Processing and Protection of Personal Data

I. General Information

These specifications apply to the Student Housing mobile application and the student-housing.app website (together, the "Service"), operated by TINT TECH S.R.L., hereinafter referred to as "the Controller". The Controller's registration details are set out in the Legal Notice.

The Controller processes the personal data of users of the Service in compliance with Regulation (EU) 2016/679 (the "GDPR") and Law No. 190/2018 on measures implementing the GDPR, and has adopted technical and organizational measures appropriate to this purpose.

These specifications inform data subjects of the categories of personal data processed, the purposes and legal grounds of processing, the persons to whom such data may be disclosed, the duration of processing, and the rights available to data subjects in connection with their use of the Service.

For any request, complaint, or clarification regarding the processing of personal data, data subjects may contact the Controller at contact@tinttechhub.com.

II. Categories of Processed Data

The Controller processes personal data collected through two components of the Service:

a) The website. In connection with the waitlist form available on the website, the Controller processes: the email address, provided voluntarily by the data subject; the IP address, processed automatically and temporarily for the purpose of preventing abusive or repeated submissions; and standard technical log data generated by the hosting infrastructure (browser type, pages accessed). The website does not use analytics or advertising cookies.

b) The mobile application. Following the creation of an account, the Controller processes the following categories of data, according to the functions used by the data subject:

• account data — email address and password, the latter stored exclusively in hashed form by the authentication provider and never accessible to the Controller as plain text;
• profile data — name, profile photograph, short biography, city, country, university, institutional email address, year of study, and age, most of which are provided at the data subject's discretion;
• student verification data — where a data subject confirms ownership of an institutional (university) email address, the Controller records that confirmation to display a "verified student" indicator. This indicator confirms only that a university email address was verified at a point in time; it is not a verification of identity, enrollment status, or trustworthiness;
• lifestyle and housing preferences — data voluntarily disclosed to facilitate roommate matching and listing search, such as smoking habits, cleanliness, personality traits, preferred quiet hours, and budget range;
• listing data — where the data subject publishes a listing: address and geographic coordinates of the property, price, photographs, amenities, and a contact telephone number and/or email address, which, once published, are accessible without restriction to any user of the application, including persons who have not created an account;
• data relating to third parties (tenants) — where the data subject manages a listing, they may enter the names and bed assignments of persons occupying the property; the data subject is solely responsible for having obtained, where required, the consent of those persons prior to entering their data;
• correspondence — the content of messages exchanged between users through the application's messaging function, retained on the Controller's servers for as long as the corresponding conversation exists;
• reports and requests — the content of any report concerning another user or listing, and any request, complaint, or attachment submitted through the support function;
• roommate-group ("Team Up") data — membership and preferences expressed within a group created for a given listing, visible to the other users of the application;
• favorites — listings saved by the data subject and any classification created for this purpose;
• camera and photo library data — with the data subject's permission, the device camera or photo library is accessed to capture or select a profile or listing photograph; no other images are accessed, and this permission may be granted, denied, or withdrawn at any time from the device's settings;
• location data — with the data subject's permission, the device's precise or approximate geographic position is used, while the application is in use, to center maps, geocode addresses, and sort or filter available listings by distance; this data is not stored in association with the data subject's profile, and the permission may be granted, denied, or withdrawn at any time from the device's settings;
• the push-notification token — a technical identifier of the device, used exclusively for delivering notifications relating to the data subject's account activity, where the data subject has permitted notifications;
• technical and diagnostic data — information automatically generated in the event of an application malfunction (device model, operating system version, error description), and aggregate statistics on application usage; and
• advertising data — where advertisements are displayed within the application, the advertising identifier of the device and other technical parameters may be processed by the Controller's advertising partner, as described in Section IV.

III. Purposes and Legal Grounds of Processing

The purposes for which personal data is processed are:

• the creation and administration of the user account and profile;
• the operation of the Service's functions: publication and search of listings, roommate matching, correspondence between users, favorites, and notifications;
• the handling of reports and requests submitted by users, for the purpose of maintaining the safety and proper functioning of the Service;
• keeping the data subject informed, through the waitlist, of the launch of the Service and related updates;
• the prevention of fraudulent, abusive, or unauthorized use of the Service; and
• the diagnosis of technical malfunctions and the improvement of the Service.

Processing carried out for the creation and administration of the account, and for the provision of the functions described above, is based on the performance of the contract concluded with the data subject upon account creation (Article 6(1)(b) GDPR); such data is necessary for the provision of the corresponding function, and refusal to provide it results in the impossibility of using that function.

Processing of optional data — such as lifestyle preferences, the institutional email address, camera and photo library access, device location, and the waitlist email address — is based on the data subject's consent (Article 6(1)(a) GDPR), which may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Processing carried out for the prevention of abuse, the handling of reports, and technical diagnosis is based on the Controller's legitimate interest (Article 6(1)(f) GDPR) in maintaining the security and proper operation of the Service, an interest which has been balanced against the fundamental rights of data subjects. The Controller does not sell personal data to third parties.

IV. Advertising

The application displays advertisements through the Google AdMob network, in order to support the free provision of the Service. In this context, the device's advertising identifier and other technical device signals may be processed for the purpose of ad selection, including personalized advertising, where permitted by the settings of the operating system. On iOS, the device advertising identifier is used for personalized advertising only if permitted through the App Tracking Transparency prompt.

Data subjects may, at any time, restrict the processing of their advertising identifier from the privacy settings of their device (on iOS: Settings → Privacy & Security → Tracking; on Android: Settings → Privacy → Ads). Restricting this setting does not remove advertisements from the application but limits their personalization.

V. On-Device Processing

Certain features, such as translating listing text and identifying its language, run entirely on the data subject's device using an on-device machine-learning model. Content processed this way is not transmitted to the Controller or to any third party for that purpose; the only network activity involved is a one-time download of the on-device model itself.

VI. Disclosure of Personal Data

For the purposes described in Section III, the Controller discloses personal data to:

• other users of the Service, to the extent that certain data (such as the content of listings, correspondence, and roommate-group data) is, by the nature of the corresponding function, visible to other users;
• Google Firebase, the Controller's infrastructure provider, which stores and processes account, profile, listing, message, and diagnostic data on the Controller's behalf, under a data-processing agreement;
• Google AdMob, for the purpose described in Section IV;
• providers of mapping and geocoding services, for the purpose of determining the geographic coordinates of listings and of location-based search; and
• the Controller's email-delivery and hosting providers.

The Controller may also disclose personal data where required by law, in order to enforce the terms applicable to the Service, or in order to protect the rights, safety, or property of the Controller, its users, or third parties. If the Controller is involved in a merger, acquisition, or sale of assets, personal data may be transferred to the party involved in that transaction, subject to the commitments made in these specifications.

VII. Transfer of Personal Data

The providers referred to in Section VI may process and store personal data outside of the data subject's country of residence, including in the United States. Where such processing entails a transfer of personal data outside the European Economic Area, the Controller relies on the transfer safeguards implemented by its providers and recognized under the GDPR, such as the EU-U.S. Data Privacy Framework or the standard contractual clauses adopted by the European Commission.

VIII. Duration of Data Processing

The email address submitted through the waitlist is retained until the launch of the Service and the creation of an account by the data subject, or until the data subject requests its deletion, whichever occurs first. IP addresses processed for the prevention of abuse are retained for approximately one hour.

Account and profile data is retained for the duration of the account's existence. Upon deletion of the account, the Controller deletes the profile, listings, and associated photographs, and deletes or anonymizes the remaining personal data (including correspondence and group memberships) within 30 days, except to the extent that retention of certain data is required for compliance with legal obligations, the resolution of disputes, or the enforcement of the Controller's agreements.

Technical and diagnostic data is retained by the infrastructure provider for a limited period, not exceeding 90 days, for the purpose described in Section III.

IX. Rights of Data Subjects

Users of the Service, in their capacity as data subjects, have the following rights, exercised in accordance with the GDPR:

• the right to be informed, exercised through these specifications;
• the right of access to the personal data processed by the Controller; most account and profile data may be accessed directly, at any time, from the application's account settings;
• the right to rectification, exercised by editing the corresponding data within the application or, where this is not possible, by a request addressed to the Controller;
• the right to erasure ("the right to be forgotten"), exercised through the account-deletion function within the application, through the self-service form at student-housing.app/delete-account, or by request addressed to the Controller;
• the right to restriction of processing and the right to object to processing;
• the right to data portability, exercised through the export function available within the application, or by request addressed to the Controller;
• the right to withdraw consent, at any time and without affecting the lawfulness of processing carried out prior to withdrawal; and
• the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) or with the competent courts.

Requests concerning the exercise of these rights may be addressed to the Controller at contact@tinttechhub.com and will be answered within the time limits provided by the GDPR. A complete, pillar-by-pillar description of these rights is set out in the GDPR Compliance page.

X. Security Measures

Passwords are stored exclusively by the authentication provider, in hashed form, and are not accessible to the Controller. Data is encrypted in transit and at rest by the infrastructure provider. Access to personal data within the Service's database is restricted by rules corresponding to each category of data — for example, only the participants in a conversation may access its content — with the exception of data which, by the nature of the corresponding function, is intended to be visible to other users, as described in Section II.

No method of electronic storage or transmission is entirely secure. In the event of a personal data breach affecting the rights of data subjects, the Controller will notify the affected data subjects and the competent supervisory authority without undue delay, in accordance with the GDPR.

XI. Minors

The Service is intended for university students and other adults. The Controller does not knowingly collect personal data from persons under the age of 16, or such higher age of consent as may apply under the law of the data subject's habitual residence. Where the Controller becomes aware that an account has been created by, or contains data of, a person below the applicable age, the account will be deactivated and the associated data deleted. Parents or legal guardians who believe that a child has provided personal data to the Controller may submit a request to contact@tinttechhub.com.

XII. Amendments

The Controller may amend these specifications as the Service evolves, in particular where new functions requiring the processing of additional categories of data are introduced. Amendments take effect upon publication on this page, together with an updated "Last updated" date. Amendments materially affecting the purposes or legal grounds of processing, or the rights of data subjects, will additionally be communicated to users by electronic means before taking effect; where such amendments concern processing based on consent, the Controller will request renewed consent where required by law.