INFORMATION NOTE ON PERSONAL DATA PROCESSING
STR ASSET MANAGEMENT SRL, headquartered in Bucharest, Calea Floreasca no. 218, District 1, registered at the trade register under no. J40/6566/2019, fiscal registration code 41137103, e-mail: email@example.com, acting as Controller, hereinafter referred to as the “Controller” / “Homey”, hereby informs about the processing of your personal data and about your rights under the national law and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data personal data and on the free movement of such data and repealing Directive 95/46 / EC (“GDPR”).
Personal data means any information concerning an identified or identifiable natural person, and an identifiable person is that person who can be identified directly or indirectly, in particular by reference to an identifying element or to one or more specific factors. for its physical, physiological, mental, economic, cultural or social identity.
Homey undertakes to process your personal data in accordance with the applicable legal provisions, in good faith, in an appropriate, relevant and limited to the purpose permitted by the subject of legal relations between you and Homey.
In order to fulfil the aforementioned desideratum, Homey adopts appropriate technical or organisational measures, as well as security measures. The purpose of this note is to inform you about the way in which the Operator processes your data and the rights granted to you by law.
I. SOURCE OF PERSONAL DATA
The Controller processes the personal data it receives directly from you, when you register on the site to create a membership account to benefit or to provide hosting services, both as a beneficiary or as a partner through our applications, when you provide us with data as part of the administration and personalization of your Homey account profile, when you give us your data and your consent for marketing communications, when you apply for a job through the “Careers” page on the site in order to carry out the recruitment process and employment relationships, as well as indirectly, including from other internal sources, such as your interactions with us through customer service, or automatically, such as online usage data or property data and its use data, and external sources, such as third-party accounts like Facebook, LinkedIn, Google, or from various service providers.
II. CATEGORIES OF PERSONAL DATA
Homey policy is to process only those personal data necessary for the purposes for which they are collected.
The data processed may include the following categories of personal data, but not limited to this enumeration:
- a) Identity data and personal preferences: name and surname, CNP, date and place of birth, domicile/residence address, citizenship, telephone number, e-mail address, series and number of the identity document, date of issue and issuing institution of the card identity, signature, photo, age range, location, Facebook account ID, LinkedIn, Google, Homey account password, booking information, payment and billing information, gender, zip code and individual preferences or demographic information, preferences and requests regarding stay, content communications, the date and time of your message and any attachment to them and other information you provide directly, your criminal record to the extent permitted by applicable law;
- b) Data on education and professional experience: study documents, professional certificates or certificates issued by the competent authorities, experience and references regarding the professional history, as well as any other relevant data from the CV and/or letter of intent;
- c) Online usage data: domain name, browser type, operating system type, name and version, page views, links you click, your IP address, location information, time period you visit or use our services, reference URL, access date and time, mobile device ID, language information, device name and model, and other information about your activities under the services and communications we send you, site browsing history;
- d) Data on the usage of the property: your stay history, information on the usage of an accommodation unit, noise levels (only decibel levels, not conversations).
The storage of personal data is done both hardcopy and electronically, in both situations Homey having implemented security measures to protect them against unauthorized access.
If Homey intends to process your personal data for purposes other than those for which it was collected, it undertakes to provide you with relevant additional information so that any processing of your data is carried out lawfully.
Please note that failure to provide your personal data or the provision of incorrect/incomplete data could lead to the impossibility of concluding and/or executing the accommodation services agreement, as well as the impossibility of performing the services and of fulfilling the legal obligations of Homey or the realization of its legitimate interests, with the consequence of not performing the accommodation services agreement that you intend to conclude / to which you are a party.
III. PURPOSE OF DATA PROCESSING AND LEGAL BASIS OF PROCESSING
Any operation or set of operations performed by manual and / or automatic means, which represent processing activities (collection, storage, registration, structuring, adaptation or modification, extraction, consultation, use, disclosure by transmission, destruction, etc.) of your data shall be carried out in accordance with the provisions of the GDPR, of the national laws on measures implementing the GDPR, as well as in accordance with the provisions of the applicable legislation, only for the following legitimate purposes:
- a) Concluding and executing the accommodation services agreement and the provision of services adjacent to the agreement: to operate, provide and maintain our services, to communicate with you about our services, to respond to your requests, to fulfil our agreement with you, to complete transactions and for other customer service purposes, for creating and customizing your Homey account, to optimize your experiences while using our services;
- b) Fulfilling the legitimate interests of Homey: carrying out marketing communications solely on the basis of your consent, ensuring the quality of the services provided, requesting reviews from Homey members, improving the quality of our services and providing a better experience, researching and analysing preferences for the development of new services, enable certain features of the services to better understand how you interact with the services, and to monitor aggregate usage by Homey members and route web traffic to services;
- c) Compliance with any legal obligation imposed on Homey: taxation; security and safety of the services provided; archiving documents; communication with public or public interest bodies / authorities / institutions;
The processing of your personal data for the purposes mentioned above will be carried out on the basis of one or more of the following legal grounds:
- a) The processing is based on the consent given for marketing communications and other communications regarding the services provided, as well as to track your online activities through cookies and similar technologies. (art. 6 paragraph 1 letter a of the GDPR);
- b) The processing is necessary for the conclusion, execution and respectively termination of the accommodation services agreement, to register and manage your Homey account (art. 6 paragraph 1 letter b of the GDPR);
- c) The processing is necessary in order to comply with a legal obligation incumbent on the Operator, to comply with tax and accounting obligations or anti-terrorism laws (art. 6 paragraph 1 letter c of the GDPR);
- d) The processing is necessary for the purpose of the legitimate interests of Homey, for the purpose of product development and internal analysis purposes and otherwise to improve the safety, security and performance of our services, except in cases where your interests or rights prevail over the interests of Homey (art. 6 paragraph 1 letter f of the GDPR);
- e) The processing of special categories of personal data (e.g., criminal record data) will only be based on your explicit consent to the processing of data for one or more specific purposes (art. 9 paragraph 2 letter a of the GDPR).
IV. CATEGORIES OF RECIPIENTS OF PERSONAL DATA
- a) Our affiliates or subsidiaries
- b) Central and local public authorities, for example fiscal authorities and, by explicit and legal request to immigration offices, customs authorities, anti-terrorist authorities (to protect the property and rights of Homey or a third party, to protect the safety of the public or any person, or to prevent or stop the activity that we may consider to be or to present a risk of being, any illegal activity, unethical or legally enforceable);
- c) Service providers: third party providers, service providers (e.g. IT service providers, accounting services, third party travel services or courier services), contractors or agents performing functions on our behalf, including to facilitate our services, to provide services on our behalf, to perform site-related services (e.g., maintenance services, database management data, web analytics, fraud detection services related to the activity of home users and the improvement of site features), conducting background checks, sending marketing communications, managing job applications that we receive through the career page of our site, to aggregate reviews or to help us analyse how our site and services are used;
- d) Owners and property managers: we will share reports with the hotels where you will be booked, property owners and managers regarding the use of their properties, such as cleaning reports, guest names and residence dates at their properties for security reasons (e.g. to avoid people who are not guests). For long-term rentals, we can share the owners’ name, email address, phone number, ID, birthday, and guest address;
- e) Other business partners: Homey may sell, transfer or otherwise divide some or all of its assets, including your personal data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy;
- f) Public: with your consent, we may post your testimony on the site along with your name.
Homey does not transfer your personal data to countries outside the European Economic Area.
V. STORAGE PERIOD OF PERSONAL DATA
Homey will store your personal data for as long as is necessary to fulfil the purpose for which it was collected, in accordance with the provisions of the GDPR and applicable national law. The storage periods can be determined by reference to the data storage obligations and registers of economic operators, as well as by reference to the applicable limitation periods and the deadlines for compliance with the archiving obligations imposed by national law.
Homey will delete your personal data when this information is no longer necessary for the purposes for which it was collected, unless we are required by law to keep this information for a longer period or there is a need to defend a right in justice.
VI. YOUR RIGHTS AND HOW YOU MAY EXERCISE THEM
the right of access to personal data – the right to obtain confirmation that personal data are processed by Homey and, if so, to be aware of the relevant details of these processing activities;
the right to rectification of personal data – the right to obtain the rectification of inaccurate personal data or the completion of processed personal data;
the right to request the erasure of personal data – the right to obtain the erasure of personal data, in compliance with the legal provisions in force (for example, if the data are no longer necessary in connection with the purposes for which they were collected);
the right to request the restriction of processing – the right to obtain, insofar as the legal conditions are met, the limitation of the further processing of personal data concerning you;
the right to data portability – the right to receive personal data in a structured, commonly used and easy-to-read format, and the right to have this data transmitted by Homey to another data Controller, to the extent that the legal conditions are met;
the right to object – the right to object at any time, for good and legitimate reasons related to your particular situation, to the personal data concerning you being processed, to the extent that the legal conditions are met;
if your consent was necessary for the processing of certain personal data, you have the right to withdraw this consent at any time, which will not affect the lawfulness of the processing before the withdrawal of consent.
In order to exercise your rights, please send us your written, dated and signed request to the e-mail address firstname.lastname@example.org or by mail, at the address in Bucharest, Calea Floreasca no. 218, District 1.
Homey will process any request for personal data promptly, and will be informed no later than one month after receipt of your request about the actions taken to exercise one or more of the rights listed above. However, the aforementioned period of one month may be extended in duly justified cases by a maximum of two months, taking into account the complexity and number of applications received, in which case you will be duly informed within a maximum of one month. month of receipt of your request.
You also have the right to lodge a complaint with Autoritatea Națională pentru Supravegherea Prelucrării Datelor cu Caracter Personal (ANSPDCP), using www.dataprotection.ro.
VII. ABSENCE OF AN AUTOMATED INDIVIDUAL DECISION-MAKING PROCESS
Homey does not use automated decision-making processes to process your data.
This information note is brought to the attention of all persons who visit the site www.homey.com.ro and register with a member account, both as a beneficiary of our services and as a partner in providing them through our applications. In the event of changes in the way personal data are processed, such will also be brought to the attention of the concerned data subjects.