Hemavi views all matters concerning privacy seriously and we are fully committed to protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law (as defined below).

This privacy policy (the “Policy”) describes how we collect, use, Process, and disclose your personal information, in conjunction with your access to and use of the Platform (as defined below). It describes our privacy practices for when you communicate with us by e-mail or interact with our website (www.hemavi.se) and/or mobile application(s) (collectively, the “Platform”).

When this Policy mentions “Hemavi” “we”, “us”, or “our”, it refers to Hemavi AB (reg. no. 559277-0670).

The intended recipient(s) of the information provided in this Policy is:

• Anyone subscribing to our newsletter(s) and/or to receive updates and information about Hemavi by way of subscribing on our Platform or through other means; and
• Users of our Platform.

Depending on the context of Personal Data you provide, Hemavi may be the Controller or the Processor of your Personal Data under this Policy.

"Applicable Law" refers to the legislation applicable to the Processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.

"Controller" is the company/organisation that decides for what purposes and in what way Personal Data is to be Processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.

"Data Subject" is the living, natural person whose Personal Data is being Processed.

"Processing" means any operations or set of operations which is performed on Personal Data, e.g. storage, modification, reading, handover or similar.

"Processor" is the company/organisation that Processes Personal Data on behalf of the Controller and can therefore only Process the Personal Data according to the instructions of the Controller and the Applicable Law.

The definitions above shall apply in the Policy regardless of whether they are capitalised or not.

We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we Process your Personal Data. This section aims to describe (i) the lawful bases for Processing your Personal Data, (ii) for how long we keep your Personal Data (storage), (iii) the type of Personal Data we collect, (iv) the methods used for collecting your Personal Data, and (v) the purposes for which we Process your Personal Data.

You are informed that Hemavi may share or transfer your Personal Data to certain third parties (Processors or Sub-Processors), but never for other purposes than for which they were collected in the first place, and always in accordance with Hemavi’s explicit instructions.

Since our products and services require the user to be 18 years of age, we do not collect or Process Personal Data of children.

When we Process your Personal Data, we rely on the following lawful bases:

Legitimate interest: Hemavi may Process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the Processing is necessary for the purpose in question.

Performance of a contract: The Processing is necessary for the performance of a contract entered between us and the Data Subject.

Consent: Hemavi may Process your Personal Data after you have given your consent to the Processing. Information regarding the Processing is always provided in connection to the request of consent. Your consent is voluntary and you can revoke it at any time – you can withdraw your consent online through Hemavi.se. If we wish to use your Personal Data already collected for a purpose other than that for which we had originally consented, we will inform you of the new purpose and request your consent again before we begin data Processing.

If you revoke your consent, we will stop Process the Personal Data for which you have withdrawn your consent, unless we are under a legal obligation not to.

In that case, Hemavi will only store the Personal Data that we are legally obligated or authorized to, and delete other Personal Data about you. If you revoke your consent, it does not mean that the Processing of your Personal Data that has been undertaken before your retraction has been unlawful.

By revoking your consent, you understand and accept that your use of our Platform may be severely affected and we might not be able to provide our services as intended.

Legal obligation: Hemavi will Process your Personal Data where we are required by laws and regulations to do so as a result of our business.

We will keep your Personal Data as long as it is necessary for the purpose(s) for which it was collected. Depending on the lawful basis on which the Processing is supported, this may (i) be regulated in a contract, (ii) be dependent on valid consent, (iii) be stated in legislation or (iv) follow by an internal assessment based on a legitimate interest assessment. In the list below we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.

The Personal Data we collect is used to ensure the quality of our products and services and to help us to get in contact with you, if needed.

There are two general categories of Personal Data we collect: (i) information that is necessary for the use of the Platform and which therefore is required, and (ii) optinal, additional information that you choose to give to us in order to improve your experience when using the Platform.

Information that is necessary for the use of the Platform

We ask for and collect the following Personal Data about you when you use our Platform. This information is necessary in order for us to provide the Platform. Without it, we may not be able to provide you with the requested services.

Account information: When you sign up for an account with our Platform, we require certain information such as your first name, last name, username, date of birth, gender, personal photo and email address. In order for our algorithm to provide accurate data and match you with a roommate you can get along with, we also require certain information regarding your social habits, interests, and lifestyle. Examples of this information are cleaning habits, preferred visiting policy, and preferred traits of a roommate. Some of this information as indicated in your account settings is part of your public profile page, and will be publicly visible to others while some of the information will only be visible to you. We have displayed on your user profile which part of the information is visible and which is not.

Profile and listing information: To use certain features of the Hemavi platform (such as creating an ad for a listing/room and sign an online contract), we may ask you to provide additional information, which may include your city, address, roommate’s preferred gender, listing area, floorplan, amenities and pictures of the listing. With your consent, you can choose to only deactivate your ad. In that case, your ad and all the information submitted with it will be stored on the Platform until you fully delete it. The purpose of the deactivation service is the convenience of not having to create the ad, upload the pictures, and fill in the information from scratch should you wish to make your ad public again. In order to delete your profile and personal information, you can get in touch with Hemavi through the email displayed on your profile settings.

Identity verification information: To help create and maintain a trusted environment, we may ask you to verify yourself using BankID, Facebook, LinkedIn, Spotify, and/or submit the number and/or picture of your identity verification (such as your personal identification number, passport, national ID card, driving license or other authentication information).

Communications with Hemavi and other members: When you communicate with Hemavi or use our Platform to communicate with other members through our internal messaging system, your communication is saved on our Platform.

Automatic housing search agent: With your consent, we can send you relevant housing ads through email and/or phone messages. In order to do that, we collect information regarding your city, budget, number of rooms, etc.

Information you choose to give us

You may choose to provide us with additional Personal Data in order to obtain a better user experience when using the Platform. This additional information will be Processed based on your consent.

Additional profile information: You may choose to provide additional information as part of your Hemavi profile such as language(s), city, employment status, hobbies, Facebook interests, and Spotify top artists. Some of this information as indicated in your account settings is part of your public profile page, and will be publicly visible to others. Providing this information enables us to incorporate it in our algorithm-based matchmaking Process. Thus, we will be able to match you with a roommate of similar interests and lifestyle.

Other information: You may choose to provide us information when you fill in a form, update or add information to your Hemavi account, post or reply to community forums (Ask your Neighboors), participate in promotions, communicate with our customer support team, share your experience with us, or use other features of the Hemavi platform.

In connection with profile data, we have the opportunity to link your personal data with the corresponding data we receive from third parties, such as Facebook and Google. We first obtain your consent to the interconnection. Personal information collected via Facebook is used only when establishing a profile – as stated in the profile editing feature – and is only passed on to a third party with your consent.

You can freely choose to forgo this connection – Hemavi services are fully available even without it.

We collect Personal Data directly from you, as well as automatically through your use of our Platform and, in some cases, from third parties. Below is a list describing how we collect Personal Data.

Information that you give us: The information we collect directly from you is typically contact details and user account information shared by you in connection with registering an account (and profile), and any additional information you choose to share with us through the use of our Platform.

Information collected automatically: When you use or interact with our Platform, we receive and store information generated by your activity, like usage data and other information automatically collected from your browser or mobile device. This information may include information on what type and version of browser you are using, websites from which you have been referred, pages you use on our website, your IP address and a rough location estimate based on your IP address, information about your web activity on our site or your interaction with e-mails we send to you, and information about your use of our Platform.

In most cases, this information is generated by various tracking technologies, which may include "cookies" and/or "web beacons". You can read about how we use cookies and other tracking technologies in our Cookie Policy and also about the choices you can make to limit their use.

Information from other sources: We may receive basic information about you such as name and e-mail adress if an existing user chooses to invite you to the Platform.

#1 - Enable access to the Services

Purpose: Register a user account and profile to enable the user to access the Platform.

Personal Data: Name, e-mail address, password, phone number (optional), profile picture

Source: Directly from the Data Subject.

Lawful basis: The legitimate interest of providing the Platform.

Storage period: As long as the Data Subject holds an account on our Platform.

#2 - Increase security and prevent abuse

Purpose: Verify user login credentials to increase security and prevent abuse.

Personal Data: Name, e-mail address, BankID or other means of verification (e.g. social media account).

Source: Directly from the Data Subject.

Lawful basis: The legitimate interest of verifying the user identity to increase security and prevent abuse.

Storage period: As long as the Data Subject holds an account on our platform.

#3 - Provide our Services

Purpose: Provide our platform and enable users to create and reply to advertisements for rooms.

Personal Data:

Source: Directly from the Data Subject.

Lawful basis: The legitimate interest of providing the Platform.

Storage period: For 12 months from last use (i.e. last time the account holder was logged in to the platform) or as long as the Data Subject holds an account on our platform.

#4 - Support and communication

Purpose: Communicate in order to efficiently help our customers/users with any problems and provide relevant information regarding the Service.

Personal Data: Name, e-mail address, phone number.

Source: Directly from the Data Subject.

Lawful basis: The legitimate interest of providing the Platform.

Storage period: Conversations are stored for as long as the Data Subject has an account on our platform.

#5 - Conducting business

Purpose: Activities to increase awareness of the Platform for sales purposes.

Personal Data: Name, e-mail address, phone number.

Source: Directly from the Data Subject and sourcing.

Lawful basis: The legitimate interest of conducting business and networking.

Storage period: 2 years or until the Data Subject unsubscribes.

You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.

Access: You always have the right to receive information about the Processing of Personal Data that concerns you. We only provide information if we have bene able to fully verify that it is you that are requesting the information.

Rectification: If you find that the Personal Data we Process about you is incorrect, you have the right to have it rectified.

Erasure: You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected.

Objections: If you disagree with any of our assessments, such as that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy, you have the right to object and demand we review our assessment. When making the new assessment, we add your objection to the balance when considering whether Processing your Personal Data can still be justified. If you object to direct marketing, we will immediately delete your Personal Data without making an assessment.

Restriction: You can also ask us to restrict our Processing of your Personal Data (i) while we are Processing a request from you for any of your other rights, (ii) if, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose, such as if you do not want us to send advertising to you in the future, for which we would still need to save your name in order to know that we should not contact you in the future, or (iii) in cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.

Data portability: We may provide you with the data you have submitted to us or that we have received from you in any other way. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manger.

Withdraw consent: If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.

How to use your rights

Send us an e-mail at admin@ and tell us what right(s) you wish to exercise, and we will make sure you can exercise them.

In order to provide our platform and run our business, we may need help from others who will Process Personal Data on our behalf. In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Lawe, by controlling that either of the following requirements are fulfilled:

• The EU Commission has determined that the level of protection is adequate in the third country where the data is processed.
• The Processor has signed up to the EU Commission's standard contractual clauses (SCCs) for data transfer to non-EU/EEA countries.
• The Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable Law.

We have entered into Data Processing Agreements (DPAs) with all our Sub-Processors. The DPAs set out, among other things, how the Sub-Processor may process the Personal Data and what security measures are required for the Processing.

We may also need to disclose your personal information to certain desginated authorities in order to fulfill obligations under Applicable Law or legally binding judgments.

Processor: Amazon Web Services (AWS).

Personal data being processed: All data collected by us (contact details, user account details, financial information, passport details, browser information).

Details: Our servers are hosted with Amazon Web Services at their premises in Stockholm, Sweden. All Personal Data collected by us are stored on their services.

Processor: Google (G Suite, Google Drive, Google Analytics, Gmail).

Personal data being processed: Full name(s), e-mail address.

Details: Google's products help us in different areas. We use Gmail as our e-mail service and Google Drive for document storage. We also use Google Analytics to track how our customers are using our Services to learn more about their needs in order to improve our Services.

Processor: The Rocket Science Group, LLC (Mailchimp).

Personal data being processed: Full name(s), e-mail address.

Details: Personal data collected with Mailchimp is stored in Atlanta, Georgia, United States. The data is transferred securely and in compliance with the GDPR by way of standard contractual clauses (SCCs) alongside the use of appropriate additional security measures.

In practice, this is a set of consents that are related to the individual services on the Hemavi platform. By giving consent to the Terms of Use you also accept Hemavi’s Privacy Policy and at the same time it is given that Hemavi AB can use the designated e-mail address to send so-called Transaction Emails. These include:

• Email confirming agreement
• E-mail confirming payments by agreement
• Email to change password
• Other e-mail that is necessary to fulfill the contract

Transaction Emails cannot be terminated unless the current agreement is terminated.

Approval of the Terms of Use also means that Hemavi has received consent to send Service Emails that may contain help to get a better service through suggested relevant advertisements on the Platform. This could be, for example, emails that give you suggestions for writing a better advertisement, or the opportunity to purchase additional services that can increase your chances of getting a room in a short time.

In connection with the use of our Platform, you can choose to use various functions such as housing search agent email, which also results in you receiving an email to your specified email address. Hemavi also gives you the opportunity to receive newsletters, where Hemavi sends out information about news, events, tips and similar services that can be of help to you as a housing applicant / landlord.

Hemavi has employed technical and organisational measures to ensure that your Personal Data is Processed securely and protected from loss, abuse and unauthorised access.

Organisational security measures: Measures implemented in work methods and routines within the organisation such as (i) internal governance documents (policies and instructions), (ii) login and password management, and (iii) physical security (premises, etc.).

Technical security measures: Measures implemented through technical solutions, such as:

• Encryption
• Access control level
• Access log
• SSL for all outside connections
• 2-step authentication for all sensitive services
• Using password manager for all passwords

Hemavi uses cookies and similar tracking technologies to analyse the use of our Platform so that we can improve them and give you a superior user experience. For more information on how we use cookies

If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Swedish Data Protection Authority (Integrationsskyddsmyndigheten).

More information about our obligations and your rights can be found at www.imy.se.

You may contact the authority via e-mail at: imy@imy.se.

We reserve the right to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in a timely and appropriate manner so that you are able to review the changes beforehand.

Please contact us if you have any questions about your rights or if you have any other questions about how we process your personal information at support@hemavi.com.

You can also write to us at:

Hemavi AB
Adelgatan 21,

211 22, Malmö, Sweden