Our Privacy Policy

This page is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

If you want to understand how we use cookies on our website, please visit our Cookie Policy.

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Cohabs™ Privacy Policy

Cohabs™ is committed to protecting its Users’ privacy and takes its responsibilities regarding protection of personal data very seriously.

This Cohabs™ Privacy Policy governs the manner in which Cohabs™ collects, uses, maintains and discloses information collected from Users, whether this is on the www.cohabs.com website (the “Site”), or the Cohabs™ Application, or the Platforms, or for any other Services offered by Cohabs™, wherever Users or Tenants are based in the world (referred to in this Privacy Policy as you, your, yours).

It is important for you to read the Cohabs™ Privacy Policy before using our Platforms. The Cohabs™ Privacy Policy sets out important information about the personal data we might collect to you or you might provide to us, and how this personal data will be treated. 

Before submitting your personal data to Cohabs™, you will be asked to accept the terms of the Cohabs™ Privacy Policy, for example, by selecting YES during the sign-up process or via our Application. This means that you will be deemed to have accepted the terms of the Cohabs™ Privacy Policy.

If you have any queries about how Cohabs™ processes your personal data or if you have any questions about the Cohabs™ Privacy Policy, please let us know via the contact details set out below. Your acceptance of this Privacy Policy will not affect your ability to freely give or withdraw your consent to our processing of your personal data, where we rely upon consent as a ground for processing. 

 

About Cohabs™

The Platforms (described below) are operated by Cohabs™ a company based in Brussels, Belgium, which is in the European Economic Area (EEA) with its registered offices at:

Cohabs Group SRL 

Avenue Louise 222, box 13
1050 Ixelles, Belgium
Enterprise number: 0663.681.72

When we refer to Cohabs™, we mean Cohabs Group SRL and its subsidiaries (also referred to in this Privacy Policy as we, us, our). We provide a new co-living experience centred around flexibility, convenience and happiness through our Platforms where you can log in to navigate different houses, apply to be a Tenant, and deal with housing arrangements and administrations if you are accepted as a Tenant. 

When we collect, use and are responsible for your data you might be a resident in any of the places where we provide co-living experiences, which may be located both inside and outside of the EEA. 

When we provide Services in the EEA or to EEA residents, our handling of your personal data is regulated by the General Data Protection Regulation (GDPR). For the purposes of the GDPR, we are a controller of your personal data. As some of our Services are based in locations outside of the EEA, this means that you might fall outside the scope of European data protection rules, such as the GDPR. However, as Cohabs™ is based within the EEA, we have chosen to generally apply the GDPR standards described in this Privacy Policy across our business as a whole. 

For the purposes of the GDPR, Cohabs Services SA is the appointed representative for any Cohabs™ entity situated outside of the EEA.

Further information on how to contact us is set out below in Section "Questions and How to Contact Us".

 

Definition

Account“ means the profile you create when you sign up to our Platforms which contains all information and content that a registered User has provided on the Platform. This contains personal information, history, complaints, pictures, etc.

Application“ means the Cohabs™ mobile application available in the App Store and Google Play under the name “Cohabs ™” that can be used by the Tenants to log an incident in a house, see other Tenant’s profiles, check information about the house, etc.

Tenant“ means each person who has entered in a rental agreement facilitated by Cohabs™ to live in one of the houses that Cohabs™ manages.

Cohabs™“ means us, a company that manages coliving spaces in the name of landlords by finding tenants, managing their move-in, stay and move-out and tracking payment of rents.

Platform“ means Cohabs’ Site, Application and Services, together the online platforms used by tenants and future tenants to discover Cohabs™, look for a room, apply for a room, subscribe to additional services, sign the rental agreement etc. It is the property of and is managed by Cohabs™ and its subsidiaries.

Services“ means the delivery of accommodation services and real estate management through our Platforms and on-site services.

Site“ means Cohabs’ website available via www.cohabs.com.

User“ means any Tenant, future tenant or any other user that gives their email address or any other personal data on or via the Site or any visitor to the Site or Application and from whom personal information may be obtained directly or via cookies or other technologies, in accordance with this Policy and our Cookies Policy.

What information do we collect?

We collect different categories of personal data depending on the activities to be carried out through the Platforms. We have set out some of the categories of data we might collect and some examples of this data:

  • Identity Data, such as your name, first name, birth date.

  • Contact Data, such as your current address and location, and contact details (such as telephone numbers and email addresses).

  • Financial Data, such as bank details in order to collect rent payments. 

  • Transaction Data, such as the bookings you have made, Services you have requested and rent payments you have made or refunds that have been made to you. 

  • Profile Data, such as your Account.

  • Marketing and Communications Data, such as your newsletter and cookie preferences. 

  • Device Data, such as your IP address and mobile or other device information.

  • Location Data, such as your localization when you use the App and use the map with your own GPS pointer you are when you make bookings.

  • Sensitive Data, such as your photograph or image (including obtained via video footage from our security systems) that you supply to us with your consent or make publicly available.  

  • Technical Data, such as your use of the Platforms, your browser type, and plug-ins. 

Usage Data, such as how you use the Platforms.

We might also collect, use and share aggregated data such as statistical or demographic data. While this could be derived from your personal data, it is not legally considered to be personal data since it will not directly or indirectly reveal your identity. If we ever connect aggregated data to your personal data so that it can directly or indirectly identify you, we will treat this as personal data.

We do not collect special categories of personal data unless provided with explicit consent or unless you provide this voluntarily by making such information manifestly public (for example by adding content to your Account such as text or a photo) or if we have a special reason to, for example when we are protecting the security of our properties with video systems. 

 

How we collect information about you

Cohabs™ collects and processes information in various different ways: 

1. Information Users provide to us; 

2. Information relating to the Users’ use of the Platform; and 

3. Information provided by other sources and third parties. 

 

This is further described below:

1. Information you provide to us

Account: This is information (including Identity, Contact, Financial and Marketing and Communications Data) you consent to giving us when you register to our Platform by filling the online questionnaire to look for a room, when you give us your name and email address, when you fill out your public profile and when you provide us with information such as photos, descriptions of your interests and who you are, when you send us an email or communicate with our customer service on our Platforms, when you are accepted as a Tenant, when you fill rental agreements, when you making a booking, when you move into one of our rooms, when you use the social media functions of our Platforms, when you request Services, and any other such activities offered on our Platforms. By voluntarily giving us this personal information, you consent to such personal information being collected, used, disclosed, and stored by us, in accordance with our Privacy Policy.

Correspondence: This is information (including Identity and Contact) collected when you contact our customer service or anyone of the Cohabs™ staff, in order to keep a record of that correspondence and collect the necessary information to classify your question, respond to it and, if applicable, investigate any breach of our Privacy Policy. While we do not use this information for advertising, we may also use this information to identify and track potential problems and trends, and customise our Services to you.

2. Information we learn about you from your use of the Platform

We may collect or process certain non-personal information or aggregated data such as Device, Content and Usage Data about how and when you use the Platform. This information is usually of a technical nature (device settings and information, including but not limited to the type of browser, Operating System, keyboard language, screen resolution, IP address, location, etc.) and behavioural nature (the actions taken by you on the Platform, including but not limited to access times, pages requested, actions executed, etc.) and is used to compile statistical data about the Use of our Platform. We collect this information using cookies and other similar technologies. Please see our Cookies Policy for more information about this.

3. Information we receive from other sources including third parties and publicly available sources

We might receive the following information as set out below: 

- Device Data from analytics providers (such as Google, based outside the EEA)

- Contact, Financial and Transaction data from Application providers (such as Apple, based within the EEA)

We do not use any automated processing or automated decision-making (such as profiling) in a way that produces legal effects concerning you or otherwise significantly affecting you, other than the automatic lead qualification we use when you apply to be a Tenant.

Purposes and legal bases of collecting information

Lawful basis for collecting information

We are required by law to have a lawful basis for collecting and using your personal data. The lawful basis we rely on will depend on the personal data that has been collected and for what purpose. We might need to process your personal data for more than one specific lawful basis. The lawful bases we might rely on include:

  • Your Consent to receive electronic communications: Cohabs™ may process your personal electronic contact information, i.e. your name, first name and e-mail address, in order to send you personal information, advertisements, activities, news from Cohabs™, our program, our agenda and events or proposals by means of a newsletter. In this case, Cohabs™ will ask for your prior consent.You may withdraw that consent at any time by contacting us (see the Section 10 below);

  • Contract: such as where use of your information is necessary so that we can perform a contract with you, or so that we can take specific steps that you have asked us to before entering into a contract, such as granting you access to the Platform as a Tenant, or providing you with Services;

  • Legal Obligation: such as where use of your personal information is necessary for us to comply with the law (which does not include contractual obligations) such as by complying with applicable tax and accounting obligations; and

  • Legitimate Interests: where use of your personal information is necessary for our legitimate interests of operating, protecting and improving our business (unless there is an important reason to protect your personal information which overrides our legitimate interests).


Please be aware that if we are legally or contractually required to collect personal information about you, and you refuse to provide this information, we might not be able to perform our contract with you - if this occurs, we will try to discuss this with you to find a way forward. 

Purposes of collecting information

Cohabs™ only collects your information for the following purposes: See here.

Disclosure to third parties

For the purposes set out above we may be required to disclose your information to third parties, such as: 

To payment parties: Cohabs™ may be required to transfer certain Financial Data, which includes information about your method of payment and booking, to the credit or debit card company that issued the credit card used for your bookings. 

To other Users: Cohabs™ offers an in-Application social media function where Tenants can communicate with one another, if they choose to, and with landlords, if they choose to or if the landlord is legally required to. We will only ever share necessary information with these parties that you have chosen to share, such as your Contact Data, or if it is necessary to share this. 

To law enforcement agencies: Cohabs™ may disclose or provide access to your personal data in order to comply with the law or in case of illegal use, of the Platforms when we receive orders from legal authorities, to enforce our policies, and to protect the rights, property and safety of our Users, us or others.

To trusted third parties: Cohabs™ provides you with a Platform, and third parties can access all information intended to be made public by you on your Profile. Such information may contain your personal data. We do not sell, trade, or otherwise transfer your personal data to any third party, unless you give your explicit permission. This does not include trusted third parties who assist us in operating the Platform, conducting our business or servicing you (related to e.g. SaaS, payment processing), so long as those parties agree to keep this information confidential and to process such information solely in accordance with the purposes set forth herein.

Here is a list of third-parties with whom we share your personal data in order to provide you with the Services offered by Cohabs™: See it here.

While using the Platform you may encounter links to third party websites and platforms. Please note that such third party websites are not related to the Platform, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites. We encourage you to carefully read the privacy policies and the terms and conditions of such third-party websites.

International transfers

Cohabs™ will not usually share your personal information outside of the EEA unless you are based or living outside of the EEA, the property you are enquiring about or have booked is outside the EEA, or if a third party supplier (such as payment platforms) is based outside of the EEA. Even if you are outside of the EEA or you book a property outside of the EEA we will use all commercially reasonable efforts to use the same safeguards that are described in this Privacy Policy.

If a data transfer is made outside of the EEA these countries might not have the same level of protection that data is provided with inside the EEA. However, in order to ensure your personal data is protected in the same way that it would have been if the personal information was being transferred within the EEA, any transfer will be subject to the relevant safeguards set down in the GDPR. We contractually oblige all parties outside of the EEA to implement adequate safeguards to protect your personal information. If you would like any more information about this, please contact us using our contact details under Section "Questions and How to Contact Us".

Security of your personal data

In order to prevent the loss, misuse and alteration of your personal data on the Platforms and to ensure you are confident using the Platforms, we have implemented a variety of appropriate technical and organizational security measures which conform with or exceed industry standard technologies. These safeguards protect the confidentiality of your personal data, and ensure your online safety. We limit access to personal information about you to those who reasonably need access to it. We cannot guarantee that unauthorized access will never occur but we take all the necessary steps that we can to prevent this. We have procedures in place to deal with any suspected security breach, and we will notify you and any applicable regulator where we are legally required to do so.

Therefore, you may not disclose to or share with any third parties your login details. Keeping your login details confidential and safe is your sole responsibility. If your password has been revealed or stolen, immediately inform us and report any privacy breach or abuse of login data by contacting us using the contact information in Section 12 - Questions and How to Contact Us.

Storage of personal data

We do not store or process your personal data for any longer than is necessary. For example, we store your personal data as long as your Account is active or when the processing of your personal data is necessary to allow you to make use of our Platform or to enable us to perform a contract with you. In this case, personal data added by you will be stored for six (6) months after you delete such personal data or delete your entire Account. Please note that any user-generated content you posted on the Platform will remain publicly viewable on the Platform after deletion of your Account.

We may also be legally required to retain some basic personal data after you stop using our Services and for longer than the timeframe set out above in specific instances. This might include retaining Financial Data or Transaction Data for tax purposes, or other personal data, for the purposes of defending or pursuing a legal claim in accordance with applicable legal limitation periods.

Access to and modification or deletion of your personal data is free of charge and you may review, update, modify or delete your personal data at any time (described further in Section 9 - Your choices and rights). Please promptly update your personal data if it changes.

Your choices and rights

Request access: you can ask us to provide you with any information that we hold about you in our records. 

Request correction: you can ask us to correct any incorrect information or out of date information.

Request erasure: you can ask us to erase your personal information or restrict its use and we must comply in certain situations. 

Object to processing: you can object to us using your personal information in certain situations, such as to ask us to stop sending you direct marketing communications (however, please note that we might continue to send you service-related, non-marketing communications). You may also unsubscribe from email marketing at any time by using the contact details set out in Section 12 - Questions and How to Contact Us, or by clicking the unsubscribe button on our emails. 

Request restriction of processing: you can ask us to suspend processing of your personal data in certain circumstances.

Request transfer: you can ask us to provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 

Withdraw consent: you can withdraw consent at any time when we are relying on your consent to process your personal data. Please note that this would not affect the lawfulness of any processing carried out before you withdrew consent. If you do withdraw consent, we might not be able to provide you with certain Services, and we will advise you at the time if this is the case.

 

Withdraw consent for electronic communications

Where you have given your consent to receive electronic communications for direct marketing purposes or to share our newsletter with you, you may withdraw your consent at any time and without justification in any of the following ways: 

  • By clicking on the link at the bottom of emails sent by Cohabs;

  • By sending us an e-mail to gdpr@cohabs.com.

Modification of this Privacy Policy

This Privacy Policy was published on June 2022 and was last updated on the 2nd of June 2022. We reserve the right to modify this Privacy Policy at any time. Any changes to the Privacy Policy will be published on the Platform, so please consult this Privacy Policy frequently. In case of significant changes to the Policy that results in Cohabs™ using your personal data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on the Platform and/or send you an email notification. Changes to this Privacy Policy are effective as of the stated date of last revision. By agreeing to this Privacy Policy when you download the Application, and continuing to use the Platform after the latest update date, you explicitly state that you have read, understand, accept and agree to the changes in the Privacy Policy.

Cookies

Cookies are small pieces of information that are stored by your browser on your computer's or mobile device's hard drive, and they can enable Cohabs™ to provide features such as remembering aspects of your room search to make subsequent searches faster. For any non-essential cookies we will always ask for your consent. More information on how we might use cookies can be found in our Cookies Policy.

Questions and How to Contact Us

We are committed to keeping your personal data safe and we want you to feel confident when you use our Platforms. If you have any concerns, please contact us using our contact details:

If you have any further questions about our Privacy Policy or its implementation, please contact us on the following email address: gdpr@cohabs.com 

If you would like to exercise your rights or discuss this Privacy Policy you can use the email above, or write to us at Avenue Louise 222, box 13, 1050 Ixelles. Please clearly mark all correspondence with ‘Data Protection’ to ensure it reaches us promptly.

After investigating your concerns we will respond to you in writing after a reasonable period with our proposed solution. We hope that we can resolve any queries or concerns you have about how we use your information quickly and to your satisfaction. 

However, if you think we might have processed your personal information in a manner which is not lawful or which breaches your rights, you can complain to a European Data Protection Authority, either in your place of residence, work, or in the jurisdiction where the processing has taken place. For example, in Belgium, the competent authority is the Belgian Data Protection Authority (Autorité de protection des données) which can be contacted:

  • By telephone on +32 2 274 48 00
  • By email on contact@apd-gba.be  
  • By letter to Rue de la Presse 35, 1000 Bruxelles.

For more information about other European Data Protection authorities, please check here.