CASAFARI (collectively, “CASAFARI”, “We”, “Us” or “Our”) respects your privacy and is committed to protecting your personal data. This policy explains how we treat your personal data, protects your privacy when you use our Housing for Refugees Platform and also provides information about your rights under applicable legislation. Please read this policy carefully before you provide us with any personal information. By using our Platform, you agree that CASAFARI can use such data in accordance with our privacy policy. CASAFARI complies with the EU General Data Protection Regulation (GDPR) to guarantee you sufficient protection and security of your data.

This policy applies to all users of our Housing for Refugees Platform.

Within our Platform, there may be links to third-party websites or applications. We do not control and are not responsible for the content or privacy compliance of third-party websites or applications. Therefore, we suggest you check on those websites and/or applications the applicable Privacy Statements and respective Terms of Use.

Children’s Privacy. Our Platform is not generally aimed at children and are not intended to be used by children or minors (under 18 years old), therefore we do not knowingly collect data relating to children or minors. 

CONTROLLER NAME & CONTACT INFORMATION:

The Controller within the General Data Protection Regulation and national data protection regulation is:

Casafari Europe Ltd

Address:  27 Old Gloucester Street, London

WC1N 3AX, United Kingdom 

E-mail: privacy@casafari.com

WHO WE ARE | WHAT IS OUR PLATFORM

CASAFARI is a real estate platform powered by Artificial Intelligence that provides property market competitive intelligence through a Software as a Service (SaaS). The CASAFARI company group is composed of CASAFARI LLC, CASAFARI EUROPE LTD and its subsidiaries in Portugal and Hungary.

The Housing for Refugees Platform is a non-profit project with partnerships, solidarity and humanitarian help in focus, that combines the efforts of CIPU (Consultores Imobiliários pela Ucrânia) empowered by CRM technology developed by CASAFARI, with the aim of supporting volunteers in their increasing efforts to help refugees.

HOW WE COLLECT DATA FROM YOU WHILE USING OUR PLATFORM

As defined in the GRPR, personal data means any information relating to an identified or identifiable natural person. In turn, an identifiable natural person is one who is capable of being identified, directly or indirectly, especially through a referent such as name, location data, specific elements of physical or physiological integrity, etc.

Other relevant definitions under this Privacy Policy will be as set out below:

• “Data subject” means the a person who has a right concerning data, including the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed and, where applicable, to exercise the other rights applicable to his or her personal data being processed;
• "Data Processing" means any operation or set of operations which is performed upon personal data or on a set of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• "Consent" of the data subject means a freely given, specific, informed and explicit indication of his or her wishes by which the data subject signifies his or her agreement to personal data relating to him or her being processed by way of a statement or unequivocal affirmative act;
• "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

We obtain personal data from you:

• Through your interactions with us and our platform, such as when you fill in our forms as a Refugee seeking for shelter or as a Property Owner seeking to help those who need it the most, or; When we provide information on Property Owners and the Properties that are available and that correspond directly to the shelter request previously submitted by the Refugee, or; When we provide information, on Refugees to Property Owners that are suitable to match a shelter according to the submitted inputs in terms of their accommodation needs, or; When you request information or contact Us for support;
• Through your system/device and use of Our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Platform, analyze usage and improve users’ experience;
• Through your IP address, in order to diagnose problems with Our server, administer the site and track usage statistics. If you reached Our Platform by clicking on a link or advertisement on another site, then we also log that information – this helps us maximize Our Internet exposure, and understand users’ interests;
• Through cookies and similar technologies included on our Services, as you interact with our Platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We gather this data by using cookies and similar technologies as further explained in the Cookies and similar technologies section.

You can choose whether or not to provide us with personal information, but if you choose not to, you recognize and accept that you may not get full access to the platform.

WHAT DATA WE COLLECT

The personal data  we collect consists of the following:

• Name and Contact Data such as your full name, e-mail, phone number, date and place of birth, gender, citizenship, languages spoken, passport/citizenship card number and expiry;
• Traveling Data, such as from which city you are traveling and estimated date of arrival, required support upon arrival (Food, Clothing, Financial aid), location preference, housing budget and information on the people traveling who would like to be sheltered with (nr. of people, gender, if there are any children/pets) and their Name and Contact Data (as stated above);
• Shelter Data, such as housing type (nr. of bedrooms and housing capacity), location (Region, City and Locality), shelter conditions, payment information (if payment is required, amount and payment frequency), availability Information (availability date and requirements), Shelter Photos and additional information you would like to share.
• User content, such as communications and files provided by you in relation to your use of the Platform;
• Device information, such as information about your device, such as IP address, location or provider;
• Usage information and browsing history, such as information about you navigating within Our Platform and  your browsing history;
• Location data, such as location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level;
• Demographic information, such as your country and preferred language.

We do not collect or process any so-called “special categories of personal data”, which according to the GDPR include details about your race or ethnicity, religious beliefs, sexual orientation, political opinions, health, biometric data, nor do we collect any information about criminal convictions and offences.

HOW AND WHY WE PROCESS YOUR DATA

CASAFARI collects your personal information in various ways, through interactions with you or by completing and submitting the forms available on the "Housing for Refugees" Platform, which is always carried out in accordance with the GDPR, and other applicable legislation in force. 

CASAFARI collects and processes data on the "Housing for Refugees" Platform, with the specific purpose of helping refugees to find urgent shelter according to their specific accommodation needs, connecting them with property owners throughout Europe, who have previously offered to provide shelter under the terms of this platform. The collection and processing of data on this platform is of a humanitarian and non-profit nature, with the primary scope of helping all people affected by the outbreak of armed conflict in Ukraine, thus bringing together on the same platform those who need to find safe accommodation, and those who can provide it.

Additionally, the collection and processing of the aforementioned data will only take place to the extent that any of the legal grounds foreseen in the law and in the GDPR can be supported, namely, the fulfillment of a legal obligation or the specific, informed and unequivocal consent of the data holder to the collection and processing of such data for the specific purpose for which they are intended.

In other words, we will only process your personal data if we are mandated by any legal obligation or if you provide us with your express and unequivocal consent to process them, and they will be processed in accordance with the principles set out in Article 5 of the GDPR: 

• Your Personal  Data will be processed lawfully, fairly and transparently (Principle of lawfulness, fairness and transparency);
• Your Personal Data will be collected only for specified, explicit purposes and may not be further processed in a manner incompatible with those purposes (Purpose limitation Principle);
• Your Personal Information will be be processed in a manner that is adequate, relevant and limited to what is actually necessary for the purposes for which they are processed (Principle of data minimization);
• Your Personal Data will be kept accurate and up-to-date whenever necessary; Every reasonable step will be taken to ensure that data which is inaccurate, taking into account the purposes for which it is processed, is erased or rectified without delay (Principle of Accuracy);
• Your Personal Data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed (Principle of Limited Conservation);
• Your Personal Data will be handled in a manner that ensures their security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by adopting the most appropriate technical or organizational measures (Principle of Integrity and Confidentiality).

However, if you change your mind, you can always withdraw your consent. The withdrawal of consent is an explicit expression of will whereby the data subject indicates, by a statement or an unequivocal positive act, that he or she wishes to withdraw consent for personal data relating to him or her not to be processed. It does not affect the lawfulness of processing based on consent given previously and, just as consent covers all processing for the same purpose or purposes, withdrawal of consent covers processing carried out for the same purpose or purposes.

YOUR RIGHTS

You can update, remove and/or exercise other rights related to your personal data by contacting Us at legal@casafari.com.

We aim to ultimately ensure your rights under applicable data protection laws:

• Data subject access request: the right to request and obtain details of your personal information and be provided with a copy of the personal data undergoing processing;
• Right to rectification – update your personal data: the right to obtain without undue delay the rectification of any incomplete or inaccurate personal data;
• Right to erasure (right to be forgotten): the right to have certain personal data about you erased and no longer processed where the personal data is no longer necessary in relation to the purposes for which they were initially collected; where the consent has been withdrawn or objects to the processing; or where such processing does not comply with the applicable legislation;
• Right to restriction of processing: the right to request that your personal information is only used for restricted purposes;
• Right to data portability: the right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format (i.e., electronic file);
• Right to object: the right to object to the processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interest.

In response to a request, We will ask you to verify your identity if we need to, and to provide information that helps Us to understand your request better. If we do not comply with your request, whether in whole or in part, We will provide you with a reasonable and appropriate explanation. 

WHO DO WE SHARE PERSONAL INFORMATION WITH

We share your information for the purposes set out in this Policy, with the following categories of recipients:

• CASAFARI group companies; 
• Third parties, when you give us consent to do so.

Processor

To support the delivery of our services, CASAFARI relies on service providers. Any third-parties engaged by CASAFARI that might have access or process data that may contain Personal Data is considered a processor. CASAFARI performs a security and privacy review of the practices of any processors before engaging with them. Our current processors are:

• Zapier – Integration Manager 
• Azure Web services - Cloud service provider
• Mailchimp - Newsletter service 
• SendInBlue - Newsletter service 
• Casa Safari, Lda - Service Provider.

Any processor and/or subcontractor used by CASAFARI is put under thorough scrutiny to assess their security, confidentiality and privacy policies.

DATA SECURITY 

CASAFARI, as the managing entity of the "Housing for Refugees" Platform, adopts various security measures, of technical and organizational nature, in order to guarantee the confidentiality of the personal information it holds, so as to protect your personal data against loss, dissemination, alteration, unauthorized processing or access, as well as against any other form of unlawful processing.

HOW LONG DO WE KEEP PERSONAL INFORMATION?

The period of time for which personal data can be kept varies according to the purpose for which it was collected, and sometimes there are legal requirements that require data to be kept for a minimum period of time. 

If there are no such requirements, the data will be kept only for the minimum period necessary for the purposes for which it was collected and subsequently processed. 

At the end of the conservation period, all personal data collected will be anonymised or deleted.

COOKIES AND SIMILAR TECHNOLOGIES

We also place a small text file known as a “cookie” on your computer’s hard drive. The use of cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities across applications, websites, or other services. 

A cookie may contain information that allow Us to track your path through the platform. Cookies do not harm your computer or any files on your computer; it cannot be used to read data off of your hard drive and cannot retrieve information from any other cookies created by other websites. 

You can manage website cookies in your browser preferences – you will always have the choice to accept, reject or delete cookies. However, if you choose to change your settings, it may result in a loss of functionality for your browser, not only on Our platform, but also others. Therefore, for the purposes of enhanced functionality and because cookies do not provide Us with any information from which we can identify you, We suggest you allow Us to place them on your computer.

We use cookies for the following purposes:

• Authentication/Status: identify when you visit Our platform, if you are logged in, and as you navigate through it. 
• Analytical/Performance cookies: allow Us to understand how you use Our platform, i.e., operating systems used, number of visits, average duration of visits, pages viewed, etc. Overall, these cookies are used to improve the way Our platform  works and enhance your user experience. 
• Functionality cookies: these cookies allow the pla to remember choices you make and provide enhanced, more personal features, i.e., greet you by your chosen user name and remember your preferences. 
• Security: We use cookies as an element of security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our platform.

Do We use any non-cookie tracking technologies

Although not at all times, We may also use web beacons (including conversion pixels) or other technologies for similar purposes as described on this section, and We may include these on Our platform. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor platform activity.

Tracking and Do-Not-Track Signals 

While browsers allow you to disable the usage of cookies, We do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser. We will not for any marketing purposes, load cookies/web beacons or any other kind of software that tracks your general behavior while you are visiting third party websites. We do, however, track if you click on advertisements for CASAFARI services on third-party platforms such as search engines and social networks and may use analytics to track what you do in response to those advertisements.

EU-US PRIVACY SHIELD

Privacy shield is a framework for transatlantic exchanges of personal data for commercial purposes that protects the fundamental rights of individuals where their data is transferred to the United States and ensures legal certainty for businesses. 

It may occur that some of Our processors are based outside the European Economic Area (EEA) so their processing of your personal data involves a transfer of data outside the EEA. If and whenever this happens, We ensure there are adequate safeguards and a similar degree of security is applied, including relying on Privacy Shield, Model Clauses approved by the European Commission, amongst other legal options, otherwise the transfer only occurs where permitted by applicable law, given that the ultimate aim is to ensure that your privacy rights continue to be protected as per this Policy.

DATA DISCLOSURE

CASAFARI does not sell, provide or disclose any kind of personal data. All the data we store is kept in encrypted databases and transported in secure channels and will not be accessed for any purposes other than provisioning, maintaining and improving our Platform. 

CASAFARI only discloses personal data to third parties, for the purposes set out in this policy, if we have the legal grounds to do so, such as your specific, informed and unequivocal consent, or if we are mandated to do so in order to comply with legal obligations.

UPDATES TO THIS POLICY

This Policy may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Policy affecting you will be communicated to you through an appropriate channel.

As of 31st of January 2022, CASAFARI is GDPR compliant.