Privacy

We process the personal data of everyone with whom we intend to enter into a rental contract or with whom we have already done so. We also process the personal data of individuals who are not our tenants, such as other residents, roommates, administrators, trustees, network partners or contacts of our business associates, buyers, former tenants or buyers, and people who contact us. In some cases, we also process data from third parties, such as the camera surveillance we deploy in our Woonwinkel and certain locations.

We work hard to protect your privacy and maintain compliance with the applicable legislation. The GDPR came into effect on 25 May 2018 and implemented rules about the protection of your privacy. The Data Protection Authority is tasked with enforcing the GDPR.

Any data that can be traced back to a single person is considered personal data. This includes your name, address, phone number and account number. Sometimes, we process your data anonymously. Officially, it is then no longer considered personal data.

Personal data categories

We divide personal data into three categories:

1. Name and contact details: name, surname, gender, date of birth, place of birth, marital status, address, historical addresses, email address and phone number. When you use our website and your tenant portal, we also store your IP address and your user agent.

2. Payment data: bank account number, payment history, and income verification data (including BSN, in the future).

3. Other personal data: student statements and student numbers, house waiting list registration number, ID number, data for the Negative Tenant Behaviour Registry, family composition, any medical data in case of specific housing adjustments, and imagery (deployment of camera surveillance).

In principle, we only collect your data through you.

When you register with us through rooms.vestide.nl, we only ask for your name, contact details and income information. Once we have this information, you can apply for available housing. When you rent from us, we collect your name, contact details, payment information, and other personal data.

We also use personal data in other situations. For example, our Tenants’ Contact Centre uses certain data to answer your questions properly. Lastly, we use personal data for research, settling legal disputes and combatting fraud.

We distinguish the following goals:

Goal 1: Provision of services

• Registration in our systems

• Housing mediation and rental, including preparation of the rental contract

• Tenants’ Contact Centre

• Authentication of the resident

• Perform transactions and send account statements

• Perform maintenance on and improve sustainability of the accommodation

• Comfortable and undisturbed living (in a liveable neighbourhood), including community building.

• Online organisation

• Affordable and efficient organisation

Goal 2: Research and statistics

• Tracking tenant numbers by district or neighbourhood

• Analysis of that data

• Transparent accountability

• In some cases: checking your student status

Goal 3: Prevention of rent arrears and addressing nuisance and fraud

• Tracking rent arrears

• Investigation of nuisance

• Investigation of housing fraud

Goal 4: Settlement of legal disputes

• Handling cases involving a legal dispute

• When someone is registered in the Negative Tenant Behaviour Registry

Goal 5: Camera surveillance

• We use camera surveillance at certain locations. To find out why and where we use camera surveillance, visit www.woonbedrijf.com/cameratoezicht.

• We have cameras in our Woonwinkel for your and our safety. There is a notice about this posted at the entrance to the Woonwinkel. We only use the video recordings when we need them for security purposes.

We only use your data if we are legally allowed to do so according to the reasons listed in the GDPR. The most common reasons are listed below.

Contracts

We need your information to fulfil the agreements made with you. We use contracts when renting or selling a property. In some cases, we may need your data even before a contract is concluded, such as in the pre-contractual stage.

We require certain personal data to provide our services. We can only help you if you provide that information. This could be an authorisation for rent payments, for example. We will only request data we need.

Legal obligations

As a landlord, we are subject to certain legal obligations, such as annual audits and the verification of income data when concluding a rental contract.

Legitimate interest

As a landlord, we believe it is important to perform our duties properly.

To that end, we regularly conduct surveys (structurally and during customer contact, execution of maintenance or projects) to assess and improve our services. We always explain the purpose of such a survey, what the results will be used for and whether the survey is anonymous.

As a landlord, we have to perform maintenance on our homes. We also have new construction, sustainability and renovation projects.

We are committed to addressing rent arrears, nuisance and fraud to fulfill our duty as a good landlord and ensure fair housing distribution and comfortable, undisturbed living.

Permission

In some cases, we are allowed to use your data because you have given us permission to do so. For example, you may give this permission when you use our website, fill out a form online, sign up for a community building platform, payment email or agree to a photo being taken or an interview given. When we process data with your consent, you can withdraw your consent at any time.

We do not use automated individual decision-making without human involvement, nor do we use automated profiling. This is not necessary for our services.

We use other parties for some of our tasks, such as contractors and suppliers for maintenance or other work on your home and for conducting satisfaction surveys. These parties only receive the data about you that they need to perform their job. This usually concerns your address and sometimes your phone number or email address to make an appointment or to ask you questions.

We work with municipal authorities, police, and other parties to address issues such as nuisance, rent arrears, drugs, and fraud. In some cases we choose to engage a private investigation or investigation agency for housing fraud or nuisance investigations. It is considered for each investigation whether we inform the person of this in advance or afterwards. Naturally, we comply with laws and regulations.

We cooperate with other housing associations, educational institutions, healthcare institutions, and municipal authorities for housing mediation, registration in the Negative Tenant Behaviour Registry, and placement of certain target groups or urgent cases. In addition, we try to continuously improve our online service. We use a number of software solutions for this and for the further design of our services.

During the annual audit, we are obliged to provide certain (personal) data to our accountant.

We ensure that your privacy remains well protected when sharing your information with third parties. For example, we enter into contracts with these parties to make sound agreements about aspects such as the security of your data. We make agreements that prohibit them from using your data for their own purposes. Our exchange of data is always within the legal framework.

We aim to only process your personal data within the European Economic Area to ensure that your data is always processed in accordance with the GDPR. If we make an exception to this, we will take appropriate measures for the international transfer to ensure the adequate protection of your data. This is documented in our Processing Register.

You can trust us to keep your personal data secure. We always choose a level of security that suits the technical development and cost to prevent the wrong people from seeing, changing or disclosing your data and from your data being lost or otherwise misused.

Examples of our measures include encryption and training our employees on privacy.

If we share your data with other organisations, we make sure that those organisations also protect your data technically and organisationally.

We work according to an established retention period policy. How long we store your data depends on the type of data and what we use it for. We never keep data longer than necessary or legally permitted. Tenant files are deleted five years after termination of the rental contract, except in the case of payment arrears or legal proceedings, in which case the retention period begins upon payment of the arrears or completion of the proceedings. There are certain exceptions to the retention period, such as case documents required to comply with legal obligations.

We retain camera footage from our Woonwinkel and at our complexes for up to 28 days unless longer retention is required. For more information, visit www.woonbedrijf.com/cameratoezicht.

You have a right to the protection of your privacy. You also have the following rights:

• Right to inspection: you may inspect any of your personal data that we process.

We do not share the following information:

• Notes taken for internal use.

• Personal data of others. For example, we will not share a tenant complaint filed by a neighbour.

Personal data used in the context of prevention, detection and prosecution of criminal offences and other cases mentioned in the exceptions of Art. 23 of the GDPR. You can submit a request to view or delete camera footage at www.woonbedrijf.com/cameratoezicht.

• Right to rectification: if the personal data we have on file is incorrect, you may have it corrected.

• Right to deletion: if we no longer need your personal data for the purpose for which we requested it, you may ask us to delete it. An exception is if we are required to keep your data, such as for the Tax and Customs Administration.

• Right to restrict processing: while we are processing your request involving any of the above rights, you have the right to request restriction of data processing.

• Right to data portability: you may ask us to transfer any data we have on you to an organisation of your choosing. This is only possible if this data is processed based on consent or agreement, not if we process it on legal grounds.

• Right to object: you can object to the use of your data if we process it on the basis of legitimate interest or public interest. A balance of interests will be made.

If you have any questions about your privacy or want to exercise any of your rights,

please stop by our Woonwinkel, call +31 40 297 93 80 or email your question to our privacy officer at: privacyofficer@woonbedrijf.com.

If you have a question about your personal data, we may ask you to fill out a form. We may also ask you to identify yourself to ensure that we do not share your personal data with anyone else.

If you feel we are not helping you properly, you can file a complaint at: https://vestide.nl/klacht-melden/.

Please state clearly that your complaint concerns a privacy complaint. We will work with you to find a solution.

You also have the right to file a privacy complaint with the regulator, the Data Protection Authority. For information on how to file a complaint with the Data Protection Authority, visit www.autoriteitpersoonsgegevens.nl.