LAST UPDATED: 01/02/2023
This privacy policy describes how we collect, use, process and transfer your personal data, for what purpose and what is its legal basis. All in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR).
For your information, MYCOORDINATE S.L. is the legal data controller, i.e. who is responsible for protecting the privacy and security of your personal information.
1. Contact details
MYCOORDINATE S.L., (hereinafter “MyColiving”) has its registered office at Calle Pintor Sorolla, 23, 46183 La Eliana and its VAT number is B-42916023.
For any matter related to the processing of your personal data, please contact info@mycoliving.es, our privacy team or the Data Protection Officer, depending on the case, will assist you as soon as possible.
If you wish to delete your personal data and unsubscribe from any communication you can also do so by emailing info@mycoliving.es.
2. What data do we collect?
2.1 Data provided by you
a) Registration as a tenant and information necessary to make a reservation request: If you make a reservation request you provide us with your name, email, telephone number, your date of birth, gender, nationality, identity document, current address, professional or academic information, a brief description about yourself, salary (if you have one) and your credit card or PayPal (or other means of payment) details. Additionally, in certain cases, we may ask for your identity card, passport or driver’s license, proof of solvency and/or proof of residence. If to be eligible you need a guarantor (e.g. parents) or if a third party has paid for your reservation, you must provide the latter information from the guarantor or third party payer. By providing us with this information, you must ensure that your guarantor consents to the processing of such data by us.
b) Other data or documents requested ad hoc: On certain occasions, either to resolve complaints, disputes or suspicions of fraud, payment problems or some other matter related to the provision of the service, either by telephone, via chat, email or through third party provider platforms, we may request the following documents/information; proof of address, proof of identity (passport or national identity card), proof of right to rent the property, academic documents, police reports, death certificates, bank statements, proof of payment, selfies, videos, your voice, etc. If as indicated in section a) If to be eligible you need a guarantor or if a third party has paid for your reservation, you must provide the latter information from the guarantor or third party payer.
c) Contracts: In order to sign the lease contract between owner and tenant it is necessary for both parties to complete the following information: first and last name, ID/Passport, address, email and telephone.
d) Contests, raffles and promotions: We periodically carry out commercial actions where in order to participate, you must provide us with certain personal data. The data collected varies depending on the action.
e) Work with us: In order to apply for any of the vacancies, you must provide name, surname, telephone, email, CV, cover letter and other optional information such as presence in social networks, promotional video or others.
f) Satisfaction survey: At the end of the stay we can send a satisfaction survey to both owners and tenants. The data obtained are first name, last name, email, age, nationality and degree of satisfaction.
2.2 Data we collect automatically
Google Analytics: While you browse or interact with the content of our website or the App, through Google Analytics we collect certain information or dissociated data such as the IP address of your device, the type of device and browser used, screen size, geographic location, language used, websites visited and date and time they have been visited.
3. What will we use your personal data for?
3.1 For the provision of our services
So that we can show the landlord that you are a suitable tenant, we give you the option of giving us a brief description of yourself. In addition, we ask you for documentation proving your identity and solvency so that the landlord can accept your reservation request.
Manage reservations, payments, check-in and check-out of tenants.
Facilitate the signing of the lease, without complications. For this it is essential that you provide the necessary information.
Contact you to give you information related to a reservation request. These communications can be made by e-mail, telephone or text messages. The form of communication chosen will depend on the reason for the communication.
To provide you with the best care and assistance. The referred assistance can only be provided if we have your personal data.
Resolve complaints, help tenants to find accommodation and mediate in disputes that may arise between tenant and landlord.
Any other matter related to the provision of the service.
3.2 To keep you up to date with our news, promotions and competitions.
We will use your Personal Data to send you news, products and promotions related to MyColiving. In any case, please note that you can unsubscribe from such communications at any time by sending an email to info@mycoliving.es.
3.3 To prevent fraud
In order to create an environment of trust for you, MyColiving, its partners and suppliers, we may use your personal data for the detection and prevention of fraud and other illegal or unwanted activities. Similarly, we may use such personal data for risk assessment and security purposes, including user and property authentication. For such purposes, we may need to quarantine certain reservations or reservation requests until we have completed 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 cross-reference it with data we already have. For example, we may verify or authenticate all personally/business identifiable data, such as your first and last name, date of birth, cell phone number, address, ID, etc. To do so, we will perform checks against databases and other third party information sources, such as fraud prevention agencies, telecommunications providers and identity verification solution providers. Similarly, we may verify your cell phone number with your cell phone provider to prevent SIM swap fraud and we may verify the authenticity of your property photos through third party providers.
In addition, we use third parties to process payments or provide bill collection services. Where a payment issue or problem arises in connection with your booking on MyColiving, either by you or by the legitimate holder of the payment method used to make the payment, we need to share certain details of the booking request with the relevant payment service provider and/or financial institution to handle the request. This may also include a copy of your booking request confirmation or the IP address used to make the booking request and other relevant information. We may also share information with relevant financial institutions if we deem it strictly necessary for fraud detection and prevention purposes.
We also use for fraud prevention purposes information about how you use and interact with our website, application or services, including the device you use. This helps us to monitor the security of the platform and control potential fraud and improve the service you receive from MyColiving.
We also use details about how you use and interact with our website, application or services, including the device you use, for fraud prevention purposes. This helps us track security and fraud and improve our service to you. You authorize your wireless carrier to disclose your cell phone number, name, address, email, network status, customer type, customer file, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber device and status details, if available, to our third party service provider solely to verify your identity and prevent fraud for the duration of the business relationship between our marketplace and to whom we digitally introduce you, i.e. tenants/landlords.
3.4 To reclaim unpaid amounts
In the event of non-payment, the data relating to the debt and the user may be communicated to third party companies specialized in the recovery of unpaid amounts. These third party companies are duly authorized and will be in charge of managing the non-payment of monetary obligations. Also, the companies are contractually obliged to protect your personal information, having access to it to perform this task entrusted to them.
3.5 To improve our service
At MyColiving we are constantly working on improving our services and, for this reason, we carry out tests, user interviews, research and analytical studies and develop new products that result in improving the quality of the service. It allows us to optimize it, improve its usability, make it more functional and adapt it to your needs. Such work often requires the use of some of your personal data or dissociated data obtained through, for example, Google Analytics.
In addition, through the satisfaction survey and reviews, we analyze where we can improve to provide a better experience and avoid recurring problems or bad experiences.
3.6 To manage your application in our selection processes
In order for you to apply for any of the published vacancies and for us to manage the selection processes, we need your data.
4. What is the legal basis for this data processing?
The legal bases that allow us to process your data for each of the purposes indicated in the previous section are:
4.1Contractual relationship: this is the one that applies when you use our service (3.1).
4.2 Legitimate interest to prevent possible fraud (3.3) .
4.3 Your consent: By ticking the box on the contract, you have authorized us to process your personal data for all other purposes.
5. How long will we keep your data?
In general, data that are necessary for the provision of the service will be kept for as long as necessary for this purpose or until you expressly request us to delete them. However, they will be kept “blocked” for a period of 6 years at the disposal of the public administration, judges and courts, for the attention and defense of possible liabilities arising from the treatment.
We may retain some of your personal data to the extent necessary for our legitimate interests, such as detecting and preventing fraud. The data collected for this purpose will be kept blocked for a period of 10 years at the disposal of the public administration, judges and courts, for the attention and defense of possible liabilities arising from the processing.
The data used to send you news and promotions, we will use them until you ask us to stop doing so.
Data relating to your candidacy in selection processes will be kept for a period of 6 months and we will ask your permission to keep it for a further 6 months, otherwise we will delete it from our system.
Finally, we will keep the data necessary to improve our service for a maximum period of 1 year.
6. With whom do we share your data?
6.1 With tenants and owners
In order to handle booking requests and subsequent stays, it is essential that we share certain information, including your personal data, as indicated below:
Each time you, as a tenant, submit a reservation request, we share certain information about you with the owner, such as your profile and documents proving your identity and creditworthiness.Once your reservation is confirmed, we will share your contact details with the owner.
Each time you, as the owner, have a confirmed reservation, we will share with the tenant your full name, contact details and full address of the property to coordinate the reservation.
6.2 With suppliers necessary for the provision of the service
Suppliers who help us with different issues related to the service. These may be located inside or outside the European Economic Area (“EEA”). If they are outside the EEA, we make sure that the recipient country is declared of adequate level by the European Commission and in the case of the USA, that the entities are attached to the Privacy Shield or Privacy Shield.
By reason of the service, these providers have limited access to your personal data to perform certain tasks on our behalf and are contractually obliged to protect and use it only in accordance with our instructions. To this end, MyColiving has signed the relevant processor contracts and verified that they meet sufficient safeguards to implement appropriate technical and organizational measures, so that the processing is carried out in accordance with the requirements of the GDPR, ensuring the protection of your rights.
Service providers may help us, for example, to do the following:
Process payments. (We use third parties to process payments, handle potential errors that may arise in connection with payment or provide billing and collection services. We will share information with relevant financial institutions if we deem it strictly necessary to detect or prevent fraud).
To provide customer services.
Store information securely.
Send marketing communications.
To perform product development, maintenance and troubleshooting tasks.
To prevent fraud.
To collect and recover debts.
To verify or authenticate your identity and address. (To do so, we share your personally identifiable information with third parties. These checks or matches will be reflected in your credit file. This is only visible to you and such third parties -our suppliers-. This does not affect credit reporting. These checks are not likely to be visible to or relied upon by other organizations, such as banks, to make decisions about risks (e.g. loans).
6.3 Competent authorities
We will disclose your personal data to governmental authorities to the extent required by law or strictly necessary for the prevention, detection or prosecution of criminal acts and fraud, or in any other legally mandatory case. We may need to disclose personal data to competent authorities to protect and defend our rights or property, or the rights and property of our employees or users.
7. Confidentiality and security
MyColiving uses all reasonable efforts to maintain the confidentiality of personal information that is processed through the Website and the App. We maintain strict levels of security to protect the personal data we process against accidental loss and against unauthorized access, processing or disclosure, taking into account the state of technology and the nature and risks to which the data is exposed. However, we cannot be held responsible for your use of the data you use on MyColiving outside of our website.
8. What are your rights?
In accordance with applicable law, you may exercise the rights that we will announce in this section, free of charge and at any time. Please note that we may ask you to verify your identity before taking any action related to your request.
To exercise any of your rights, simply send an email to info@mycoliving.es.
Please note that we will try to deal with your request as soon as possible, but we would like to warn you that the maximum period established in the RGPD to deal with such rights is one month from the date of request.
For your information, you have the following rights:
Access: You have the right to know if we are processing your personal data or not. If so, we will give you access to the data we are processing, the recipients of such data (if any), the storage period and the purpose of processing, among other issues.
Rectification: You can ask us to modify data that is inaccurate or incomplete. In your request you must indicate which data you are referring to, as well as the correction to be made.
Deletion: You can ask us to delete the Personal Data we have about you (i) when they are no longer necessary for the purpose for which we use them, (ii) when you withdraw your consent, in the event that we only treat them to develop purposes based on it. However, we warn you that in certain occasions we must keep your data blocked for a certain period of time due to legal obligations.
Portability: You can ask us to deliver directly to you or to deliver to another entity, whenever technically possible, a structured file, commonly used and readable by a computer system, containing your personal data.
Restriction: You may ask us to temporarily restrict the use of your Personal Data (i) when you believe that your data is inaccurate, until we verify or update it (please note that, in the meantime, you will not be able to enjoy the Service); (ii) when we no longer need it to carry out the purposes set out in paragraph 4 above but you prefer that we keep it so that you can exercise or defend yourself against claims and (iii) when you object to our use of your data for any of the purposes set out in number 2 of paragraph 4 of this Privacy Policy, while we assess whether the legitimate interest we have in MyColiving prevails over your right to object to our use of your data.
Opposition: You may object to our use of your data to send you commercial communications. We inform you that we use automated data processing so there is no option to object.
Finally, we inform you that you can file a complaint with the competent supervisory authority on data protection, which in your case in the Spanish Agency for Data Protection.
9. May we modify this Privacy Policy?
Yes, that is why we ask you to check from time to time to see if there are any changes. Please note that if for any reason we decide to make a material change, we will inform you by e-mail.
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