cases, in order to solve claims, disputes, suspected fraud, payment processing or any other matter related to the provision of the services, either by phone, chat or email, through our own systems or through third parties’ platforms, we may request the following information/data: proof of identity (passport or national ID card), proof of residency, legal right to let or rent the property, invoice, IBAN, personal/home address, national ID number, academic documents, police reports, death certificates, bank statements, proof of Spotahome purchase, selfies, video recordings, voice, etc. If in order to be eligible you require a guarantor, you may be required to provide some of the referred information from the guarantor.
e) E-contract (only applicable in the United Kingdom and Spain): In order to sign the lease agreement between the landlord and the tenant through the platform, both parties shall fill in the following data: name and last name(s), ID/Passport, address, email and phone number.
f) Contests, raffles and promotions: We regularly perform commercial actions. In order to participate, you shall provide us with some personal data. The data collected shall vary depending on the action.
g) Work with us: If you wish to apply for any of the job positions published on our website, you shall provide us with your name, last name(s), phone number, email, CV, cover letter and other optional information, such as social networks, promotional videos, etc.
h) Satisfaction surveys: At the end of the stay in the property, we send the tenant and the landlord a satisfaction survey. The data collected are the following: name, last name(s), email, age, nationality, and satisfaction level.
2.2 Automatically collected data
a) Registration as a tenant via Facebook/Google: When you register via Facebook or Google, we collect your name, email, date of birth and gender directly from that platform.
b) Google Analytics: While you browse or interact with the content of our website or App, we collect certain dissociated data and information via Google Analytics, such as the IP address of your device, the type of device and browser used, the size of your screen, the geographic location, the language used, websites visited and the time and date they were visited.
For more information on the automatically collected data, please refer to our Cookies Policy.
3.1 To provide our services
3.2 To keep you updated about our news, promotions and contests
We shall use your Personal Data to send you news, products and promotions related to Spotahome. In any case, please bear in mind that you may unsubscribe from these communications at any time. To do so, simply click on the “Unsubscribe” link in any of such communications.
Our Marketing Team is highly proactive and regularly launches campaigns, promotions, contests and raffles, and other promotional actions, and you shall provide certain data in order to participate.
3.3 To prevent potential fraud
In order to create a trustworthy environment for you, Spotahome, its partners and providers, we may use your personal data for the detection and prevention of fraud and other illegal or unwanted activities. Similarly, we may use personal data for risk assessment and security purposes, including the authentication of users and properties. For such purposes, we may have to stop certain bookings or put on hold the requests until we have finished our assessment.
To the extent permitted by applicable law, we may receive additional information about you from third party service providers and/or partners, and combine it with information we have about you. For instance, we may verify or authenticate all personal/business identifiable data such as your name and last name(s), date of birth, address, ID, etc. To do so, we will conduct checks against databases and other information sources from third parties such as fraud prevention agencies and identity verification solution providers. Similarly, we may verify the authenticity of the photos of your properties through third party providers.
Furthermore, we use third parties to process payments or provide billing collection services. When a payment concern or issue is raised for the payment of your booking at Spotahome by either you or by the holder of the debt / credit card used to make the payment, we need to share certain details related to the booking request with the payment service provider and the relevant financial institution to handle the request. This may also include a copy of your booking request confirmation or the IP address used to make it and other relevant information. We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.
We also use for fraud prevention purposes the details about how you use and interact with our website, app or services, including the device you use. This helps us carry out security and fraud monitoring apart from improving the service you get from us.
3.4 To improve our service
At Spotahome we are constantly working to improve our App and Website. This is why we run tests, carry out user interviews, conduct researches and analytical studies, as well as develop new products to improve the quality of our service. By doing so, we are able to optimize it, improve its usability, make it more functional and adapt it to your needs. In many occasions, these activities imply the usage of some of your personal data or dissociated data obtained, for example, via Google Analytics.
Furthermore, through the satisfaction survey, we analyse the existent room for improvement to offer you a better experience and avoid recurring problems or bad experiences.
3.5 To manage your application in our recruitment processes
In order for you to apply for any of the job positions published on our website, and for us to be able to manage the recruitment process, you need to provide some data.
We process your data for the different purposes stated above on the following legal grounds:
4.1 Contractual relationship It is the relationship that applies when you use our service (3.1).
4.2 Legitimate interest: To prevent potential fraud (3.3).
4.3 Your consent: If you are a user who is registered as a tenant or as a landlord, you have authorised us to process your personal data for the remaining purposes by clicking the box on the registration form. In the case of “work with us” you give consent by filling in the corresponding form.
In general terms, data required for the provision of the service shall be kept for as long as they are necessary for this purpose or until you expressly request us to delete them. Nevertheless, such data shall be retained for a period of 6 years at the disposal of public authorities, judges, and courts for determining and defending any possible liabilities arising from the processing.
We may keep some of your personal data to the extent necessary for our legitimate interests such as to detect and prevent fraud. Data collected for this purpose shall remain retained for a period of 10 years at the disposal of public authorities, judges, and courts for determining and defending any possible liabilities arising from the processing.
Data used to send you news and promotions shall be used until you request us to stop using them. Please note that you can request us to stop sending you news, personalised offers, and promotions at any time by simply clicking on the “Unsubscribe” link in any of our communications.
Data regarding your job application in our selection processes shall be kept for a period of 6 months and we shall request your permission to keep them for another 6 months. If you do not agree, such data shall be deleted from our system.
Finally, data required to improve our service shall be kept for a maximum of 1 year.
6.1 With tenants and landlords
In order to manage booking requests and subsequent stays, certain information needs to be shared with other platform users, including your personal data. This is necessary for the due performance of your contract with us, as indicated below:
As a tenant, every time you send a booking request we share certain information about you with the potential landlord, such as your profile and documents proving your identity, residency and solvency (the last two only apply in France and Germany). When your booking is confirmed, we share your contact details with the landlord.
As a landlord, every time you have a confirmed booking, we share with the tenant your full name, contact details and full address of the property to coordinate the booking.
6.2 With our Homecheckers team
If you are a landlord, to schedule the visit to your property with our Homecheckers team (they record videos, take photos and create digital floor plans which are then displayed in our ads) it is necessary to share with them your contact details and full address of the property. All the members of the team have signed the pertinent contract for the processing.
6.3 With companies of the SPOTAHOME Group
We need to give or allow access to your personal data to certain entities of the Spotahome group for service purposes. The entities comprising the Spotahome Group are listed below:
6.4 With necessary providers for the provision of the service
Providers who assist us with various issues related to the services. These providers may be located within or outside the European Economic Area (“EEA”). If they are located outside the EEA, we ensure that the country of destination is declared to have an appropriate level by the European Commission. In the case of the USA, we ensure that the entities are attached to the Privacy Shield.
For service purposes, such providers have limited access to your personal data to perform certain tasks on our behalf and they are bound by contract to protect and use these data solely in accordance with our instructions. To this end, Spotahome has entered into pertinent data processing agreements and verified that these agreements meet the guarantees to implement adequate technical and organisational measures so that processing is carried out in accordance with the requirements of the GDPR, ensuring the protection of your rights.
For instance, service providers may help us with the following:
6.5 Competent Authorities
We shall disclose your personal data to government authorities as requested by law or as strictly necessary for the prevention, detection or prosecution of criminal acts and fraud, or as otherwise required by law. We shall have to disclose personal data to the competent authorities to protect and defend our rights or properties or the rights and properties of our collaborators or users.
Spotahome makes all reasonable efforts to keep the confidentiality of personal information processed through the Web and the App. We have strict security levels to protect the personal data processed from any inadvertent loss and unauthorised access, processing, or disclosure, considering the state of technology, nature, and risks to which the data are exposed. However, we shall not be responsible for your use of the data (including username and password) in Spotahome in platforms other than our Web or App.
In accordance with the applicable legislation, you can exercise the rights detailed in this section free of charge and at any time. We may require you to verify your identity and residency before taking any action related to your request.
To exercise any of your rights you must send an email to [email protected].
Please note that we shall make everything to deal with your request as soon as possible, however we would like to advise you that the maximum period set forth in the GDPR to attend such requests is one month upon the date of the request.
For your information, you can exercise the following rights:
Lastly, we inform you that you can file a complaint with the competent data protection supervisory authority, which in your case is the Spanish Data Protection Agency.
Yes! So please read this policy often to check if there is any update. Nevertheless, we send you an email if we make any material change.
Thanks a lot for reading!
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