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ROBY.AI PRIVACY POLICY

 

Roby.AI respects your privacy and is committed to protect the Personal Information that you share with us. We believe that you have a right to know our practices regarding the information we may collect and use when you use the Service or interact with us in another manner through our website (“Website“).

Roby.AI is a web platform that assists letting agencies and property managers in all the different tasks involved in property management, including without limitations, management of guarantees, execution of lease agreements, or payment processing  (the “Services“).

A User may be either an estate agency or a letting agency or a property management company or a build to rent company or a freehold company which has executed an agreement with Roby.AI (“Property Manager“) or a Property Manager’s client, for example a Property Manager’s tenant (“Tenant“) (Property Manager and Tenant together shall be referred herein as “User” or “you“).

For the purposes of European Economic Area data protection law, (the “Data Protection Law“), unless otherwise explicitly set forth in this policy, the data controller of the data processed through the Service is the Property Manager who makes available and permits Tenants to access and use the Service and Roby.AI is the data processor. Thus, the processing of any Personal Data on behalf of the Property Manager will always be subject to the Property Manager’s privacy statement provided to you separately. In some instances, as specified in more detail below, such as the collection of some cookies as part of using the Website or with respect to personal data necessary for the operation of the account setup and login processes of the Website, Roby.AI may be the controller.

 

Who is Responsible for the Processing of Your Personal Data?

The entity responsible for the processing of your personal data is generally the Property Manager. Roby AI Limited is processing your personal data as a processor, and is referred to as “Roby.AI”, “our”, “we” or “us” in this privacy policy.

 

Which Information is Collected on the Website and through the Service

 

Data you give us

The first type of information we collect is individually identifiable information (“Personal Information“). Such Personal Information may be provided to us as part of your use of the Website or throughout the Service provided to you by the Property Manager using our tools and platforms. It may be used to identify an individual, and may include, without limitation, a first and last name, email address, a home, postal or other physical address, other contact information, phone number, IP address, ID, birth date, gender, job title, education history, occupation, employment history, photos, bank account details and other information when strictly needed to provide a service you requested.

The Personal Information, in some cases if the Property Manager chose to, may be of a private and/or sensitive nature (this only refers to data processed through the Service).

The Personal Information collected is provided voluntarily by a Property Manager, a Tenant or as a result of your use of our platform.

 

Anonymous Data for R&D Purposes

The second type of information we collect is non-identifiable and anonymous information (“Non-personal Information”). Non-Personal Information does not enable us to identify the User from which we have collected such information. It may be based on the Personal Data obtained from you as set forth above, but we will only refer to such Personal Data as Non-personal Information after applying anonymization methods that ensure that such information cannot be identified. We may use such Non-personal Information for research and development purposes, artificial intelligence and machine learning processes, statistics and analytics as well as for security purposes with respect to the Website and Service.

 

How We Collect and Use Information

 

Information to operate the Website and Service

We process Personal Information such as name, email address, home address, phone number, photo, date of birth, identification number, employment history, job title, education history, or bank account details in order to allow the Property Manager to provide the Services to Tenants, such as lease agreements execution, guarantees management, payment clearance and processing of the Property Manager to us and of the Tenant to the Property Manager.

Such Personal Information may be collected when you register and open an account on our platform, or when you provide us with such information, whether by entering it yourself or via a Property Manager.

In addition, as a controller, we will process some necessary registration information from you to allow us to technically open an account for you, allow you to login to your account and provide adequate security measures for the operation of the Website. Such information may include your user name, your password, your email address and phone number.

 

Information for Customer Support and Inquiries

We process Personal Information, such as full name, email address, home address, phone number, photo,  identification number, IP address, login, password, address, when you submit inquiries or requests with respect to the Services. We will use such information on behalf of the Property Manager to contact you only for the purposes for which you sent the inquiry and in connection with the Services.

 

Information for Marketing and Promotional Purposes

We may also process Personal Information, on behalf of the Property Manager such as name, email address and other contact information, if you subscribe to the Property Manager’s newsletter or agree to opt-in for advertising and marketing plans, for the purpose of sending you opportunities if you are looking for new available apartments according to your specifications, either with respect to apartments of a specific Property Manager (and in such case the Property Manager will act as controller). We do so only if you have given your explicit, free and informed consent for such purposes to the Property Manager. In line with the GDPR the Property Manager will always give you the opportunity to opt in to the advertising practices and without your consent you will not be added to receive direct marketing or market research information.

 

Information for the maintenance and Improvement of our Website and Services

We may also process your Personal Information, such as web server logs, IP addresses, cookies, pixel tags and web beacons, when you send us inquiries regarding our Services or when you browse the Website, to administrate and improve this website or our Services, for our internal records and for statistical analysis, all as set forth in our Cookie Policy https://roby.ai/cookies-policy/ In such instances, we will act as controller.

In addition, we may process Non-Personal Information or Personal Information which has been anonymized in order to administrate and improve our platform and our Services, for research and development activities, for artificial intelligence and machine learning processes and for security purposes.

 

Cookies, pixels and web beacons

This Website may also process cookies, pixels and web beacons subject to our Cookie Policy available at https://roby.ai/cookies-policy/ You can always change your cookie preferences using your web browser and the instructions in the Cookie Policy.

 

Usage Analysis for Property Manager Portals

Please note that if you are using the Website as an employee or contractor of a Property Manager, the Website may collect cookies, pixels and web beacons, as well as other web activity identifiers which may be attributed to you personally. In such circumstances the Property Manager will be the controller of such processing and the processing will be subject to the privacy statements provided to you by the Property Manager.

 

Legal Basis for Processing

When we act as processors on behalf of the Property Manager, it is the Property Manager’s responsibility, as a data controller, to ensure that the processing of Personal Data is based on lawful grounds for processing. Please refer to the Property Manager’s privacy statement provided to you to review the applicable grounds for processing for each type of processing.

When we act as data controllers, as set forth above, our processing of Personal Information is based on the following:

  1. need to carry out the above processing of information, which is in anticipation of entering into commercial engagements or as part of the performance of existing engagements between a Tenant and a Property Manager, between a Property Manager and Roby.AI or between the Tenant and Roby.AI (as per our Website terms of use), for example for providing a Tenant or a Property Manager the ability to use the Website, register and login to their account.
  2. To the extent that we use the Personal Information to improve this website or for analyzing statistics, the basis for processing of data is either our legitimate interest to conduct such improvements and analysis or your consent, to the extent that such consent may be required.
  3. To the extent that we use the Personal Information to apply appropriate security measures to the Website and Services, the basis for processing is our legitimate interest.

 

Information sharing and disclosure

Because Roby.AI is a part of a global group of companies, your Personal Information may be shared with other Roby.AI offices around the world as well as with its parents, subsidiaries and affiliated companies, such as iagree Ltd. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements.

Roby.AI may share your Personal Information with other companies or people under any of the following circumstances:

We will not sell or otherwise transfer your personally identifiable information that you or a Property Manager provide to us at our Websites to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.

For the above purposes, Personal Information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your Personal Information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

For avoidance of doubt, we may transfer and disclose Non-Personal Information to third parties at our own discretion. We may process Personal Information to make it anonymized and aggregated. Any aggregated data shall belong to Roby.AI provided it is completely anonymized, cannot identify any person or reversed to be considered Personal Information again. We may make such Non-personal Information publicly available or combined with other information provided no such data may identify a person or reversed to be considered Personal Information again.

 

 

Data Retention

Roby.AI stores the Personal Information, including Personal Information it processes on behalf of the Property Manager, as long as it is necessary to fulfil the purpose for which the data has been collected. Generally, this means that Roby.AI deletes your Personal Information after a period of at least seven (7) years as of the date of its collection, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which has been anonymised may be saved thereafter.

Please note that Property Manager, as a Controller, may retain and own Personal Information about a Tenant. If you have any questions about the right of the Property Manager to retain and process your Personal Information you should raise this directly with the Property Manager. You hereby agree not to assert any claim against Roby.AI in this regard and waive any rights regarding such Personal Information including the right to view and control such Personal Information.

 

Data Subject Rights

If you are a resident of the EU/EEA, you may at any time request the rectification or erasure of your Personal Information. Please note however that deletion could mean that Roby.AI cannot process your requests or provide you any requested Services. You have the right to request a copy of your Personal Information from our record. You have the right to request a limitation of the use of your Personal Information (for example if you deem the information to be incorrect) or the termination of use of your Personal Information (for example as regards the use of the information to improve our Services).

Please note that, in most cases, Roby.AI is a processor of data processed through the Service and is not the data owner or controller and may therefore not be able to delete, edit or retrieve your information without controller’s authorization and instructions. Each User hereby agrees and confirms that Roby.AI shall not have any liability or responsibility in connection with actions taken in accordance with controller’s instructions.

If, for any reason, a Tenant wishes to modify, delete or retrieve his/her Personal Information, s/he may do so by using any designated tools included in the Website or by contacting the applicable Property Manager (e.g. your landlord or the property manager managing the leasing of the apartment you are interested to rent). The Property Manager shall perform the necessary process to identify the Tenant as an Tenant who has a the right to retrieve the specific information and then furnish to Roby.AI the data required to be amended, deleted or retrieved together with a specific identification of the Tenant and data (as shall be applicable for the specific Service provided and the requested data). Roby.AI cannot retrieve data without a specific identification of Tenant by the Property Manager.

Please note that Personal Information may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Information, depending on technical commercial capability. Such information may continue to be used by Roby.AI for the purposes set forth above.

For any request or question regarding deletion or amendment of User data, you can contact our DPO at dpo@roby.ai and we shall make efforts to respond and support your request.

If you opted-in to receive marketing communications from us as controllers, you can opt-out at any time by modifying your preferences in the user account section of our website or by contacting us at dpo@roby.ai. You can also opt-out by clicking on the unsubscribe link or following the opt-out instructions included in any related message.

 

Data security

Roby.AI safeguards the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your Personal Information. While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.

 

 Third party sites

Our website may contain links to websites operated by other companies. Roby.AI does not share your Personal Information with those websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies. Some of these third-party sites may have permission to include the Roby.AI logo, even though they are not operated or maintained by Roby.AI. Although we choose our business partners carefully, Roby.AI is not responsible for the privacy practices of websites operated by third parties that are linked to our site. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you. We may provide services based on third party applications and content tools on the Roby.AI website such as DocuSign, Experian, etc. These third parties may automatically receive certain types of information whenever you interact with us on our website using such third party applications and tools, based on such third parties’ privacy statements.

 

Changes to this privacy policy

Roby.AI will amend this policy from time to time. If we make any substantial changes in the way we use your Personal Information we will make that information available by posting a notice on this site.

Privacy Inquiries

Roby.AI is responsible for the processing of your Personal Information, and requests to exercise your rights as stated above shall be addressed to dpo@roby.ai

If you are a resident of the EU/EEA, and have a complaint regarding the processing of your Personal Information by Roby.AI you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.

 

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