Habita1. Data controller
The controller is [Ragione sociale], [Sede legale], [Registro delle imprese e numero di iscrizione], [Partita IVA / codice fiscale dell’impresa], hereinafter "Habita". For any privacy request, including exercising your rights, write to [email protected].
2. Data we process
Account: email, app language, password (stored only in encrypted form), first name, last name, nationality, date of birth, mobile number and, for businesses, company name, Italian or EU VAT number and, for Italy only, e-invoicing code or certified email. We don’t ask for a tax code or any other national identification number. If you sign in with Apple or Google we only receive your name and email from them (with Apple you can choose an anonymous address); you enter the other details yourself. Profile: profile photo and, if you add them, the languages you speak. House search: area on the map (centre and radius), budget, floor area, optional lifestyle (smoking, social life, tidiness, guests, time at home), employment contract, monthly net income, guarantees (guarantor, months paid in advance, willingness to pay a security deposit), pets, introduction, income documents uploaded voluntarily. Household: name, role, age and income of the members you add. Listings: property details and photos. Use of the service: applications, matches, chat messages and attachments, reports, people you have blocked, notification device. Subscription and invites: status and expiry of Habita Featured (received from RevenueCat; payment details stay with Apple or Google), your invite code and whether someone used it, the outcome of the matches you close (lease signed or not) and when a landlord saw an application. Security: if you enable two-step verification, the authenticator key (stored by our authentication provider); date and ID of identity verification attempts. Identity verification (only for those who publish listings): document images and selfie, processed by Stripe.
3. Why we process it and on what legal basis
Providing the service (account, search, compatibility score, matches, chat, notifications): performance of the contract, art. 6.1.b. Featured subscription and invite programme: performance of the contract, art. 6.1.b. Alerts about new compatible listings and the outcome of closed matches, used in aggregate to measure and improve the service: legitimate interest, art. 6.1.f; alerts can be turned off in Settings > Notifications. Sponsored content: we don’t use your data to choose it and don’t share it with partners; we only count, anonymously, how many times an offer is seen or tapped. Income documents: your consent, art. 6.1.a, which you can withdraw at any time. Identity verification with selfie: explicit consent to the processing of biometric data, art. 9.2.a, requested before starting. Prevention of fraud, abuse and discrimination (mandatory profile photo, reports, blocking between users, sending limits, blocking of direct contacts before the match, automatic filter for discriminatory exclusions in listings, suspension of listings reported by several people pending human review): legitimate interest, art. 6.1.f, and obligations under EU Regulation 2022/2065 (DSA). Crash diagnostics: legitimate interest, without identifying data. Legal obligations: art. 6.1.c.
4. Anonymity before the match
During the search the landlord sees your profile photo, type of contract, household, guarantees, introduction, the languages you speak and compatibility score; you see the languages the landlord has added. They don’t see your name, contacts, exact income or documents. These details become visible only after mutual consent (match) and only while the match remains active. Your nationality and date of birth are never visible to other users. If you have activated Habita Featured, the landlord also sees the “Featured” label; people with Featured can see when the landlord looked at their application (date and time only).
5. Compatibility score and automatic filters
Habita automatically calculates a score from 0 to 100 by comparing your file with the listing’s requirements: ratio between rent and household income (up to 35 points), type of contract (25), guarantor and months paid in advance (20), household composition (10), uploaded documents (10). The score is halved if you have pets and the listing doesn’t allow them, and stays below 50 if household income is below the required minimum. We don’t show you listings outside the area you chose, with a minimum income above yours, that don’t allow pets if you have them or that don’t allow smoking if you said you smoke indoors. The score helps the landlord but doesn’t decide for them: accepting an application is always a person’s choice. You can ask us for explanations, contest the result and express your view by writing to [email protected] (art. 22).
6. Identity verification
For people publishing listings, the verification is carried out by Stripe Payments Europe Ltd. Stripe compares the selfie with the document photo; Habita only receives the result and checks that the first name, last name and date of birth on the document match those in the profile. As soon as the result is recorded we ask Stripe to delete the document images and data. Without your explicit consent the verification doesn’t start; you can still use Habita to look for a home.
7. Data of other people
If you list the members of your household, you agree to inform them first. We only ask for name, role, age and income: no photos or documents of others. The landlord sees this data only after a match.
8. Recipients and providers
Your data is visible to other users only within the limits of section 4. It is processed on our behalf, as processors, by: Supabase (database, storage, EU servers), Expo (push notifications, which never contain the text of messages), Sentry (crash diagnostics, without name, email or IP address, can be turned off in Settings > Privacy), RevenueCat (subscription management). Maps and address search use the phone’s map services (Apple Maps on iPhone, Google Maps on Android). Stripe (identity verification) and Apple and Google (sign-in with Apple or Google, in-app purchases) also act as independent controllers. Some providers are based in the United States: transfers rely on the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses.
9. How long we keep it
Account, profile, file and listings: as long as the account is active; we delete them immediately when you delete it. Income documents: until you delete them or withdraw consent. Chats and attachments: as long as the match is active; we delete them when either party closes it. Listings you passed on: 3 months, then they may return to your deck. Rejected applications or closed matches: 6 months, then you can apply again. Reports: for the time needed to check them and up to 24 months after closure. Blocks: until you unblock or delete your account. Notification devices: 9 months after last use. Identity verification images: deleted at Stripe after the result. Log of identity verification attempts (date and ID, no images): 90 days, to limit abuse and costs. The cloud provider’s backup copies are overwritten within a few days.
10. Security
Encrypted connections, encryption at rest, access rules enforced by the database and not by the app. Documents and attachments are kept in private storage with no public links: every time they are opened a temporary link is used. On your phone, the sign-in session is stored in encrypted form. Photos are re-encoded before upload, removing location metadata. You can turn on two-step verification and sign out of all devices from Settings > Security. If a data breach puts you at risk, we tell you without delay and notify the supervisory authority within 72 hours (arts. 33 and 34 GDPR).
11. Your rights
You can access your data and download a complete copy in JSON format (Settings > Download my data), correct it from your profile, delete it by deleting your account (Settings > Delete account and data), withdraw consent for documents (Profile > Income documents) without affecting processing already carried out, object to processing based on legitimate interest and request restriction of processing. We reply within one month if you write to [email protected]. You also have the right to lodge a complaint with the supervisory authority: Garante per la protezione dei dati personali (garanteprivacy.it), or the one in the EU country where you live or work.
12. Location
Habita does not track your location. It uses it only once, and only if you tap "Near me", to centre the map of your search area; the data is not saved. We only save the area you choose (centre and radius). For listings we save the approximate location of the neighbourhood, never the address.
13. Minors
Habita is for adults only: age is checked from the date of birth at sign-up and, for those who publish listings, from the identity document. For underage household members we only record role and age.
14. Closing matches and reports
When either of you closes a match, the conversation and shared files are deleted for both. You can report a user or a listing: the report stays anonymous for the reported person.
15. Changes
If we change this privacy policy substantially we’ll tell you in the app before the changes take effect.
This text is also in the app, under Settings.