Privacy Notice Dwello Technologies B.V.

Privacy Notice

1. Who are we and what do we offer?

We are Dwello Technologies B.V. (Dwello). We offer a digital Platform where you as a buyer or seller can trade real estate in the Netherlands (Investment Services).

You can access our Platform via our Website: www.dwello.nl. The use of the Platform, the Website and our Investment Services are collectively: our Services.

2. Privacy Notice

This is our Privacy Notice. In this document we explain what kind of Personal Data we collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain Personal Data and what rights you have as a data subject.

3. Personal Data and Controller

We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Under the General Data Protection Regulation (GDPR) we are the so-called Controller of your Personal Data. If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Notice.

4. What Personal Data do we collect as Controller?

As the Controller, we may process your Personal Data in different contexts.

We will process your Personal Data if you use our Investment Services. In addition, we may process Personal Data in a general context, e.g. via our Website and social media accounts (General). We will also process your Personal Data if you apply for a job at Dwello (Applicants).

If you use our Investment Services, we may process the following Personal Data:

Personal Data that we may process of all users of the Services:

Personal Data we may process if you are an Applicant:

5. Mandatory information

When you engage our Services, it may be legally or contractually required that you provide us with certain Personal Data, as indicated with a (*). For example, we may need additional information so that we can verify you as our customer and administer your investment(s) and/or sales on our Platform. Where you do not provide us with such information, this will usually imply that we will not be able to provide you with specific Services or perform part of our agreement with you.

6. Cookies

We may use functional, tracking and/or analytical cookies on our Website. A cookie is a simple small text file that can be stored in your device when visiting the Website. This text file identifies your browser and/or device. When visiting our Website again, the cookie ensures that your browser/device is recognized.

For more information on our use of cookies, please refer to our cookie statement.

7. How long do we keep the Personal Data?

We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the above purposes, unless we are legally obliged to retain the Personal Data for a longer period. In this respect, we apply the following retention periods:

• Personal data of early access subscribers | These data are stored as long as necessary to determine whether we enter into an agreement with a potential user and for a maximum period of 24 months after our last contact.
• Personal data of users of our Services | These data are stored as long as we have a contract with you and for a maximum period of 5 years after, unless we are legally obliged to retain the data for a longer period.
• Newsletters | We retain the Personal Data used for sending newsletters until you unsubscribe from our newsletter.
• Personal Data in our correspondence | This data is stored as long as necessary to handle your message/question/complaint and for a period of 5 years thereafter.
• Personal Data in our records for the (tax) authorities | These data are stored for seven (7) years, unless we are legally obliged to retain the data for a longer period.
• Personal data of job applicants | We store these Personal Data for a maximum of 1 year after the application process (e.g. in order to include you in our talent pool), if we have your consent.

After expiry of the aforementioned retention period(s), we may process and retain certain Personal Data to comply with legal retention obligations and/or for fraud/misuse investigations or to substantiate a (judicial) claim. In such events, we will retain the Personal Data separately and only use such Personal Data for the aforementioned purposes.

8. Do we share Personal Data with others?

Processors

We use third parties (Processors) who support us in providing our Services. Within this context these Processors receive Personal Data from us which they process on our behalf. For instance, we use Processors for building and maintaining our Website and Platform, sending our newsletters and hosting our data.

These Processors may only use or disclose the data collected and processed by us within the scope of our instructions to them and under no circumstances for other purposes. We enter into a data processing agreement with all of our Processors.

External Controllers

In addition, some of the Personal Data may be processed by other controllers (External Controllers):

• We share your (financial) personal data with the notary and/or the bank in order to perform our agreement with you (i.e. the settlement and the delivery of the property you have purchased or sold through the Platform).  
• We may share our financial administration with the national tax authorities, because we are legally obliged to do so.

Any Personal Data provided to these External Controllers will be processed in accordance with their own privacy policies.

Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.

9. Export of personal data outside the European Union

We may transmit Personal Data to parties outside the European Union, if one of our Processors or Controllers is established outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the European standards. You contact us if you wish to receive more information or a copy of the safeguards we take in this scope where necessary.

10. Third party websites

You may find advertising or other (hyper)links on our Website that link to the websites, products and services of partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not control the content or the links that appear on these websites and we are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites, products and services, including their content and links, may be constantly changing. These websites, products and services may have their own privacy notices, user terms and customer service policies. Browsing and interaction on any other website, including websites that are linked to or from our Website, are subject to the terms and policies of that website.

11. Changes of the Privacy Notice

The Privacy Notice may be changed from time to time. Please check our Privacy Notice frequently. The new Privacy Notice will be effective immediately upon posting on our Website. If we change our Privacy Notice significantly, then we will state so on our Website together with the revised Privacy Notice.

12. Your rights as a data subject and our contact data

You are always entitled to file a complaint with a data protection supervisory authority if you believe that we are not processing your Personal Data in accordance with the GDPR. In the Netherlands, the supervisory authority for data protection is:

Autoriteit Persoonsgegevens

Website: https://www.autoriteitpersoonsgegevens.nl

If you have questions or concerns about this Privacy Notice or your privacy, you can contact us at info@dwello.nl.

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Dwello Technologies B.V.

Hofplein 33

3011 AJ Rotterdam

The Netherlands

E: info@dwello.nl

W: www.dwello.nl  

Chamber of Commerce: 83653791