Our Privacy Statement for interested parties en prospective tenants

Elfi respects your privacy. We value the trust you place in us and will do everything in our power to protect your privacy. In this privacy statement, we explain why we collect certain personal data and how we protect your privacy. In our Cookie Statement, we explain which cookies we use and for what purposes we use them.

Elfi processes personal data from you in various situations:

• When you visit Elfi.nl or another website of Elfi;
• When you are interested in renting a property from Elfi;
  
• When you are a visitor, supplier or other third party;
• When you are a tenant at Elfi;
• When a tenant has provided us with information about you.

This privacy statement consists of two parts:

Privacy statement in brief
Here you can quickly read: 

• which organization is responsible for processing your personal data;
• what the main personal data we process are;
• how you can contact us if you have any questions about privacy.

Detailed privacy statement
Want to know more? Then read the detailed privacy statement. In it, we answer the following questions:

• What are personal data?
• What does the processing of personal data involve?
• When are we allowed to process personal data according to the law?
• What personal data do we process and why?
• When do we share your personal data with others?
• How does Elfi deal with camera surveillance and access registration?
• How does Elfi protect your personal data?
• How long does Elfi retain your data?
• What are your rights?
• How do you contact Elfi?

PRIVACY STATEMENT IN BRIEF
Responsible organization Elfi Vastgoed Holding B.V. is responsible for processing personal data. We are located at Assumburg 2, 1081 GC in Amsterdam, and registered with the Chamber of Commerce under number 88373649.

Main personal data we process:
We process personal data in various situations. Our starting point is that we do not process more information than necessary. These are the main personal data we process:

When you visit an Elfi website, we process this data:

• Your click behavior and other marketing data for which you give permission via the cookie banner;
• Data about your device.
  

If you sign up as an interested party for a rental property at Elfi, we process the following data:

• Username and password;
• First and last name;
• Gender;
• Email address;
• Your housing preferences / criteria;
• The property(ies) you save or sign up for.
  

If you request a viewing, in addition to the data already mentioned above, we may need the following additional information from you and any partner or co-tenant:

• Address;
• Full first names;
• Phone number;
• Date of birth;
• Household composition and marital status;
• Financial information;
• Employment situation.Bovenkant formulier
• Industry in which you work;
• Current housing situation;
• Type of identification and document number;
• The rental period for which you want to rent the property.
  

If you take an option on a property and/or rent a property from Elfi, in addition to the above data, we may process the following data from you and a possible partner or co-tenant:

• copy of your identification document, including its number (not the Citizen Service Number);
• employer statement and copy of employment agreement;
• payment details; • income, asset, and debt details;
• other documents necessary for determining your suitability as a tenant;
• results of various legally required investigations;
• contract terms and rental start date.
  

• To see which other data we (possibly) process and for what purposes we need this data, we refer you to the detailed privacy statement.

Do you have any questions about privacy?
In the detailed privacy statement, we explain how we process your personal data. If you have any questions about this privacy statement, we are happy to help. You can email us at privacy@elfi.nl. You can also reach us at the following postal address: Elfi Vastgoed Holding B.V., Assumburg 2, 1081 GC Amsterdam.

If you believe that your request has not been handled properly or if you have a complaint, please contact us. We will try to resolve it together as soon as possible. Additionally, you always have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP).

The privacy legislation (GDPR) grants you the following rights:

• Right to be informed
• Right of access
• Right to rectification
• Right to restriction of processing
• Right to object
• Right to data portability
• Right to erasure
  

EXTENSIVE PRIVACY STATEMENT

In this extensive privacy statement, we answer the following questions:

1. What are personal data?
2. What does processing personal data mean?
3. When are we allowed to process personal data according to the law?
4. What personal data do we process and why?
5. When do we share your personal data with others?
6. How does Elfi handle camera surveillance and access registration?
7. How does Elfi protect your personal data?
8. How long does Elfi keep your data?
9. What are your rights?
10. How do you contact Elfi?

1. What are personal data?
Personal data contains information that relates directly to someone or that can be traced back to that person. This is stated in the General Data Protection Regulation (GDPR).

2. What does processing personal data mean?
Elfi processes personal data. According to the GDPR, processing means everything you can do with personal data. For example: collecting, viewing, changing, requesting, using, distributing, protecting, linking, deleting or destroying data. This can be done partially or fully automatically, and can also be done manually.

3. When are we allowed to process personal data according to the law?
Elfi processes personal data carefully and transparently. We only process personal data if the law allows us to do so. This is in the following cases:

If you want to enter into an agreement with Elfi If you have seen an interesting property with Elfi or want to be kept informed, you can register as an interested party. By doing so, you enter into an agreement with us and we are allowed to process your personal data. We will then inform you about the properties you are interested in, communicate about viewings, use the data to assess who will be invited for a viewing, determine who will ultimately be awarded a property, and use the data to enter into a lease agreement.

If you have given clear consent to Elfi We may process your personal data if you have given us clear consent to do so. In your profile, fields are marked as not mandatory. If you fill in these fields, you give us permission to use that data. This data is stored as long as your profile is active or until you delete the data yourself.

If you are not allocated a property, you can still use your data and documents for another property for 3 months. This means that you do not have to submit all the documents again for a new viewing. These data are automatically deleted after 3 months. You will receive an email within 3 months asking if you want the documents to be stored for longer. If you choose to do so, the documents will be stored for 1 year.

If you are no longer interested, you can unsubscribe yourself on my.elfi.nl in the privacy menu. Your entire profile will then be deleted.

Even if you upload documents or data that you think may be relevant to the allocation of a property, you give us permission to use these documents or data. However, we will first process the mandatory documents that are requested.

If Elfi has a legal obligation Elfi may process your personal data if we are required to do so by law.

If Elfi has a legitimate interest Elfi may process your personal data if we have a 'legitimate interest' in doing so. This means that it is very important for Elfi to process your personal data. For example, for company security and information security, for good business operations, or to prevent theft and fraud.

We also ask for some of your data before a viewing of a desired property in order to make the process more efficient. It appears that otherwise many unnecessary viewings take place, which is unpleasant for you, but also for the departing tenant. Therefore, we only want to do viewings with people who can and want to rent the property.


4. What personal data do we process and why?
We process personal data in different situations. Our starting point is that we process no more information than necessary. We process personal data in the following cases: If you sign up as an interested party for a rental property with Elfi. Do you want to stay informed about rental properties that will be available soon? Or save your search profile? Then we process the following personal data:

• username and password hash;
• first and last name;
• gender;
• email address;
• housing preferences;
• desired rental period;
• data about your personal living situation;
• the property(ies) you save or apply for;
• the content of messages you have sent to us, such as feedback and product reviews you have written, or questions and information you have provided to customer support. When you contact us, phone calls or chat sessions with our employees may be recorded and monitored;
• data about your device, such as IP address (and associated approximate location data), internet browser and device type, device IDs, login and logout data, regional and language settings;
• data about website usage;
• whether you want to receive updates by email.

If you request a viewing for a rental property, in addition to the above-mentioned data, we process the following personal data of you (and potentially your partner or co-tenant), depending on the specific rental property:

• Initials and title;
• Full first names;
• Address;
• Phone number;
• Date of birth;
• Family composition and marital status;
• Financial information;
• Information about any co-tenants (including name, address, contact information, and gender);
• Employment status (employee with type of contract, self-employed, retired);
• Current housing situation (renter, home sold, homeowner, living with someone);
• Type of identification and document number;
• Rental period desired;
• Country of origin;
• Nationality;
• Specific property for which you are requesting a viewing;
• Images from door or security cameras.
  
  

For homes that generate a lot of interest or have a short turnaround time, we may request further information or documents prior to the viewing that are necessary for the allocation of a home.

Do you want to rent a home and/or take an option on a home with Elfi? Elfi rents and sells homes. As a tenant, you have the option of taking an option on the home. In both cases, when creating a lease agreement or applying for an option on a home, we process the following personal data from you (and possibly from your partner or co-tenant), in addition to the aforementioned information: 

• a copy of your ID including the document number (no Citizen Service Number);
• the relevant property, with all related information;
• financial information (such as income, collateral, assets, and debts/financial obligations);
• information regarding your employer (if applicable); - employer's statement or copy of employment contract if you are employed;
• payment details (payment method, IBAN and verification thereof (e.g. copy of bank statement));
• information regarding alimony or divorce;
• information regarding your business, turnover, and income security
• information regarding social security benefits;
• a declaration of truthfulness;
• industry in which you are employed;
• a photo of you (for identity verification in person);
• declaration about a care indication;
• results of a customer and credit check;
• other statements from you or a third party;
• if you have been a tenant before, we also process information about our past experiences with you (as far as we still have them);
• signature and other signature data;
• other information and documents that you provide to us.

We need these personal data to perform our work properly:

• To address you correctly.
• To keep you informed about suitable properties.
• To better understand the needs of our visitors and users and to tailor our services accordingly.
• To operate our websites and provide users with access to their own data.
• To maintain contact with you in various ways and make arrangements.
• To conduct a financial and creditworthiness assessment and check if you are able to rent a property.
• To enable you to view a property.
• To conduct a tenant screening to assess whether you meet our rental policy and to determine who is granted a property. For more information on this, please refer to our rental terms and conditions.
• To verify your identity. For this, we use various personal data, including a copy of your passport or identity card. Upon delivery of a property, we verify whether the tenant is really the person in the passport or identity card photo.
• To enter into a lease agreement with you. We then use your personal data to enter into and perform this agreement. For more information on this, please refer to our privacy statement for tenants.
• To create access passes for our tenants. We rent out, manage and maintain rental units such as residential and commercial properties, residential complexes, rooms, and parking garages and use your data for that purpose.
• To comply with legal obligations and agreements with other parties, such as the AFM, FIU, tax authorities, police and municipalities. .
• From your data and that of all other (potential) tenants, we also derive statistics that we use as management steering information.
• To protect and secure our business operations and to identify and help minimize or prevent fraud, unauthorized activities, claims, and other liabilities.
• To notify you of changes in policy, documents, and our services.
• To record and handle questions, complaints, and requests.
• To prevent or handle security and usage incidents.

If you are on the negative list
Elfi keeps a negative list for its own use. This list contains the names of individuals to whom we do not (anymore) want to rent, for example because we have determined that they were not honest when applying for a rental property. Or because they did not comply with the rules of the rental agreement. Or because they exhibited undesirable behavior as tenants. We carefully consider before placing someone on the negative list. We examine, among other things, how serious the behavior was. We also consider the likelihood that the tenant will cause the same problems with another landlord. For more information on this, please refer to our privacy statement for tenants.

5. When do we share your personal data with others?
We handle your personal data confidentially, which means that we only share them with other parties in the following cases. In all cases, we will provide as little data as possible.If you have given permission for it If you have given permission for the placement of cookies when visiting our website, we will provide the personal data for which you give permission to the parties mentioned in the cookie policy.

If it is necessary to enter into the rental agreement with you For example, we share your personal data with other parties to verify if you have sufficient income to rent a property.If we have a legitimate interest Elfi may share your personal data if we have a 'legitimate interest' in doing so. This means that it is very important for Elfi to share your personal data. For example, in case of abuse of our systems for reporting, reporting of crimes or a suspicion thereof.If required by law According to the law, we are obliged to share personal data with other parties in some cases. For example, we must share personal data with the AFM, tax authorities or police if they request it.If another party acts on your behalf If you ask another party to communicate with Elfi on your behalf, such as a lawyer, we may share your personal data with this party.

6. How does Elfi handle camera surveillance and access registration?
In some of Elfi's complexes, there are security cameras or we use electronic access registration. We do this to prevent disturbances, crimes, and vandalism, and to protect the residents and their property. Elfi or a Homeowner's Association (HOA) only uses the images and access registration in the following cases: After incidents: to determine the nature of the offense and to identify perpetrators, involved parties, and/or witnesses. If a concerned party specifically requests access to the images on which he/she appears. If there is a reason to do so: to check whether everyone complies with the regulations, rules of conduct, or conditions that apply to tenants. We have established a Policy on Camera Surveillance in which we have clearly defined who has access to the images and what the retention period of images is. You can request these regulations and procedures from the HOA or from Elfi by sending an email to privacy@elfi.nl.

7. How does Elfi protect your personal data?
We take great care to process your data safely, with the goal of preventing unauthorized access to personal data or disclosure of data, maintaining the accuracy of data, and ensuring the proper use of data. For this purpose, we have implemented physical, electronic, and organizational management measures to protect and secure the personal data we process. Unfortunately, we cannot guarantee the effectiveness of these security measures, and nothing in this notice should be construed as an explicit or implicit guarantee against loss, misuse, or unauthorized access, disclosure, alteration, or destruction. How do we protect your personal data that we share with third parties? We enter into a data processing agreement with organizations that process your personal data on our behalf. The agreement states that they handle your personal data as safely and confidentially as Elfi does. If the organization is responsible for properly handling the received personal data itself, prior agreements are made or this is done only if there is a legal obligation to do so. For example, consider the AFM, tax authorities, FIU, FIOD, AIVD, or police. These organizations are themselves obliged to comply with privacy laws and regulations.How do we protect your personal data that we share outside the EU? Elfi does not generally share personal data with organizations based outside the EU (or non-EU countries), but it may happen. We only share your personal data if it is well-protected and secure. We use international guidelines to determine whether this is the case.

8. How long does Elfi retain your personal data?
For personal data, there are sometimes legal retention periods, and otherwise we have determined retention periods ourselves. We do not retain your personal data longer than these periods. We also do not retain your personal data longer than necessary for the purpose for which we processed them.

These are our main retention periods:

• If you sign up to rent from us, but no rental agreement is concluded, we delete all your personal data (and your account) after 1 year of inactivity.
• If we reject your rental application because you were not honest in the application, we retain your name, email address, and reason for rejection for a maximum of 5 years after rejecting your application.
• If you provide us with documents to qualify for a rental home, we delete them within 3 months after rejection, unless you indicate that we should retain the data for one more year.
• If we terminate your rental agreement because you did not comply with the rules, we retain the personal data that we processed for that purpose for a maximum of 5.5 years after the end of the rental contract.
• Data of visitors to our websites are stored for 3 months and then kept anonymized and aggregated.
• We retain data related to received complaints and requests for 2.5 years.

9. What are your rights?
You have the right to access, correct, delete, object, restrict, and transfer the personal data we have about you. You can also withdraw your consent to our processing of your personal data at any time. This means that we had the right to process your personal data, but no longer have that right after you withdraw your consent. Do you want to exercise your rights? If you want to exercise the rights listed above, please send an email to privacy@elfi.nl, or a letter to: Elfi Vastgoed Holding B.V., Assumburg 2, 1081 GC AMSTERDAM.

Do you have a complaint?
If you have a complaint about the processing of your personal data, please contact us using the above information. We will do everything we can to resolve the issue together. If we cannot reach a resolution, you have the right to file a complaint with the privacy supervisory authority: the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10. How do you contact Elfi?
If you have any questions about this privacy statement, we are happy to assist you. You can send us an email at privacy@elfi.nl. You can also reach us at this postal address: Elfi Vastgoed Holding B.V., Assumburg 2, 1081 GC AMSTERDAM. We may change this privacy statement. If we do so, we will inform you about it on our website. We advise you to regularly review this privacy statement.