Living25 is offering a holistic SaaS product consisting of tenant-facing mobile apps combining features like community, access control, smart home features and a variety of services (the Living25 Platform”).
As one part of the Living25 Platform, Living25 is offering a building administration and management system (the “Living25 Administrator System”) for its customers who administrate buildings (“Building Administrators”) and use the Living25 Administrator System for their own administration purposes and are thus the controller of personal data processed through the Living25 Administrator System. With regard to such data processing, we make reference to the Privacy Policy of the Building Administrator of the building with regard to which the Living25 Administrator System is used.
The Living25 Platform, however, includes services, which are provided by Living25 to you, as a tenant or other user, without involvement of the Building Administrator (the “Living25 User Services”). Therefore, Living25 is the controller of your personal data processed in connection with the Living25 User Services.
1. Name and contact Details of the Controller
By this privacy notice, we, [Living25] would like to provide any user of the Living25 User Services (“you”) with the information required pursuant to Art. 13, 14 GDPR.
You can also reach us at info@living25.io.
2. Purposes of the processing, categories of personal data concerned, period of storage
2.1 When downloading the App, your personal data will be processed by the operator of the app store (Apple App Store or Google Play). We have no influence on this data collection and are not responsible for it. Further information on this data processing can be found in the privacy policy of the app store operators: Google Play Store: https://policies.google.com/privacy?hl=de&gl=de or Apple App Store: https://www.apple.com/legal/privacy/de-ww/.
2.2 Before using the Living25 User Services, you will have to register. You will have to provide the registration data indicated as required in order to complete the registration. If you do not provide such data, we will not be able to conclude the contract with you regarding the use of the Living25 User Services and cannot provide access to the Living25 User Services.
At the time of registration, in addition to the data you enter to complete the registration process, the following data is stored: IP-address of the user and date and time of the registration. We processes your login data to authenticate you when you log in and to respond to requests to reset your password. The registration data will be processed (1) to verify your authorization to manage the user account, (2) to enforce the terms of use of the App and all rights and obligations associated therewith, and (3) to contact you in order to send you technical or legal notices, updates, security messages or other messages regarding the management of the user account.
The legal basis for such processing activities is Art. 6 para. 1 lit. b) GDPR.
The pertaining personal data will remain stored until the user deletes their user account with us.
2.3 Through the Living25 User Services, we process your personal data in order to provide the contractual services as promised in the Terms of Use, in particular to make available the following features: building and appartment access, communications with the building administrator, controlling home technology like lighting, heating, locks and blinds, review metering data from electricity, heating and water meters and allow communication amongst tenants of a building. Therefore, when you use the Living25 User Services, we will automatically process the following personal data: logins and user sessions of a user account by time and date, type of user devices (eg. smart phones), type and version of operating systems used, IP-numbers used to connect to our services. We do not collect, process or store data about the usage of particular services and devices like controlling heating, lights or opening doors.
(comprehensively, the “Use Data”) and messages sent to other users and building administrators including text and uploads like photos, videos and documents, your profile picture (if provided) (comprehensively, the “Content Data”).
The legal basis for such processing activities is Art. 6 para. 1 lit. b) GDPR.
The Use Data will remain stored until the account of the user is deleted and the Content Data until the user account of the user is deleted.
2.4 We temporarily store the Use Data in a so-called log file for the following purposes: Protection of our systems, Error analysis, Prevention of abusive or fraudulent behaviour.
The legal basis for the processing of the listed data is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest follows from the purposes of data processing listed above.
The pertaining personal data will remain stored for 3 months.
2.5 Through the Living25 User Services, your personal data is processed in order to facilitate support requests by users, e.g. in case a feature of the Living25 User Services does not properly function.
The legal basis for such processing activities is Art. 6 para. 1 lit. b) GDPR.
The pertaining personal data will remain stored for 3 months.
2.6 Through the Living25 User Services you may subscribe to our direct marketing offers, in particular the Living25 newsletter, which is free of charge. In such case, we will process the personal data you provide us with and the Use Data for direct marketing purposes. Living25 will contact you by email or push notification with personalized information regarding the building and other services. In this context, Living25 will also process data on your use of direct marketing information (e.g. click behaviour).
The legal basis for such processing activities is your consent, which you have provided us with upon subscribing, Art. 6 para. 1 lit. a) GDPR and our legitimate interests in marketing our and our customer’s products (Art. 6 (1) letter f GDPR, where applicable. Please note that you are entitled to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
This data will be deleted by Living25 following your objection, respectively revocation of any consents given, or otherwise upon the end of your use at the latest, respectively it will only be stored in aggregated, anonymised form. To the extent necessary, Living25 will store the fact that you have objected in order to prevent you being contacted further.
2.7 We process your pseudonomyzed personal data for research and development purposes with the aim of generating non-personal insights allowing us to improve our services and to create new attractive value-added-services.
The legal basis for the processing of the listed data is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest follows from the purposes of data processing listed above.
The pertaining personal data will remain stored for 2 years.
The Living25 System may contain links to other internet presences of Living25 on websites and services of third parties, e.g. to social media channels such as Facebook, Twitter or Youtube. These third parties are exclusively responsible for the data processing by such other service providers on their websites and their data protection notices apply.
3. Recipients in third countries
Living25 does not process data outside of the European Economic Area.
4. Automated Decision Making
The Living25 System does not include any feature with automated decision-making in the sense of Art. 22 GDPR.
5. Security
Living25 takes technical and organisational security measures to protect your personal data managed by Living25 against accidental or deliberate manipulation, loss, destruction or access by unauthorised persons. Our data processing and our security measures are improved on a constant basis according to the technical developments.
During the transfer of your personal data to Living25 it is encrypted with Secure Socket Layer (SSL). Personal data which is exchanged between you and Living25 or other participating enterprises is fundamentally transmitted via encrypted connections which meet the latest technical standards.
Our employees and our retained service providers are naturally obliged to maintain confidentiality.
6. Your rights to information, correction, blocking or deletion
Every natural person whose personal data Living25 processes has, in principle (i.e. depending on the respective preconditions), the following rights vis-à-vis Living25:
(a) Should you have questions regarding our processing of your personal data, Living25 would be pleased to provide you at any time and at no charge with information on the data stored about you (Art. 15 GDPR).
(b) You have a right to the correction of incorrect data as well as completion of incomplete data (Art. 16 GDPR).
(c) You have a right to the blocking/limitation of the processing or to deletion of personal data concerning you which is no longer required or stored on grounds of legal obligations (Art. 17, 18 GDPR).
(d) You have a right to the transfer of the data in a structured, standard and machine-readable format, insofar as you have provided Living25 with the data on grounds of a consent or contract between Living25 and you (Art. 20 GDPR).
(e) You have the right to object at any time to the processing of your data for marketing purposes (cf. Section 2.9 above; Art. 21 para. 2 and 3 GDPR).
(f) You have the right to object to a processing on the basis of legitimate interest, in which case Living25 is entitled to demonstrate our compelling reasons (Art. 21 para. 1 GDPR). Living25 has pointed out above in which cases this right applies.
(g) Insofar as you have consented to a data processing, you can revoke this consent at any time with effect for the future, i.e. the legality of the data processing remains unaffected until the date of the revocation. After a revocation of consent, you may no longer be able to use our services.
Please address your concerns in writing (reference: data protection) or by e-mail to the contact details given herein. Living25 reserves the right to check your identity to ensure that your personal data is not disclosed to unauthorised persons.
Furthermore, you are entitled to file a complaint with a supervisory authority for data protection.
7. Data protection officer
Our data protection officer can be contacted at: info@living25.io
8. Amendments
From time to time the content of this privacy notice may have to be modified. Living25 therefore reserves the right to amend it at any time. When you revisit the Living25 Platform, you should therefore regularly check the privacy notice for updates.
Version April 2021
