PURPOSE OF THE PRIVACY POLICY

The purpose of this charter is to inform you in a transparent manner about the way in which the Huuty platform, operated by the company HÜÜTY AND CO S.R.L., processes your personal data (hereinafter referred to as “Personal Data”) as part of its matchmaking services for the rental of spaces between private individuals. The purpose of this notice is to clarify Huuty’s practices regarding the collection, use, protection and disclosure of your personal data, as well as your rights as a user of the platform.

HUUTY processes Personal Data in accordance with Belgian and European regulations applicable to the protection of personal data, and in particular:

• 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 and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “RGPD” ) ;
• The law of July 30, 2018 on the protection of individuals with regard to the processing of personal data.

DEFINITIONS

1) “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;

2) “Processing” means any operation or set of operations which is performed upon personal data or sets of data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

3) “Controller”: the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing operation;

4) “Processor”: the natural or legal person, public authority, department or other body that processes personal data on behalf of the controller;

5) “Recipient”: the natural or legal person, public authority, department or any other body that receives personal data, whether or not it is a third party;

6) “Third party”: a natural or legal person, a public authority, a service or a body other than the data subject, the controller, the processor and the persons who, placed under the direct authority of the controller or processor, are authorized to process personal data;

7) “Consent”: any free, specific, informed and unambiguous expression of will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her may be processed.

CONTACT DETAILS OF THE DATA CONTROLLER AND DATA MANAGEMENT DELEGATE

Data controller

The person responsible for processing your Personal Data is: HÜÜTY AND CO S.R.L. with registered office at 1070 Brussels, Avenue Victor Olivier 10 Box 25, registered with the ECB under number BE0805.645.673 (hereinafter referred to as “HUUTY”).

CATEGORIES OF PERSONAL DATA PROCESSED BY HUUTY

HUUTY may process the following categories of Personal Data:

• Identification data: surname, first name, home address, e-mail address, gender, date and place of birth, place of birth, passport photo, nationality, national register number, signature, language spoken;
• Rental space data: information about rental spaces, such as location, features and photos;

• Browsing data processed when you visit our websites: IP address, data collected via cookies (see below), browsing history, browser type, pages viewed, unique identification numbers, geolocation data.
• Data you volunteer to HUUTY: any information users choose to share with Huuty, which may include preferences, comments, or specific requests.

LAWFULNESS AND PURPOSES OF PERSONAL DATA PROCESSING

HUUTY may process your Personal Data for the following purposes and on the following legal bases:

P URPOSE	LEGAL BASES
User account management: Collection and processing of data to create and manage user accounts, including verification of identity and contact information.	For the performance of a contract
Facilitating transactions: Use of data to facilitate transactions between landlords and tenants, including payment processing and billing.	For the performance of a contract
Communication and support: Communication with users for support, service updates, and important notifications.	Legitimate interests
Service improvement: Analysis of user data to improve the experience on the platform, including personalization of recommendations and optimization of the user interface.	Legitimate interests
Marketing and advertising: Use of data for marketing activities, including the sending of newsletters.	Based on your consent
Website administration: Data processing to manage and maintain the optimal operation of the HUUTY website.	For the performance of a contract Legitimate interests Based on your consent
Security and fraud prevention: Monitoring of platform activities to prevent and detect fraudulent or unauthorized activity.	Legitimate interests
Legal and regulatory compliance: Data processing to comply with legal and regulatory obligations.	To comply with a legal obligation

SHARING PERSONAL DATA

For the purposes described above, HUUTY may share your Personal Data with the following recipients: subcontractors and external service providers.

HUUTY may need to disclose your Personal Data in order to comply with applicable laws, court orders or injunctions, and/or to protect and defend its rights or the rights of persons affected by the processing of such Personal Data.

In each case, HUUTY will ensure that such disclosure complies with the law and safeguards your essential data protection rights.

STORAGE AND TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Your Personal Data is stored in Belgium or elsewhere in the European Economic Area, thus guaranteeing equivalent protection.

However, your Personal Data may be shared with recipients outside the European Economic Area. In such cases, HUUTY makes every effort to ensure that these recipients guarantee adequate protection. This includes measures such as adequacy determinations by the European Commission, standard contractual clauses, internal company rules, or other EU-compliant arrangements.

WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?

In accordance with current legislation, you have a number of rights relating to the processing of your Personal Data.

These rights may be exercised by sending a letter to HUUTY or an e-mail to the following address: …

Right of access

You have the right to ask HUUTY for the Personal Data it holds about you. This right gives you the opportunity to request a copy of all or part of your Personal Data, if you wish.

Right to object

Where the processing of your Personal Data is based exclusively on the performance of one of HUUTY’s public interest missions, you have the right, for reasons relating to your particular situation, to object to such processing.

However, HUUTY may refuse your objection if it can demonstrate compelling legitimate grounds for processing your Personal Data.

Right of rectification

You have the right to request HUUTY to correct information that is incorrect.

Right to limit

You have the right to obtain the limitation of the processing of your Personal Data when:

• You dispute the accuracy of your Personal Data, for a period of time allowing HUUTY to verify the accuracy of such data.
• The processing is unlawful;
• HUUTY no longer needs the Personal Data but they are still necessary for you to exercise a legal right;
• You exercise your right to object for a period of time that allows HUUTY to verify that the legitimate reasons it pursues prevail over yours.

Right to erasure

You have the right to request HUUTY to delete your Personal Data if you are in one of the following situations:

• Data are no longer necessary for the purposes for which they were originally collected or processed;
• You withdraw your consent to the use of your data;
• Your data is processed unlawfully;
• Your data must be deleted to comply with a legal obligation;
• You have objected to the processing of your data and there is no legitimate or compelling reason not to comply with this request.

Right to withdraw your consent

Where the processing of your Personal Data is based on your consent, such consent may be withdrawn.

Right to portability

You also have the right to receive the Personal Data concerning you that you have provided to HUUTY in a structured, commonly used and machine-readable format and the right to transfer it to another controller where the processing of Personal Data is based on your consent or a contract and carried out using automated processes.

Right to claim

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged breach if you consider that the processing of your Personal Data infringes the RGPD.

Belgium:

Data Protection Authority

Rue de la Presse 35, 1000 Brussels

Tel : +32(0)2 274 48 00 – Fax : +32(0)2 274 48 35

Email : contact@apd-gba.be

Website: www.autoriteprotectiondonnees.be

COOKIES

See our cookies policy.

SAFETY MEASURES

In order to ensure the protection of Personal Data processed, HUUTY has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including among others, as required in accordance with Article 32 of the RGPD.

DATA RETENTION PERIOD

HUUTY keeps your Personal Data for the following period:

P URPOSE	SHELF LIFE
User account management: Collection and processing of data to create and manage user accounts, including verification of identity and contact information.	For the time needed to achieve the desired goal
Facilitation of transactions: Use of data to facilitate transactions between lessors and lessees, including payment processing and invoicing.	For the time needed to achieve the desired goal
Communication and support: Communication with users for support, service updates, and important notifications.	For the time needed to achieve the desired goal
Service improvement: Analysis of user data to improve the experience on the platform, including personalization of recommendations and optimization of the user interface.	For the time needed to achieve the desired goal
Marketing and advertising: Use of data for marketing activities, including the sending of newsletters.	Withdrawal of consent
Website administration: Data processing to manage and maintain the optimal operation of the HUUTY website.	For the time needed to achieve the desired goal Withdrawal of consent
Security and fraud prevention: Monitoring of platform activities to prevent and detect fraudulent or unauthorized activity.	For the time needed to achieve the desired goal
Legal and regulatory compliance: Data processing to comply with legal and regulatory obligations.	For the time needed to achieve the desired goal