Privacy Policy and Data Protection

Last update: November 15th 2019

This Privacy Policy describes the way in which we collect, use, process and disclose your information, including your personal data and your access data to the LivingMad website and the Payment Services and their use thereof.

If you see any term whose definition is not included in this Privacy Policy, it means that said term must be interpreted in accordance with the definitions included in our Terms and Conditions.

Any reference to this document is made to “LivingMad”, “we”, “our (s)”, or “us” refers to the society of Ca Deco & Living S.L. responsible for your information in accordance with this Privacy Policy (hereinafter, the ‚ÄúResponsible for the Data Processing‚ÄĚ).

This Privacy Policy also concerns Payment Services that LivingMad provides to you in accordance with the provisions of the Terms and Conditions When you use the Payment Services, you will also be providing your data, including your personal data, to one or several banking entities, which will also perform the functions of Responsible for the Processing of Data (hereinafter, the ‚ÄúResponsible for the Processing of Data of Payment ‚ÄĚ) of your information related to Payment Services depending on your Country of Residence:

1. DATA WE COLLECT

We collect information that belongs to three general categories:

> 1.1 Data you provide us

1.1.1 Information collected from the Living Mad website / Emails associated with LivingMad staff.

We request and collect the following personal information about you when you use the LivingMad Web and communicate with us through any of our communication channels (website, LinkedIn, Facebook, contact phone number, LivingMad staff phones). These data are necessary for the correct execution of our services and the contract signed between you and us and allow us to fulfill our legal obligations. Without this information, we may not be able to provide all the requested services.

o Contact form: When filling out the contact form and information (general or of a specific property), we require certain information such as name, surname, email address and telephone.

o When filling out the admission form, we require certain information such as name, surname, ID / Passport number, email address, telephone number and acceptance letter to the University or work. If the person to stay is a minor, data from parents / legal guardians are also requested. This form is related to the CRM Rentger tool, where the data will be collected for proper storage.

o Payment Information: To use certain functions of the LivingMad website (such as booking or making rent payments or other services related to our business), we may ask you for some financial information (such as your bank account or credit card details) in order to process payments (through the POS of the website or direct debits).

o Communications with LivingMad and other members: When communicating with LivingMad or using the LivingMad Web or its social media accounts (such as Facebook, LinkedIN, Instagram, Whatsapp, etc.) to communicate with members of the LivingMad team, we collect information about of these communications and any data you choose to provide.

o Reservations: Once you have contacted LivingMad through the contact form, direct mail, telephone or social networks, you must fill in the reservation form or we can request additional information, which may include your address and telephone number and data of one of Your parents or legal guardian. Before formalizing any reservation, we will ask for this documentation:

o Copy of ID / Passport / NIE

o Family address in country of residence

o Letter of acceptance to the University / School / Work

o 3 last payrolls

o Signed contract

We will need to have these documents before you enter to live in our apartments. You can send them to us by mail or through our reservation form.

1.1.2 Information you voluntarily provide.

You can provide us with additional personal data to obtain a better user experience when using the LivingMad website or communicate with the members of the LivingMad team via email / Whatsapp / phone calls / Digital media. This additional information will be processed with your consent.

o Additional Information. You can provide additional information as part of your LivingMad profile (such as your gender, preferred language (s), city and a personal description).

o Contact information for the Address List. Usted podrá optar por importar los contactos de su Listado de Direcciones o introducir la información de sus contactos de forma manual para poder acceder a determinadas funciones de la web de LivingMad, como animar a éstos a utilizar la web de LivingMad.

o Other information. You can choose to provide us with information when filling out any form or do a search, update or add information through our contact or worker emails, worker mobile or company phone, answer surveys, participate in promotions or use other functions from the LivingMad website.

1.1.3 Information necessary for the use of Payment Services.

The Person Responsible for the Treatment of Payment Data needs to collect the following data, since they are necessary for the proper execution of the contract entered into with you and for compliance with the applicable legislation (such as regulations for the prevention of money laundering). Without this information, you will not be able to use the Payment Services:

o Payment information. When using the Payment Services, the Person Responsible for the Processing of Payment Data will require certain financial data (such as your bank account or credit card information) to process payments and comply with applicable legislation

>1.2 Information that we automatically collect fromyour use of the LivingMad Web and Payment Services.

By using the LivingMad website and Payment Services, we automatically collect information, including your personal data, about the services you use and how you use them. This information is necessary for the correct execution of the contract between you and us, for the fulfillment of our legal obligations and given our legitimate interest in being able to provide and improve the functions of the LivingMad website and the Payment Services.

o Geographic location data. By using certain functions of the LivingMad website, we may collect information about your precise or approximate location from data such as your IP address or the GPS of your mobile device to offer you a better user experience. Most phones allow you to control or disable the use of location services for applications in the device settings menu. LivingMad may also collect this information when you are not using the application if location services are activated in the settings menu or in the permissions of your device.

o Usage Information We collect information about the interactions you have with the LivingMad website, such as the pages or other content you view, the searches for Ads you make, the reservations you have made and other actions carried out on the LivingMad website.

o Registration data and information about your device.We automatically collect registration information and your device every time you access and use the LivingMad website. This information includes, among other information, details about how you have used the LivingMad website (including if you clicked on links to third-party applications), IP address, dates and times of access, hardware and software information, information on device, device event information, unique identifiers, data on blockages, data on cookies and the pages you have viewed or interacted with before or after using the LivingMad website.

o Transactional Information LivingMad collects information related to your payment transactions made through the LivingMad website, including the payment instrument used, the date and time, the payment amount, the expiration date of the payment instrument and the billing postal code , the IBAN code, your address and other transactional data. These data are necessary for the correct execution of the contract between you and us and for the provision of Payment Services.

> 1.3 Information we collect from third parties

LivingMad may collect information, including personal data, that others provide about you each time they use the LivingMad website and Payment Services, or obtain information from other sources and combine it with what we collect through the website of LivingMad and Payment Services. We do not control, supervise or respond in the way that the third parties that provide your information process your personal data and any request for information regarding the disclosure of your personal data that has been made to us must be directed to said third parties.

o Background Information. In relation to Members residing in the United States, LivingMad may, to the extent permitted by applicable law, obtain reports from public records of criminal records or sex offender listings. In relation to Members residing outside the United States, LivingMad may, to the extent permitted by applicable law and subject to their consent where appropriate, obtain the local version of the history of police, criminal records or inclusion in listings of sex offenders LivingMad may use your information, including full name and date of birth, to obtain such reports.

o Other sources. To the extent permitted by applicable law, LivingMad may receive additional information about you, such as demographic data or fraud detection data, from third party service providers or partners and combine it with the information we have about you. For example, we may receive the results of criminal background checks (with your consent, where appropriate) or warnings about fraud from identity verification services for the purposes of our fraudulent practices prevention and risk assessment. LivingMad may receive information about you and your activities on and off our Website through our partners or information about the experiences and interactions you have had through our network from associated advertisers.

2. HOW WE COLLECT INFORMATION

LivingMad uses, stores and processes information about you, including your personal data, to provide, understand, improve and develop our website and to create and maintain an environment of trust and with better security conditions and to fulfill our legal obligations.

> 2.1 Provide, improve and develop the LivingMad website

o Allow you to communicate with other Members.

o Direct, protect, improve and optimize the LivingMad website and the LivingMad experience, for example, through analysis and research.

o Provide customer service.

o Send you messages and emails about the service or support, such as updates, security alerts and notifications.

o If you provide us with your contact information, we may submit it to treatment: i) to send you promotional emails or notices from LivingMad or its partners; ii) to send your requests for references; iii) to carry out detection and prevention of fraudulent activities; iv) and for any purpose you authorize at the time of collection.

o To direct, protect, improve and optimize the LivingMad website and the LivingMad experience, as well as to personalize your experience (for example, by suggesting some specific property), we analyze the preferred content that you send to the web, social networks and LivingMad email accounts.

LivingMad processes this information in view of our legitimate interest in improving our website and the experience of our Members in it.

> 2.2 Create and maintain an environment of trust and better security conditions

o Detect and prevent fraud, spam, insults, security incidents and other harmful acts.

o Conduct safety investigations and risk assessments.

o Verify or authenticate information or identifications that you have provided (eg, to verify your Accommodation address or compare the photo that identifies you with another photo you provide).

o Check with databases and other sources of information, including criminal and police background checks, to the extent permitted by applicable law and subject to your consent, where appropriate.

o Comply with our legal obligations.

o Resolve any dispute arising with any of our Members and demand compliance with our contracts with third parties.

o Exigir el cumplimiento de nuestros Términos y Condiciones

In relation to the preceding activities, we may analyze the interactions you make with the LivingMad website, your profile information and any other content you submit to the LivingMad website, as well as information obtained from third parties. In certain cases, automated processes may restrict or suspend your access to the LivingMad website if such processes detect a Member or an activity that may pose a security or other risk to the LivingMad website, other Members or third parties.

Nosotros procesamos esta información habida cuenta de nuestro interés legítimo por proteger la web de LivingMad, para valorar la correcta ejecución del contrato formalizado con usted y para cumplir la legislación aplicable.

> 2.3 Provide, customize, measure and improve our advertising and marketing

o Send you promotional messages, marketing content, advertising and other information that might interest you based on your preferences (including information related to LivingMad or partner campaigns and services), as well as advertising through social communication platforms such as Facebook or Google.

o Customize, measure and improve our advertising.

o Manage recommendation programs, prizes, surveys, sweepstakes, contests or other promotional activities or events sponsored or managed by LivingMad or by our Third Business Partners.

o Outline your characteristics and preferences (from the information you provide us, your interactions with the LivingMad website, information obtained from third parties and your search and reservation history) to send you promotional, marketing or advertising messages, as well as Other information that we believe may be of interest.

We will process your personal information for the purposes set out in this section in view of our legitimate interest in conducting marketing activities to offer you products or services that may be of interest to you. You can unsubscribe from these marketing communications by following the instructions in this regard in our marketing communications.

> 2.4 How the Responsible for the Processing of Payment Data uses the information collected.

o To allow you to access and use the Payment Services.

o To detect and prevent fraud, abuse, security incidents and other harmful activities.

o To carry out safety investigations and risk assessments.

o To perform checks of databases and other sources of information.

o To comply with its legal obligations (such as regulations for the prevention of money laundering).

o To apply the Payment Terms and other payment policies.

o With your consent, to send you promotional, marketing, advertising and other information that may be of interest to you based on your preferences.

The Person Responsible for the Processing of Payment Data processes this information in view of his legitimate interest in improving Payment Services and the experience of its users with them, and to the extent necessary for the proper execution of the contract entered into with you. , as well as to comply with applicable legislation.

3. SHARE AND DISCLOSURE OF INFORMATION

> 3.1 With your consent

When you have given your consent, we may share your information, including your personal data, as they appear at the time you have given your consent, such as when you authorize a third party application or website to access your data or when you participate in promotional activities carried out by LivingMad partners or third parties.

We do not share your billing and disbursement information with other Members.

> 3.2 Profiles, Ads and other public information

All information that you share publicly on the web or Social Networks of LivingMad can be indexed through third-party search engines. In some cases, you may disable this feature in your Account settings. If you change your settings or your available public content, these search engines will not be able to update their databases. We do not control the practices of third-party search engines, which may use cache memories that contain obsolete information about you.

> 3.3 Additional Services provided by LivingMad

LivingMad may require Third Party Services to assist in the management of your Accommodation or the provision of Additional Services that you request, such as cleaning, insurance companies or locksmith services. LivingMad may share your name and phone number with these third-party service providers in order to coordinate the stay, manage the Accommodation or provide other services. LivingMad podrá compartir su nombre y teléfono con dichos terceros proveedores de servicios con el fin de coordinar la estancia, gestionar el Alojamiento o prestar otros servicios.

> 3.4 3.4 Regulatory compliance, response to legal requirements, damage prevention and protection of our rights.

LivingMad may disclose your information, including your personal data, to courts, state security forces or bodies or government agencies, or to authorized third parties, in case we are obliged or authorized to do so in accordance with the law or in case such disclosure is justifiably necessary: ‚Äč‚Äči) to comply with our legal obligations, ii) to comply with legal proceedings and to respond to claims of rights filed against LivingMad; iii) to respond to certified requirements related to investigations by the judicial police or to alleged or alleged illegal activities or of any other nature that could expose us, you or any of our users to legal responsibility; iv) to demand compliance with our Terms of Service, Payment Terms or other contracts with partners and regulate them, or v) to safeguard the rights, property or personal safety of LivingMad, its employees, its Members or members of the public.

> 3.5 Service providers

LivingMad uses various third-party service providers to help us provide services related to our Website, apartments maintenance, accounting and billing and Payment Services.

Service providers may help us, for example, to the following: i) verify or authenticate their identification documents; ii) collate information with public databases; iii) conduct criminal or police background checks, prevention of fraudulent practices and risk assessment; iv) perform product development, maintenance and error resolution tasks; v) allow the provision of LivingMad Services through third-party softwareplatforms and tools (for example, through integration with our APIs), or vi) provide customer service, advertising or payment services. Such providers have limited access to your data to carry out these tasks on our behalf and are obliged by contract to protect and use them only for the purposes for which they have been disclosed and in a manner consistent with this Privacy Policy.

LivingMad will have to share your information, including your personal data, to ensure the correct execution of the contract between you and us.

> 3.6 Communication platforms

When applicable law permits, we may use certain personal information about you, such as your email address, to use it as hashand to share it with social communication platforms, such as Facebook or Google, to generate leads, direct the traffic to our websites or otherwise promote our products and services or the LivingMad website. These treatment activities are based on our legitimate interest in conducting marketing activities to offer you products or services that may be of interest to you.

The social communication platforms with which we may share your personal information are not subject to control or supervision by LivingMad. Therefore, any question regarding the way in which your social communication platform service providers treat your personal data should be addressed to those providers.

Please note that you can request LivingMad at any time to interrupt the processing of your data for these direct marketing purposes by sending an email to info@livingmad.es

> 3.7 Commercial transmissions

If LivingMad carries out a merger, acquisition, reorganization, sale of assets or enters into a bankruptcy or bankruptcy proceeding, or if this company participates in any such process, we may sell, transmit or share all or part of our assets, including your information related to said transaction or related to it (for example, in a purchase audit). In this case, we will inform you before your personal data is transferred and becomes subject to a different privacy policy.

> 3.8 Aggregate data

LivingMad podrá también compartir datos agregados (información sobre nuestros usuarios que combinamos de modo que deje de identificar o aludir a un usuario concreto) y otra información anonimizada necesaria para el cumplimiento normativo que no le identifique con fines de análisis sectoriales y de mercado, elaboración de perfiles demográficos, marketing, publicidad y demás fines comerciales.

4. OTHER IMPORTANT INFORMATION

> 4.1 Google Maps/Google Earth

Some parts of the LivingMad website use Google Maps / Google Earth services, including Google Maps APIs. The use of Google Maps / Google Earth is subject to the Additional Terms of Service of Google Maps / Google Earth and the Google Privacy Policy.

5. THIRD PARTNERS AND THIRD PARTY INTEGRATIONS

The LivingMad website may contain links to websites or Third Party Services, such as third party integrations, joint brand services or third party branded services (hereinafter, ‚ÄúThird Party Partners‚ÄĚ). LivingMad does not own such Third Party Partners or control them and, when you interact with them, you may be providing information directly to the Third Partner, LivingMad or both. Such Third Partners usually have their own rules regarding the collection, use and dissemination of information. We encourage you to review the privacy policies of the other websites you visit.

6. YOUR RIGHTS

You may exercise the rights set forth in this section before your Data Processing Manager or the Payment Data Processing Manager by sending an email to info@livingmad.es Please note that we may ask you to verify your identity before take any action you have requested.

> 6.1. Rectification of incorrect or incomplete information

You have the right to ask us to rectify any incorrect or incomplete personal information related to you.

> 6.2 Data retention and deletion

In general, we retain your personal information for as long as necessary for the execution of the contract between you and us and to fulfill our legal obligations. If you do not want us to continue using your information, you can ask us to delete your personal information. Please note that if you request the deletion of your personal information:

o We may retain some of your personal data to the extent necessary for our legitimate business interests, such as detecting and preventing fraud and improving security.

o We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, LivingMad may retain some of your information in compliance with its tax, legal and audit information obligations.

o Since we make sure to protect the LivingMad website from loss or accidental or malicious destruction, it is possible that your personal information is not deleted from our backup systems for a limited period of time.

> 6.3 Revocation of consent and restriction of data processing

In those cases in which you have authorized the processing of your personal information by LivingMad, you may revoke your consent at any time by sending a communication to LivingMad specifically indicating the consent you wish to revoke. Please note that the revocation of your consent does not affect the legality of the data processing subject to your consent that was made before said revocation.

> 6.4 Opposition to data processing

In some jurisdictions, applicable law may grant you the right to require LivingMad not to process your personal information for specific purposes (including the analysis of its activity for profiling purposes) when such treatment is carried out based on legitimate interest. If you object to such treatment, LivingMad will stop processing your personal data for such purposes unless we can demonstrate that there are justified and convincing causes to perform such treatment or unless such treatment is necessary for the initiation, exercise or defense of actions legal.

If your personal information is processed for direct marketing purposes, you may at any time ask LivingMad to interrupt such data processing for commercial marketing purposes by sending an email to info@livingmad.es

> 6.5 Submission of claims

You have the right to submit claims related to the data processing activities carried out by LivingMad before the competent data protection authorities

7. CHANGES TO THIS PRIVACY POLICY

LivingMad reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will publish the revised version of this on the LivingMad website and update the ‚ÄúLast update‚ÄĚ date, which appears at the beginning of this document. Likewise, we will notify you of the modifications by sending you an email at least thirty (30) days before they become

8. CONTACT

If you have any questions or complaints about this Privacy Policy or about the information manipulation practices of LivingMad, you can contact us by mailto:info@livingmad.esor by sending a letter to the following address: C / Mantuano 4, 28002, Madrid, Spain.

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