Privacy Policy

1. Who controls your data

The data controller is Territorium Inmobiliario S.L., incorporated in Spain, CIF B90123456, registered office at Passeig de Gràcia 89, 4-2, 08008 Barcelona. For any privacy question, write to privacy@territorium.eu.

2. Data Protection Officer

Our Data Protection Officer is reachable at dpo@territorium.eu for any query about how we handle your personal data or to exercise your rights. [COUNSEL] — confirm whether appointment is mandatory per Article 37 given our processing volume; if not, a Privacy Contact is sufficient.

3. Data we collect + how

• Account data — name, email, phone, preferred language and currency, password hash (never the password itself). Source: you, at signup.
• Verification data (Landlords) — national ID or passport, proof of address, title deed extract or rental management mandate, tax residence certificate, bank account name + IBAN, signature specimen. Source: you, at partner onboarding.
• Contract + payment data — the lease document, signature audit trail (stroke count, timezone, document hash), payment reference numbers, verification timestamps, invoice PDFs. Source: you + the counterparty.
• Messaging data — messages you send through the in-app conversation, including timestamps + read receipts. Source: you.
• Technical data — IP address, browser + OS, session cookies, error logs, aggregate usage counters. Source: your browser, our servers.
• Analytics data — aggregate page-view + interaction counts via Plausible + PostHog. Source: your browser, only if you accept analytics cookies.
• Marketing data — newsletter subscription state, campaign engagement. Source: you, on opt-in.

4. Why we process — purpose + lawful basis

5. Who we share with

• Your counterparty — the Landlord sees your application + signed Contract; the Tenant sees the Landlord's verified identity + Property details.
• Payment banks — SEPA / domestic bank rails carry the transfer memo + amount but not other account data.
• Verified Photographers — where we don't operate on-the-ground, an accredited local photographer signs a data-processing agreement + walks the Property.
• Cloud infrastructure — Cloudflare (edge CDN + WAF), Amazon Web Services (object storage for uploads + backups), Laravel Forge (server orchestration). All under Data Processing Agreements + EU regions.
• Communications — SMTP provider for transactional email, PostHog for analytics (only if you accept), Plausible for aggregate stats (only if you accept).
• Legal + regulatory — a competent authority, if we're required by law to disclose (subpoena, court order).

We do not sell your personal data. We do not disclose your data to advertisers. [COUNSEL] — confirm each processor's SCC or adequacy status; document any transfer to a third country outside the EU/EEA.

6. How long we keep it

• Account data — while the account is active + 3 years after closure for reactivation grace.
• Verification data — 7 years (Spanish AML retention); shorter where a jurisdiction imposes a lower cap.
• Contract + payment data — 10 years (accounting + civil claim limitation). Signed PDF + audit trail: 15 years.
• Messaging data — 3 years after the last message; earlier on request unless required for a legal claim.
• Technical + error logs — 90 days rolling.
• Analytics data — aggregate only, 24 months.
• Marketing subscriptions — until you unsubscribe. Unsubscribe processed within 72 hours.

After the retention period, data is anonymised (aggregate stats retain) or deleted. [COUNSEL] — confirm retention caps against local transposition of GDPR + sector-specific laws (AML5, tax code).

7. Your rights

Under GDPR you have the right to:

• access the personal data we hold on you (Article 15)
• rectify inaccurate or incomplete data (Article 16)
• erase your data when the legal basis no longer applies (Article 17)
• restrict processing while a dispute is resolved (Article 18)
• data portability — receive a machine-readable export (Article 20)
• object to processing based on legitimate interest (Article 21)
• withdraw consent at any time, where consent is the basis (Article 7.3)

To exercise any of these, write to privacy@territorium.eu — we respond within 30 days.

8. Right to complain

You may lodge a complaint with the Spanish Agencia Española de Protección de Datos (AEPD, C/ Jorge Juan 6, 28001 Madrid, aepd.es) or with your local supervisory authority. [COUNSEL] — supplement with the relevant DPA per jurisdiction we serve.

9. Automated decision-making

We do not make decisions that produce legal effects on you solely by automated means. Application review, verification decisions, and dispute outcomes involve a human in the loop. Our fraud + abuse triage models flag activity for review; they do not autonomously suspend accounts.

10. Cookies + trackers

See our Cookie Policy for the full list of cookies + local-storage keys we use, the categories they fall under, and the retention per category. Non-essential cookies fire only after you accept via the consent banner.

11. Changes to this policy

We may update this policy from time to time. Material updates are notified by email + a banner on the site at least 30 days before they take effect. The "last updated" date at the bottom reflects the current version.