PRIVACY POLICY LENTO
This is the privacy policy of Lento Operations B.V. and all its affiliated companies (hereinafter referred to as “Lento”, “we” or “us”). This privacy policy explains how we handle your personal data. We only process personal data that we need to provide our services and we treat the information we receive from you with due care.
1 | Definitions
In this policy, the following words have the following meanings:
Account: the personal online environment in the Portal made available to the User by Lento for the purposes of using and managing the Service.
GDPR (General Data Protection Regulation): Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC. All terms used in this policy have the same meaning as in the GDPR.
Service(s): the facilitation of the Portal and all services offered by Lento via the Portal, such as providing letting services, including but not limited to the possibility of offering lettable units, providing tenancy or temporary tenancy agreements for the letting of the lettable units to be used by the landlord and tenant (to which Lento is not a party), providing accommodation-related services and services in the area of accounting and financial settlement, including all Portal content.
User: any (potential) party using the Service, being you as (an employee of) a landlord, employer or as a consumer.
Portal: Lento’s digital platform, accessible via www.lento.eu and including all Services offered via this platform.
Website: www.lento.eu, affiliated websites, including all content.
2 | Applicability of policy and contact details
If you visit our Website, create an Account and are a User of our Portal, receive our newsletter or other marketing communications or apply for a job with us, we will determine the purpose and means of processing your personal data. This makes us the controller within the meaning of the GDPR. We will be your point of contact in those cases. This policy only applies to the processing of personal data by us as the controller.
For all questions, comments and/or complaints about this privacy policy and/or the processing of your personal data, please contact us:
Lento Operations B.V.
This policy does not apply if we are a processor of your personal data. If we process personal data in the performance of the Services as a processor, we will conclude a data processing agreement. In such cases, Lento refers you to the privacy policy of the relevant landlord or your employer.
This policy also does not apply to third-party websites that are connected to our Website or Portal by means of links. The cookie and privacy policies of third parties apply to these. We are neither responsible nor liable for the processing of personal data by third parties, and can therefore not guarantee that these third parties will handle your personal data in a reliable and secure manner. You should always read the privacy policy of other websites before using them.
3 | Personal data we collect
Below we explain, among other things, the purposes for which we process your personal data, the legal basis for processing your personal data and how long we may retain your personal data.
Purposes, categories of personal data, categories of data subjects and legal basis
We use cookies and similar techniques to process personal data about your visiting behaviour and activities on our Website and Portal. We refer to our cookie policy for more information on these cookies. This privacy policy applies to all personal data processing operations on the basis of cookies.
Insofar as we use anonymous data to improve our Website and our Portal, the GDPR does not apply to this, nor do we need any legal basis for this.
We only collect personal data from website visitors - i.e. visitors who are not logged into our Portal and do not have an Account - when they ask a question via e-mail or WhatsApp. This may involve the following personal data:
| (Personal) data | Data subjects | Legal basis | |
|---|---|---|---|
| Website visitor who is not logged in or does not have an Account | Person requesting contact | ||
| Private or business e-mail address | - | x | Legitimate interest |
| Private or business mobile telephone number | - | x | Legitimate interest |
| Other personal data that you provide in your request or message to us | - | x | Legitimate interest or consent |
| Data via cookies | x | x | Legitimate interest or consent |
Explanation of legal basis
Your personal data are needed to process your contact requests, to improve our Services and to maintain, develop and secure the operation of our IT systems. We process these personal data on the basis of our legitimate interest, except when your interests or your fundamental rights and freedoms outweigh our interests. This legal basis is referred to below as ‘legitimate interest’. When your interests or your fundamental rights and freedoms outweigh our interests, we will ask for your consent.
Retention periods
If you send us a message or contact us in any other way, we will retain your contact details for as long as necessary to comply with your request. After that, we will delete or anonymise your personal data. If we process your personal data on the basis of your consent, you may easily withdraw this consent at any time. You can submit your request using the e-mail address stated below the contact details.
Purposes, categories of personal data, categories of data subjects and legal basis
If you wish to use our Services via the Portal, you must create an Account. For example, you need to register as a User in order to be able to offer properties for rent or make use of an allocated housing unit. You must enter personal data in order for your Account to be registered. Your personal data are necessary to enable you to access the Portal and our Services.
We (or third parties engaged by us) will request the following personal data from the following data subjects when registering your Account:
| (Personal) data | Data subjects | Legal basis | |||||
|---|---|---|---|---|---|---|---|
| Consumer | Employer (company) | Employee of the employer | Landlord (company) | Employee of the landlord | Landlord (private individual) | ||
| Name (first name + surname / name of organisation) | x | x | x | x | x | x | Performance of the agreement |
| Private or business address details (street, house number + addition, postcode + city, country) | x | x | x | x | x | x | Performance of the agreement |
| Private or business IBAN + account name | x | x | - | x | - | - | Performance of the agreement |
| Nationality | x | - | x | - | x | x | Performance of the agreement |
| Language | x | - | x | - | x | x | Performance of the agreement |
| Date of birth | x | - | x | - | x | x | Performance of the agreement |
| Gender | x | - | x | - | x | x | Performance of the agreement |
| Passport / ID number | x | - | x | - | x | x | Performance of the agreement |
| Expiry date of passport / ID | x | - | x | - | x | x | Performance of the agreement |
| Private or business mobile telephone number | x | - | x | - | x | x | Performance of the agreement |
| Private or business e-mail address | x | - | x | - | x | x | Performance of the agreement |
| Interests (optional) | x | - | - | - | - | - | Legitimate interest |
| Social media of person (Facebook/Twitter: optional) | x | - | - | - | - | - | Legitimate interest |
| Photo of person (optional) | x | - | x | - | x | x | Legitimate interest |
| Other personal data that you provide to us, for example when using the forums and communication facilities in our Portal | x | - | x | - | x | x | Legitimate interest |
Explanation of legal basis
When you create an Account for our Portal and want to use our Services, you must agree to our general terms and conditions and this privacy policy will be declared applicable. We process most of your personal data because this is necessary for the performance of the agreement we conclude with you or in order to take action at your request prior to the conclusion of an agreement. For example, we need your ID number to verify your identity and your date of birth to register your age. We may process the foregoing personal data within our Portal and in our systems for administrative purposes.
We may also (further) process the above-mentioned personal data for statistical or analytical purposes if we have a legitimate interest in doing so. If so, we only use the necessary (pseudonymised) data. If we use anonymised data for these purposes, the GDPR will not apply and we will not need any legal basis.
Retention periods
Your personal data will be retained for the duration of your Account, unless we receive a request to delete your personal data sooner. We cannot (fully) comply with your request if we have to retain your personal data for certain purposes (for a longer period) due to a statutory retention period. We keep some data for 7 years for tax and administrative purposes. This statutory retention period starts, in principle, after the document in question loses its current value.
Purposes, categories of personal data, categories of data subjects and legal basis
One of our Services within the Portal is the collection of rent, service and other charges and deposits from the tenant on behalf of the landlord. For this purpose, we need to process the following personal data of the following data subjects:
| (Personal) data | Data subjects | Legal basis | |||||
|---|---|---|---|---|---|---|---|
| Consumer | Employer (always an organisation) | Employee of the employer | Landlord (organisation) | Employee of the landlord | Landlord (private individual) | ||
| Name (first name + surname / name of organisation) | x | x | x | x | x | x | Performance of the agreement |
| Private or business address details (street, house number + addition, postcode + city, country) | x | x | x | x | x | x | Performance of the agreement |
| Private or business IBAN + account name | x | x | x | x | x | x | Performance of the agreement |
| Private or business mobile telephone number | x | x | x | x | x | x | Performance of the agreement |
| Private or business e-mail address | x | x | x | x | x | x | Performance of the agreement |
| The period and amounts to which the costs relate | x | x | x | x | x | x | Performance of the agreement |
Explanation of legal basis(s)
When the amounts are collected, the personal data collected when creating the Account will be used for a different purpose, but this is necessary for the performance of the agreement we conclude with you within the context of our Portal. For example, we need your IBAN to be able to collect the rent via the Portal and your e-mail address to be able to inform you about possible arrears.
Retention periods
Your personal data will be retained for the duration of your Account, unless we receive a request to delete your personal data sooner. We cannot (fully) comply with your request if we have to retain your personal data for certain purposes (for a longer period) due to a statutory retention period. We keep some data for 7 years for tax and administrative purposes. This statutory retention period starts after the document in question loses its current value.
Purposes, categories of personal data, categories of data subjects and legal basis
Lento wishes to offer targeted services to the Users of its Portal. This may take the form of a targeted offer of Services to Users and the sending of a newsletter. For these marketing purposes, we process the following personal data of possibly the following data subjects:
| (Personal) data | Data subjects | Legal basis | |||||
|---|---|---|---|---|---|---|---|
| Consumer | Employer (always an organisation) | Employee of the employer | Landlord (organisation) | Employee of the landlord | Landlord (private individual) | ||
| Name (first name + surname / name of organisation) | x | x | x | x | x | x | See explanation |
| Private or business mobile telephone number | x | x | x | x | x | x | See explanation |
| Private or business e-mail address | x | x | x | x | x | x | See explanation |
| Subscription to newsletter | x | x | x | x | x | x | See explanation |
Explanation of legal basis
We will not use your electronic contact details for marketing purposes, unless you are an existing customer, when we have obtained your consent to send direct marketing or meet another exception under the applicable Telecommunications Law. For the “underlying” processing of personal data for marketing purposes, we rely on our legitimate interest.
Retention periods
We retain your data for marketing purposes for up to 5 years from the time the data were created or from the time of your consent. After that, we will delete or anonymise your personal data, unless we need certain personal data for a longer period for another purpose. If we process your personal data on the basis of your consent, you may easily withdraw this consent at any time. You can submit your request using the e-mail address stated below the contact details.
Purposes, categories of personal data, categories of data subjects and legal basis
If you apply for a job with us, we need personal data to assess your application and to contact you about it. You must therefore provide us with the following personal data:
| (Personal) data | Data subjects | Legal basis |
|---|---|---|
| Job applicants | ||
| Name (first name + surname / name of organisation) | x | Legitimate interest or pre-contractual phase |
| Address details (street, house number + addition, postcode + city, country) | x | Legitimate interest or pre-contractual phase |
| Date of birth | x | Legitimate interest or pre-contractual phase |
| Mobile telephone number | x | Legitimate interest or pre-contractual phase |
| Motivation letter and CV | x | Legitimate interest or pre-contractual phase |
| Date you are available to start work | x | Legitimate interest or pre-contractual phase |
| Other personal data you provide to us in connection with your application | x | Legitimate interest or pre-contractual phase |
Explanation of legal basis
The legal basis for collecting your personal data as part of the ‘commencement’ of the application is a legitimate interest. If we get further into the application process, your personal data will be necessary for us to draw up and perform the employment contract (during the pre-contractual phase).
Retention periods
If you have applied for a job with us, your personal data will be deleted when you ask us to do so, or 4 weeks following completion of the application process, unless you have consented to us retaining your personal data for a period of 1 year after completion of the application process. You can withdraw your consent at any time by contacting us.
3 | Third parties
In order to provide our Services, we cooperate with third parties.
Insofar as third parties process your personal data on our behalf, they do so as processors. In these cases, we are the controller, as we determine the purposes and means of processing. As the controller, we have a legal basis for being allowed to process the personal data. Lento will only engage processors who adequately implement appropriate technical and organisational measures and who guarantee the protection of the rights of data subjects. We engage third parties to assist us in using or improving the Website or the Portal, such as web hosting, payment processing and marketing. We only give these third parties access to personal data to the extent that they need it in order to perform their work, and only on the basis of our instructions.
If we process personal data on behalf of third parties - the reverse situation - we ourselves will be the processor. In that case, the third party will be the controller and must have a legal basis for being allowed to process your personal data. We will then process your personal data only on the instructions and on behalf of that controller.
In situations involving a controller and a processor, we conclude a data processing agreement. This is compulsory under the GDPR. The data processing agreement regulates, among other things, data security, confidentiality and your rights.
Furthermore, Lento may share personal data with:
If data are transferred to ‘third countries’ – i.e. countries outside the European Economic Area – we will only do so if the third country offers an adequate level of protection. If this is not the case, we provide appropriate safeguards to ensure the best possible data protection, such as standard contractual clauses approved by the European Commission. If no appropriate safeguards are in place, we will only transfer personal data if a legal exception applies. An example of a legal exception is explicit consent.
4 | Security of personal data
We take the protection of your personal data seriously and implement appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and improper changes.
In order to safely store and secure your personal data, we use security software and take the necessary and appropriate measures to this end. If you discover a personal data breach or suspect one, please contact us.
5 | Your rights
As a data subject, you have certain rights with regard to your personal data. We explain these rights and how you can invoke them below.
You may access the personal data we process about you and you are entitled to receive (additional) information as set out in this policy.
You have the right to have your personal data rectified.
You have a ‘right to erasure’. This is stated in inverted commas. For we may not always erase your personal data. Sometimes the processing is still necessary, for example, for complying with statutory obligations or for lodging, exercising or substantiating claims. Therefore, we always weigh up the pros and cons when such a request is made. If you want to delete your Account, you can do so by clicking on the ‘delete account’ button.
Under certain circumstances, you may also have us restrict the processing of your personal data.
Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about rectification, deletion or restriction of processing.
Under certain circumstances, you may request us to transfer your personal data to another party.
Furthermore, under certain circumstances you may object to the processing of your personal data by us (or third parties engaged by us). For example, you may object to the use of your personal data for marketing purposes. Apart from this, you may object to the use of your e-mail address for direct marketing. For example, you can click on ‘unsubscribe’ at the bottom of our marketing e-mails or e-mail us at info@lento.eu with an unsubscribe request.
If we have requested your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.
If you believe that the processing of your personal data violates applicable laws and regulations, please contact us. You also have the right to lodge a complaint with the Dutch Data Protection Authority, or any other competent authority in the European Union, or to take legal action.
You can submit your requests for exercising these rights to us via the details described under 2 (contact details). We may ask you for additional information to confirm your identity. We will respond to your request as soon as possible, and within one month of receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the law. If a longer period is needed, we will inform you. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive.
6 | Amendments
We reserve the right to amend our privacy policy. Therefore, please check this Website regularly for the latest version. You hereby declare that you have read this policy. Continued use of our Services implies that you have also read the amended policy.
© 2023 Lento Operations B.V.