This Privacy Policy is a fundamental component of the Terms and Conditions that govern the services offered by SKOR ("we," "us," or the "Company") through our website atskortorent.com(the "Website") and our mobile application (the "Application"). In this document, we describe our practices regarding the collection, processing, and safeguarding of personal data for those who utilize our platform.

For clarity and compliance with data protection regulations, we define our users within two distinct categories:

• Landlords: Referring to those users who register or log in to our platform as Landlords: Landlords use our services to access tenant credit information, list properties, and engage with potential tenants.
• Tenants: Encompassing users who register or log in as Tenants. Tenants interact with our platform to explore property listings, access their credit scores, and, when applicable, seek assistance in obtaining financing options.

This Privacy Policy aims to transparently inform you, whether you are an Tenant or a Landlord, about how your personal data is handled within our platform. We emphasize our commitment to protecting your privacy and ensuring that your personal information is used responsibly and in accordance with applicable data protection laws.

By using the Website, Application, or our services, you acknowledge that you have read and accepted the terms of this Privacy Policy. We may update this Privacy Policy as required by applicable laws or for the improvement of our services, and it is your responsibility to periodically review it. If you do not agree with the terms of this Privacy Policy, please refrain from using our services.

1. INTRODUCTION OF SERVICES AND DATA USAGE

   SKOR, through its Website and Application, provides the following services:

   1. Offering Landlords a property rental and management service for property tech solutions.
   2. Facilitating property rental for Tenants.
   3. Assisting Tenants in finding suitable properties within the SKOR network.
   4. Providing access to additional property-related services.
   5. Provide a platform for utility bills payments.
   6. Offering the functionality of monthly rent payment directly to the Landlord through the SKOR platform.
   7. Access to third-party insurance policies through the SKOR platform

   We may also introduce new services and functionalities that we deem relevant to our users.

   This Privacy Policy details our commitment to the responsible management of Tenant and Landlord data in the provision of these services.

2. DATA CONTROLLER

   SKOR (MadRent Ventures, S.L), with a registered address at C/ MONTESA 5 1B, 28006 MADRID and Tax ID - B56523731, is responsible for the processing of your personal data.

   For any inquiries regarding this Privacy Policy or the processing of your personal data, please contact us at info@skortorent.com

3. DATA COLLECTED

   The data we collect falls into two main categories:

   1. Information on Landlords:

      • Identifying information such as name, surname, and passport or ID card details (not public).
      • Contact information including email and postal address (not public unless expressly requested).
      • Property, goods, or services details, including addresses (approximate unless requested), descriptions, and basic conditions.
      • Photographs for property illustration.

   2. Information on Tenants:

      • Identifying personal data, such as names and passport or ID card details.
      • Contact details including email, postal address, and phone numbers.
      • Payment data, including card details.
      • Credit information
      • User-generated content, such as reviews or comments for publication on the Website or Application.

   Any additional information Tenants choose to include in their profiles, such as photographs, workplace, position, hobbies, etc.

   SKOR can collect credit information through a variety of methods, each compliant with data protection laws like GDPR and LOPDGDD. Here's an overview of how this might be done:

   1. Direct information from Tenants

      Tenants may provide financial information directly to SKOR during their use of the service. This can include income details, employment history, financial obligations, and other relevant financial data.

   2. Authorization to access credit reports

      SKOR may request Tenants to authorize access to their credit reports from credit bureaus. This involves obtaining explicit consent from Tenants to retrieve their credit information, ensuring compliance with data protection regulations.

   3. Integration with Financial Institutions

      SKOR might establish partnerships with banks and other financial institutions. With User consent, SKOR can access relevant financial information from these institutions, such as credit history, loan details, and payment records.

   4. Data aggregation services

      SKOR may use data aggregation tools or services that compile financial information from various sources, including bank accounts and financial transactions, with the User’s consent. These tools help consolidate and analyze financial data to assess creditworthiness.

   5. APIs with financial entities

      Application Programming Interfaces (APIs) can be used to securely exchange financial data between SKOR’s platform and external financial systems, with the User's authorization.

4. DATA PROCESSING

   We collect personal, financial, and property-related data from Tenants for house listing and credit scoring purposes. For Landlords, we provide credit scores to assist in making informed tenancy decisions. Additionally, upon Tenants request, we facilitate access to financing options, necessitating the processing of financial data. We also process data for the purposes mentioned in point 5. Purposes of Data Processing, of this policy.

   We collect personal data from Tenants and Landlords through the Website, Application, electronic communications, or forms, as outlined in our Terms and Conditions. Your use of our services and the provision of personal data implies your acceptance of this Privacy Policy.

   If you provide personal data on behalf of third parties, you confirm that you have obtained the necessary consent and agree to transfer this Privacy Policy to them. SKOR is not liable for any claims arising from the sharing of third-party data.

   This Privacy Policy applies exclusively to the Website and Application. SKOR disclaims any responsibility for the privacy and data protection policies of websites or applications accessed through hyperlinks on our platform.

5. PURPOSES OF DATA PROCESSING

   SKOR processes personal data based on the following legal grounds:

   • Service provision: We process data not only to facilitate property rentals for students, but also for:

     • Management of utilities payments: Enabling Tenants to efficiently manage and pay household bills such as electricity, water, internet, among others.
     • Intermediation in insurance policies: Acting as an intermediary to facilitate Tenants in acquiring suitable insurance policies through third parties, ensuring the protection of their data in this process.
     • Payment of rental installments: Offering a secure and reliable platform for the timely payment of rent installments, including transaction management and payment confirmation.
     • Connecting users: We can process certain data to facilitate the connection between students, which now also includes the possibility to share experiences and tips related to household and insurance bill management.
     • User assistance through the website: we can help you to solve your day-to-day doubts with us through the chat implemented on the website.

   • Carry out credit rating of Tenants, so that Landlords can make better informed decisions.

   • Improvement and efficiency: We use data to continually evaluate and enhance all our services, including new payment and insurance services. This involves managing complaints, conducting satisfaction surveys, and developing new features based on user needs and preferences, as well as to analyze data to better understand user needs and preferences, enabling us to personalize and recommend more suitable services, including the best options for bill payments, insurance policies, and rental payment methods.

   • Marketing: In addition to informing Tenants about rental options, we will also contact them with relevant information about payment management and insurance services, always respecting their preferences and rights regarding marketing communications.

     • Compliance with legal obligations: we may sometimes need to process your personal data in order to comply with legislation that applies to us, including tax legislation.

   1. Credit information provided by SKOR to Landlords will be strictly for the purpose of evaluating the User's creditworthiness and suitability for tenancy.

   2. The User acknowledges that SKOR does not assume any responsibility for the decisions taken by Landlords based on the provided credit information. While SKOR provides credit information to Landlords, it does not influence or bear responsibility for the decisions made by Landlords based on this information. Landlords are responsible for their own decisions and compliance with relevant laws and regulations.

   3. SKOR reserves the right to collect, process, and analyze credit information pertaining to Tenants for the purpose of providing credit scoring services. This includes gathering data from credit bureaus, financial institutions, and other relevant sources.

   4. SKOR is entitled to provide credit information to Landlords, strictly for the purpose of assisting them in evaluating the Tenant’s creditworthiness and suitability for tenancy. This provision is subject to the consent of the Tenant, where required by law, and in compliance with GDPR and LOPDGDD.

   5. SKOR commits to ensuring that the credit information it processes and provides is accurate and up-to-date. SKOR will take reasonable steps to rectify any inaccuracies or errors in the credit information in a timely manner.

   6. SKOR will retain credit information only for as long as is necessary for the purposes for which it was collected, in compliance with applicable data retention laws and regulations. Upon the expiry of this period, or upon the User's request where applicable, the data will be appropriately deleted or anonymized.

6. LEGAL BASIS FOR PROCESSING

   In accordance with the provisions of the General Data Protection Regulation (GDPR) and the Ley Orgánica 3/2018, de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD), SKOR adheres to the highest standards of data protection and privacy. The processing of personal data by SKOR is underpinned by the following lawful bases:

   • Managing and facilitating the rental process Contract performance (Article 6(1)(b) GDPR): The primary legal basis for processing personal data of Tenants and Landlords is the performance of the contractual service in order to provide the renting services.

   • Express consent (Article 6(1)(a) GDPR): For specific data processing activities, particularly those extending beyond the basic contractual requirements, such as indepth financial assessments or sharing information with third-party financial institutions, SKOR obtains explicit, informed consent from the data subjects. This consent is revocable at any stage, with the withdrawal not affecting the lawfulness of processing before its revocation. Similarly, explicit consent will also be necessary to carry out advertising and marketing communications, as well as to facilitate the connection between students.

   • Sending commercial communications. Similarly, express consent (Article 6(1)(a) of the GDPR) will also be necessary to carry out advertising and marketing communications.

   • Compliance with legal obligations (Article 6(1)(c) GDPR): Certain processing activities are conducted to fulfill legal obligations to which SKOR is subject. This may include adhering to financial and tax laws, complying with judicial orders, or fulfilling other regulatory requirements imposed upon SKOR.

   • Improvement and efficiency of the services: Legitimate interests (Article 6(1)(f) GDPR): SKOR processes data on the basis of legitimate interests, considering a careful balance between these interests and the rights and freedoms of the data subjects. These interests include but are not limited to the enhancement of our services, prevention of fraud, and safeguarding the security of our IT infrastructure.

   By accepting this Privacy Policy, Landlords and Tenants acknowledge that they have read, understood, and unconditionally accepted its terms during their use of our services. Tenants are responsible for keeping their data accurate and updated. SKOR reserves the right to exclude users providing false or incomplete data and may take any other actions as required by law.

   SKOR is not responsible for damages resulting from false or inaccurate data provided by users.

   SKOR is committed to transparency in its profiling practices. Detailed information about the profiling process, including the involved logic, significance, and anticipated consequences of such processing for the User, will be provided upon request.

   Profiling at SKOR is not solely based on automated processing. SKOR implements measures to safeguard the rights, freedoms, and legitimate interests of the User, including the provision for human intervention in the decision-making process. Tenants have the right to express their viewpoint and challenge decisions made solely based on automated processing.

   SKOR provides an option for the User to opt-out of profiling activities. By opting out, SKOR will use alternative methods, which may include manual processing, for credit assessment purposes.

7. ACCURACY OF DATA PROVIDED BY USERS

   The User guarantees the accuracy of the personal data provided and agrees to inform SKOR of any changes to such data. The User shall be responsible, in any case, for the accuracy of the provided data, and SKOR reserves the right to exclude any User who has provided false information from its services, without prejudice to other legal actions.

   It is recommended that Users protect their data with the utmost diligence using appropriate security tools. SKOR shall not be liable for any theft, illegal modification, or loss of data.

   Any modification or update of the data must be communicated to SKOR through the means of communication provided in this Privacy Policy.

8. DATA SHARING AND INTERNATIONAL TRANSFERS

   1. All data sharing complies with data protection laws and is subject to strict confidentiality terms.

   2. We do not share personal data with third parties for purposes other than those specified in this Privacy Policy. However, other Tenants may access some personal data.

   3. Authorized SKOR personnel and third-party service providers involved in service provision may access data for the same purposes. Access to data by third-party collaborators is regulated by contractual agreements in compliance with relevant regulations.

   4. Data may be transferred to countries outside the European Economic Area, including the United States. To ensure data protection, international transfers adhere to applicable safeguards, such as standard data protection clauses and Data Privacy Framework certification.

   5. Data may also be disclosed as required by applicable laws or competent authorities.

9. DATA RETENTION

   Personal data is retained for the time necessary to fulfill the purposes for which it was provided.

   1. For users registered in the system, SKOR will retain data for the duration of the contractual relationship and, once terminated, for the time prescribed by law.

   2. If the user receives advertising, SKOR will store the data as long as there is mutual interest, and the user can opt out of processing at any time.

   3. For data used for the improvement and efficiency of SKOR, after the legal timeframe, the data will be appropriately anonymized to continue being processed.

   4. For user connections, SKOR will store data as long as there is mutual interest, and the user can opt out of processing at any time.

   Data may be deleted when the Tenants terminate their relationship with SKOR, and the Company determines that services have been satisfactorily provided.

   In all cases, when the user unsubscribes, opposes the receipt of promotional information and updates, or revokes their consent, their data will be blocked for the legally applicable periods in case of claims and subsequently deleted after the expiration of the same.

10. USER RIGHTS

    The users may exercise the following rights at any time through written communication:

    • Access: Obtain information about the personal data we hold about you.

    • Rectification: Correct inaccurate personal data.

    • Erasure: Request the deletion of personal data.

    • Portability: Receive your personal data in a structured, machine-readable format.

    • Limitation of processing: request a restriction of the processing of the data.

    • Objection: Request that we stop processing your personal data.

    The right not to be subject to solely automated decisions, including profiling: the user shall have the right to have the human factor involved in their processing.

    The Tenants retain the right to dispute the accuracy of the credit information provided by SKOR. In such cases, SKOR is obliged to investigate and rectify any inaccuracies in a timely manner, adhering to GDPR and LOPDGDD guidelines.

    Exercise of these rights requires a a request specifying which of these rights is being sought . Send requests to info@skortorent.comor the postal address CL MONTESA 5 1B, 28006 MADRID, SPAIN. You also have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es). Likewise, the user shall have the right to withdraw the consent given at any time without this affecting the processing previously carried out under the protection of this consent.

11. PRIVACY POLICY UPDATES

    SKOR reserves the right to update this Privacy Policy in accordance with applicable laws. We recommend periodically reviewing this policy to stay informed about the processing and protection of your personal data.

12. DATA SECURITY

    The protection of users' privacy and personal data is highly important for SKOR. Therefore, SKOR has taken all available measures to prevent the misuse of user data, allowing access only to authorized personnel.

    SKOR maintains adequate security for the protection of personal data in accordance with applicable legislation and has implemented all technical means at its disposal to prevent loss, misuse, alteration, unauthorized access, and theft of data provided by the User through the Website. However, it is important to note that security measures on the Internet are not impervious.

    SKOR commits to fulfilling the duty of secrecy and confidentiality regarding personal data in accordance with applicable legislation.

    SKOR shall not be responsible for damages and losses that may arise from the User's failure to comply with this obligation.

13. ACKNOWLEDGEMENT & CONSENT

    By utilizing SKOR’s services, Tenants and Landlords acknowledge their understanding and agreement to this Privacy Policy, and consent to the processing of their data as described.

    If you have any questions or concerns about our Privacy Policy, please contact us at info@skortorent.com. .

    You also have the right to file a complaint with the Spanish Data Protection Agency if you believe your rights are not being properly safeguarded.