Neybor™ is committed to protecting its Users’ privacy and takes its responsibilities regarding protection of personal data very seriously.

This Neybor™ Privacy Policy governs the manner in which Neybor™ collects, uses, maintains and discloses information collected from Users, whether this is on the www.neybor.co website (the “Site”), or the Neybor™ Application, or the Platforms, or for any other Services offered by Neybor™, wherever Users or Tenants are based in the world (referred to in this Privacy Policy as you, your, yours).

It is important for you to read the Neybor™ Privacy Policy before using our Platforms. The Neybor™ Privacy Policy sets out important information about the personal data we might collect to you, or you might provide to us, and how this personal data will be treated.

Before submitting your personal data to Neybor™, you will be asked to accept the terms of the Neybor™ Privacy Policy, for example, by signing the lease. This means that you will be deemed to have accepted the terms of the Neybor™ Privacy Policy.

Neybor may update this Privacy Policy from time to time to ensure compliance with applicable laws and regulations or to reflect changes in our practices regarding the collection, use, and disclosure of personal data. We will notify you of any material changes to this Privacy Policy by posting an updated version on our Site, our Application, or through other appropriate communication channels. Your continued use of our Site, Application, or Services after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of the revised Privacy Policy.

If you have any queries about how Neybor™ processes your personal data or if you have any questions about the Neybor™ Privacy Policy, please let us know via the contact details set out below. Your acceptance of this Privacy Policy will not affect your ability to freely give or withdraw your consent to our processing of your personal data, where we rely upon consent as a ground for processing.

Neybor Services SRL

Head office: Chaussée de Boondael 365, 1050 Brussels

VAT number: BE 0744.870.126

hello@neybor.co

We are responsible for the processing of your personal data that we use in the context of the provision of our products and/or services. If you have any questions or comments on this subject, do not hesitate to contact us at hello@neybor.co.

(Hereinafter, “Neybor” or “we”)

You will find below the types of personal data we use, the persons concerned by the collection and use of this data, how we obtained it, how long we keep it, our legal basis for processing this data and why we use it (purpose), and with whom we share it.

"Become a Neybor" form on our website

Who is affected by the collection and use of personal data? The person who contacts Neybor in order to receive information (i.e. the potential tenant)

What personal data? Surname, First name, Age, E-mail address, Telephone number, Information related to the desired move-in (eg. date of entry, duration of rental, type of room, location of the house)

How did we get them? Directly by the persons concerned in the context of the negotiations and the execution of the lease contract.

How long do we keep them? During the time of the execution of the lease increased by the durations of legal prescriptions. If the tenant finally decides not to conclude a lease contract with Neybor, we keep the data for a maximum period of 1 year. After this period, we delete the data.

What purpose? These data are essential to conclude a lease contract (i.e. know the identity of the tenant, ensure that the person is of legal age to conclude a lease contract and be able to contact him). Know your audience and be able to better advise tenants on the choice of houses.

What legal basis to do so? The execution of a lease contract or pre-contractual measures and the legitimate interest of Neybor.

Who do we share them with? With the website host (subcontractor) and our CRM (subcontractor)

Registration via our website to receive our newsletters

Who is affected by the collection and use of personal data? The person who communicates his email address to receive the newsletters.

What personal data? E-mail address

How did we get them? Directly by the persons concerned who wished to communicate their e-mail address to us in order to receive our special offers by e-mail.

How long do we keep them? During the time of our activities and as long as we do not receive a request to withdraw consent (opt out).

What purpose? to send our newsletters.

What legal basis to do so? the consent of the person, which can be withdrawn at any time by contacting us by e-mail hello@neybor.co or by clicking on the unsubscribe link which is at the end of each email containing our newsletter.

Who do we share them with? Mailchimp (subcontractor)

1st call between Neybor and the potential tenant (prospect)

Who is affected by the collection and use of personal data? The person who contacts Neybor in order to receive information (i.e. the potential tenant)

What personal data? Nationality and its maximum budget to rent a room

How did we get them? Directly by the people concerned via our 1st call.

How long do we keep them? During the time of the execution of this lease increased by the durations of legal prescriptions.

What purpose? The maximum budget for renting a room is essential information for concluding a rental contract. Nationality is crucial for Neybor who aims to know his tenant and his culture in order to create a true international community based on respect and intercultural exchanges. (i.e. know the identity of his tenant and be able to contact him).

What legal basis to do so? The maximum budget for renting a room is necessary for the execution of a lease contract or pre-contractual measures. The Nationality is collected on the basis of the legitimate interest of Neybor who wishes to know his tenant and his culture in order to create a true international community based on respect and intercultural exchanges.

Who do we share them with? With our CRM (subcontractor).

In order to reserve a room in a Neybor house

Who is affected by the collection and use of personal data? the person who wishes to reserve a room (potential tenant)

What personal data? ID or passport at the choice of the tenant (be careful, the national register number must be made unreadable by the tenant before communicating his document to Neybor), address, bank information to block the guarantee and proof of solvency at the choice of the prospect (i.e. letter from a guarantor, bank account statement, or employment contract). When the tenant decides to communicate his employment contract, the latter must make the name of his employer and the other non-useful data illegible, namely those which are not used by Neybor to assess his financial capacity to pay his rent.

How did we get them? Directly by the persons concerned who wish to book a room.

How long do we keep them? During the time of the execution of this lease increased by the durations of legal prescriptions.

What purpose? These data are essential to conclude a lease contract (i.e. information allowing to confirm the identity of the candidate lessee and his legal and financial capacity to sign the lease), to know the identity of his tenant and to ensure the solvency of the tenant).

What legal basis to do so? Execution of a lease contract or pre-contractual measures.

Who do we share them with? Our booking platform (subcontractor), our CRM (processor) and our banks (separate controller).

Tenant at Neybor

Who is affected by the collection and use of personal data? The tenant at Neybor.

What personal data? Banking information (rent, bank account number, etc.), date and time of entry and exit of tenants in their Neybor house and in their room.

How did we get them? Directly by the people concerned who are tenants at Neybor.

How long do we keep them? During the time of the execution of this lease increased by the durations of legal prescriptions.

What purpose? Banking information This data is essential for the execution of the lease contract (i.e. paying the rent), the security of our tenants. For data such as the date and time of entry and exit of our tenants, this data is essential to ensure the safety of our tenants. Given the sensitivity of this data, data will only be used in exceptional cases and only when strictly necessary and proportionate to the situation, for example only in the event of an incident (e.g. theft, damage, etc.).

What legal basis to do so? Banking information is necessary for the execution of a lease contract or pre-contractual measures. Regarding the date and time of tenants entering and leaving their house, this data is collected on the basis of Neybor's legitimate interest in order to guarantee the security of tenants (see purpose above).

Who do we share them with? Our CRM (subcontractor), our booking platform (subcontractor), our banks (separate controller) or our payment facilitator (subcontractor) or our door opening and closing provider (subcontractor).

Events

Who is affected by the collection and use of personal data? The tenant at Neybor.

What personal data? Preferences in terms of events via surveys, contact information (email, sms, WhatsApp, etc.).

How did we get them? Directly by the people concerned who are tenants at Neybor.

How long do we keep them? 5 years.

What purpose? We ask our tenants to tell us their preferences in terms of events in order to choose our next activities (via surveys). We use their contact information to keep them informed of our activities.

What legal basis to do so? The legitimate interest of Neybor.

Who do we share them with? Typeform (subcontractor).

Neybor App (developed by Obeyo)

Who is affected by the collection and use of personal data? The tenant at Neybor using the app.

What personal data? Name, pictures, short biography, country of origin, language, interests, device and usage data such as IP address, device type, operating system, app usage statistics, and location data (if permission is granted by the user).

How did we get them? Cfr. above depending on the personal data concerned, and through the use of the Neybor app.

How long do we keep them? Cfr. above depending on the personal data concerned, but maximum 5 years after the end of the use of the app by the tenant.

What purpose? Cfr. above depending on the personal data concerned. In addition, we use device and usage data to improve app functionality, user experience, and security, as well as to provide personalised content and offers.

What legal basis to do so? Cfr. above depending on the personal data concerned. For device and usage data, we rely on the legitimate interest of Neybor.

Who do we share them with? Cfr. above depending on the personal data concerned. For device and usage data, we share this information with Obeyo (subcontractor) and other third-party service providers for analytics and app optimisation purposes.

At the exit of a Neybor tenant

Who is affected by the collection and use of personal data? The tenant who terminates his lease contract and leaves a Neybor house.

What personal data? Preferences, aspects they liked or disliked in the house or in our organisation.

How did we get them? Directly by the people concerned who are tenants leaving a Neybor house.

How long do we keep them? 5 years.

What purpose? When the tenant leaves, we ask them via surveys what they liked or disliked in the house and in our organisation in order to improve our products/services.

What legal basis to do so? legitimate interest of Neybor.

Who do we share them with? Typeform (subcontractor).

Guarantee of a legitimate and secure process of your personal data

Your personal data is solely processed for the legitimate purposes above. Your personal data is collected and processed in an appropriate, relevant and non-excessive manner, and is not kept longer than necessary to achieve the intended purposes.

Right to access

If you can prove your identity, you have the right to obtain information about the processing of your personal data. Thus, you have the right to know the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data is transmitted, the criteria used to determine the data retention period, and the rights that you can exercise on your personal data.

Right to rectification of your personal data

Inaccurate or incomplete personal data may be corrected. It is primarily the responsibility of the User to make the necessary changes in his "user area" himself, but you can also request us in writing.

Right to erasure (or “right to be forgotten”)

You also have the right to obtain the erasure of your personal data under the following assumptions:

- Your personal data is no longer necessary for the intended purposes;

- You withdraw your consent to the processing and there is no other legal ground for processing;

- You have validly exercised your right of opposition;

- Your personal data has been illegally processed;

- Your personal data must be deleted to comply with a legal obligation.

The deletion of personal data is mainly related to visibility; it is possible that the deleted data are still temporarily stored.

Right to limitation of processing

In certain cases, you have the right to request the limitation of the processing of your personal data, especially in case of dispute as to the accuracy of the data, if the personal data is necessary in the context of legal proceedings or the time required to Neybor to verify that you can validly exercise your right to erasure.

Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes. Neybor will stop processing your personal data unless it can demonstrate that there are compelling legitimate reasons for the processing which prevail over your right to object.

Right to data portability

You have the right to obtain any personal data which you have provided us in a structured, commonly used and machine readable format. At your request, this data may be transferred to another provider unless it is technically impossible.

Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

How to exercise your rights?

If you wish to exercise your rights, you must send a written request and proof of identity by email to Neybor : hello@neybor.co. We will respond as soon as possible, and no later than one (1) month after receipt of the request.

In cases where personal data is transferred to countries outside the European Economic Area (EEA), Neybor ensures that appropriate safeguards are in place to protect your personal data in accordance with the GDPR. These safeguards may include the use of Standard Contractual Clauses or the transfer to countries providing the same adequate level of protection.

If you have any questions or concerns about this Privacy Policy or the processing of your personal data, please contact us at:

Neybor Services SRL

Email: hello@neybor.co

Address: Chaussée de Boondael 365, 1050 Brussels

You can also lodge a complaint with the competent authority:

Belgian Data Protection Authority – Autorité de protection des données (APD)

contact@apd-gba.be

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