PRIVACY POLICY

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Sourcified platform accessed via 'flatmate.com.mt' and 'lets.flatmate.com.mt'.

If you see an undefined term in this Privacy Policy it has the same definition as in our Terms of Service.

When this policy mentions “Sourcified”, “Flatmate”, “we”, “us”, or “our”, it refers to the Sourcified Limited (Sourcified LLC) company that is responsible for your information under this Privacy Policy (“Data Controller”).

This Privacy Policy applies to all other Terms specified on the Sourcified platform accessed via 'flatmate.com.mt' and 'lets.flatmate.com.mt'.

1.0 Information we collect

1.1 Information you give to us

1.1.1 Information that is necessary for the use of the Sourcified platform

We ask for and collect the following personal information about you when you use the Sourcified platform via 'flatmate.com.mt' and 'lets.flatmate.com.mt'. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. With it, we may not be able to provide your with all the requested services.

Account information. When you sign up for an Flatmate account on the Sourcified platform, we require certain information such as your first name, last name, email address and date of birth.
Profile and Listing information. To use certain features of the Sourcified platform, we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
Identity verification information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
Payment information. To use certain features of the Sourcified platform, we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments via Sourcified payments.
Communications with Sourcified and other Members. when you communicate with Sourcified or use the Sourcified platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

1.1.2 Information you choose to give us

You may choose to provide us with additional personal information in order to obtain a better user experience when using Sourcified platform. this additional information will be processed based on your consent.

Additional profile information. You may choose to provide additional information as part of your Flatmate profile (such as gender, preferred language, city and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
Other information. You may choose to provide us information when you fill in a form, conduct a search, update or add information to your Flatmate account, respond to surveys, post to community forums, participate in promotions, or use other features of the Sourcified platform.

1.1.3 Information that is necessary for the use of the Payment services

The Payments Data Controller sometimes needs to collect the following information, as it is might be necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). We might have to share this data with third party Payments Data Controller such as PayPal. Without this information, you will not be able to use payment services.

Identity verification and other information. If you are a Seller, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the payment services to you, and to comply with applicable law.

1.2 Information we automatically collect as you use Flatmate website and Sourcified platform

When you use the Sourcified platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligation and given your legitimate interest in being able to provide and improve the functionalities of the Sourcified platform.

Geo-location information. When you use certain features of the Sourcified platform, we may collect information about your precise or approximate locations as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience based on your location. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Sourcified may also collect this information even when you are not using the application if this connection is enabled through your settings or device permissions.
Usage information. We collect information about your interaction with the Sourcified platform such as the pages or content you view, your searches for Listings, Users, and other actions on the Sourcified platform.
Log data and device information. We automatically collect log data and device information when you access and use the Sourcified platform, even if you have not created an Flatmate account or logged in. That information includes, among other things: details about how you’ve used the Sourcified platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Sourcified platform.
Cookies and similar technologies. We use cookies and other similar technologies, such as pixels and mobile identifiers. We may also allow our business partneres to use these tracking technologies on the Sourcified platform, or engange other to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, the Sourcified platform
Payment transaction information. Sourcified payment services collects information related to your payment transactions through the Sourcified platform, including the payment instrument used, date and time, payment amount, payment instrument, PayPal email address, your address and other related transaction details. This information is necessary for adequate performance of the contract between you and Sourcified and to allow the provision of the payment services.

1.3 Information we collect from third parties

Sourcified may collect information, including personal information, that other provide about you when they use the Sourcified platform, or obtain information from other sources and combine that with information we collect through the Sourcified platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, any any information request regarding the disclosure of your personal information to us should be direct to such third parties.

Third party services. If you link, connect, or login to your Flatmate account with a third party service (i.e. Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Your references. If someone has written a reference or review for you, it will be published on your Flatmate public profile with your consent.
Background information. Sourcified, to the extent permitted by applicable laws and with your consent where required, may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
Other sources. To the extent permitted by applicable law, w may receive additional information about you, such as demographic data or fraud detection information, from third party service provides and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud preventions and risk assessment efforts. We may receive information about you and your activities on and off the Sourcified platform through partnership, or about your experiences and interaction from our partner ad networks.

2. How we use information we collect

We use, store, and process information, including personal information about you to provide, understand, improve, and develop the Sourcified platform, create and maintain a trusted and safe environment and comply with our legal obligations.

2.1 Provide, improve and develop the Sourcified platform

Enable you to access and use the Sourcified platform
Enable you to communicate with other Members
Operate, protect, improve and optimize the Sourcified platform and experience, such as by performing analytics and conducting research
Provide customer service
Send you service or support messages, updates, security alerts, and account notifications
To operate, protect, improve and optimize the Sourcified platform and experience and personalize and customize your experience (such as ranking search results), we conduct profiling based on your interactions with the Sourcified platform, your search history, your profile information and preferences, and other content you submit to the Sourcified platform.

We process this information given our legitimate interest in improving the Sourcified platform and our Members experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and maintain a trusted and safe environment

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity
Conduct security investigations and risk assessments
Verify or authenticate information or identions provided by you such as to verify your Accommodation address or compare your identification photo to another photo your pvide
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required
Comply with our legal obligations
Resolve any disputes with any of our Members and enfore our agreements with third parties
Enforce our Terms of Service and other Policies and Standards
We may conduct profiling based on your interaction with the Sourcified platform, your profile information and other content you submit to the Sourcified platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Sourcified platform if such processes detect a Member or activity that we think poses a safety or other risk the Sourcified platform, other Member, or third parties.

We process this information given our legitimate interest in protecting the Sourcified platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Provide, personalize, measure and improve our advertising and marketing

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Sourcified or partner campaigns and services) and social media advertising through social media platforms such as Facebook, Google or Instagram)
Personalize, measure, and improve our advertising
Administer surveys, contests or other promotional activities or events sponsored or managed by Sourcified or its third party partners.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Sourcified platform, information obtained from third parties and your search history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that maybe be for your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Flatmate account.

2.4 How payment services uses the information collected

Enable you to access and use the payment services
Detect and prevent fraud, abuse, security incidents, and other harmful activity
Conduct security investigations and risk assessments
Conduct check against databases and other information sources
Comply with legal obligations (such as anti-money laundering regulations)
Enforce the Extended Terms of Service and other Payment policies
With your consent, send you promotional messages, marketing, advertising, and other information that maybe be of interest to you based on your preferences

The payments data control processes this information given its legitimate interest in improving the Payment services and the experience with it, and where it is necessary for the adequate performance of the contract with your and to comply with applicable laws.

3. Sharing and Disclosure

3.1 With your consent

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Flatmate account or when you participate in promotional activities conducted by Sourcified partners or third parties.

3.2 Sharing between Members

To help facilitate with interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

When you as a Flatmate Member submit a request, certain information about you is shared with the other Member.
When you as a Member invite new users to the Sourcified platform additional information will be shared, such as email address

3.3 Profiles, listings and other public information

The Sourcified platform lets you publish information, including personal information, that is visible to the general public. For example:

Parts of your public profile page that is visible to others
Listing pages are publicly visible and include information such as the Accommodation location or precise location, listing description, calendar availability, shipping fees, your public profile photo and any additional information you choose to share
If you submit content in a community or discussion forum, blog or social media port, or use a similar feature on the Sourcified platform, that content is publicly visible

Based on our legitimate interest to promote the Sourcified platform we may display parts of the Sourcified platform on sites operated by Sourcified business partners, using technologies such as widgets or iframes. If your Listings are displayed on a partner site, information from your public profile page may also be displayed.

Information you share publicly on the Sourcified platform may be indexed through third party search engines such as Google. In some cases, you may opt-out of this feature by contacting us. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4 Compliance with law, responding to legal requests, preventing harm and protection fo rights

Sourcified may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary, to comply with our legal obligations, to comply with legal process and to respond to claims asserted against Sourcified, to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, to enforce and administer our Terms of Service and ny other Terms, Policies or Standards with Members, or to protect the rights, property or personal safety of Sourcified, its employees, its Members, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Sourcified platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

Where appropriate, we may notify Members about legal requests unless: providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Sourcified’s property, its Members and the Sourcified platform. In instances where we comply with legal request without notice for these reasons, we will attempt to notify that Members about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.5 Service providers

Sourcified uses a variety of third party service providers to help us provide services related to the Sourcified platform and our services. Service providers may be located inside or outside of the European Economic area (“EEA”).

For example, service providers may help us verify your identity or authenticate your identification documents, check information against public databases, conduct background or police checks, fraud prevention and risk assessment, perform product development, maintenance and debugging, provide customer service, advertising. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was discloses and consistent with this Privacy Policy.

Sourcified will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.6 Corporate affiliates

To enable or support us in providing the Sourcified platform, we may share your information, including personal information, within our corporate family of companies and products (both financial and non-financial entities) that are related by common ownership or control.

Sharing with Sourcified Limited (Sourcified LLC). Your information is shared with Sourcified which provides the technical infrastructure and all services of the Sourcified platform and your Flatmate account, product development and maintenance, customer support, trust and safety and other business operation services to other Sourcified services and products.The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Sourcified platform internationally.

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote and to improve the Sourcified platform and our affiliates services.

3.7 Social media platforms

Where permissible according to applicable law we may use certain limited personal information about your, such as your email address, to hash it and to share it with social media platforms, such as Facebook, Instagram or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Sourcified platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Sourcified. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

3.8 Government registration

In jurisdictions where Sourcified facilitates or requires a registration, notification, permit, or license application of a Member with a local governmental authority through the Sourcified platform in accordance with local law, we may share information of participating Members with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Members full name and contact details, Accommodation address, tax identification number and Listing details.

3.9 Business transfers

If Sourcified undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (i.e. due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.10 Aggregated data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references and individual users, and other anonymez information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. Other important information

4.1 Analyzing your communication

We may review, scan, or analyze your communications on the Sourcified platform for fraud prevention, risk assessment, regulator compliance, investigation, product development, research, and customer support purposes. In some cases we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these our fraud prevention system and risk assessment tools. We will not review, scan, or analyze your communication to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

4.2 Linking third party accounts

You may link your Flatmate account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends”. When you create this link:

some of the information you provide to us from the linking of your accounts may be published on your Flatmate account profile;
your activities on the Sourcified platform may be displayed to your Friends on the Sourcified platform and/or third party site;
a link to your public profile on that third party social networking service may be included in your Flatmate account public profile;
other users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
the information you provide to use from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes;
the publication and display of information that you provide to Sourcified through this linkage is subject to your settings and authorizations on the Sourcified platform and the third party site.

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

4.3 Google Maps/Earth

Parts of the Sourcified platform use Google Maps/Earth services, including the Google Maps API. Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Third party partners and integrations

The Sourcified platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third party partners”). Sourcified doesn’t own or control these Third party partners and when you interact with them, you may be providing information directly to the third party partner, Sourcified, or both. These Third party partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. Your rights

You may exercise any of the rights described in this section. Send an email to available email addresses listed on the Sourcified platform. Please note that we may ask your to verify your identity before taking further action on your request.

6.1 Managing your information

You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of inaccurate or incomplete information

You have the right to ask us to correct inaccurate or incomplete personal information concerning your (and which you cannot update yourself within your Flatmate account).

6.3 Data access and portability

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Sourcified platform to you, you can request that we erase your personal information and closure your Sourcified account. You also have the option to erase your personal information and close and delete your Sourcified account. Please not that if your request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Flatmate account for fraud or safety reasons, we may retain certain information from that Flatmate account to prevent that Member from opening a new Flatmate account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Sourcified may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with other (i.e. reviews, forum postings) may continue to be publicly visible on the Sourcified platform even after your Flatmate account is cancelled. However, attribution of such information to you will be removed. Additionally some copies of your information (i.e. log records) may retain in our database, but are disassociated from personal identifiers.
Because we maintain the Sourcified platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing consent and restriction of processing

Where you have provided your consent to the processing of your personal information by Sourcified you may withdraw your consent at any time by changing your Account settings or by sending a communication to Sourcified specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Addiotionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where you contest the accuracy of your personal information, the processing is unlawful and you oppose the erasure of your personal information, we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims, or you have objected to the processing pursuant to section 5.5 and pending the verification whether the legitimate ground of Sourcified override your own.

6.6 Objection to processing

In some jurisdictions, applicable law may entitle you to require Sourcified not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If object to such processing Sourcified will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Sourcified to cease processing data for these direct marketing purposes. Send an email to available email addresses listed on the Sourcified platform.

7. Operating internationally

To facilitate our international operations Sourcified may transfer, store, and process your information within our family of companies or with service providers based in different parts of the world. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer, store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

7.1 Other means to ensure an adequate level of data protection

Together with data controllers, third party providers, corporate affiliates we have - prior to sharing your information with such entities, established the necessary means to ensure an adequate level of data protection.

8. Security

We are continuously implement and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Sourcified account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Flatmate account, please contact us using available email addresses listed on the Sourcified platform.

9. Changes to this Privacy Policy

Sourcified 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 post the revised Privacy Policy on the Sourcified platform and update the “Last updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least sixty (60) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your account. If you do not cancel your account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Sourcified platform will be subject to the revised Privacy Policy.

10. Contact us

If you have any complaints or questions about this Privacy Policy or Sourcified’s information handling practices you may email us or contact us by phone. Options listed on the Sourcified platform.