Privacy Policy

1. Introduction and Legal Basis

1.1 Data Controller

• –Contact: privacy@domuhq.cz
• –GDPR Rights Page: domuhq.cz/gdpr
• –Postal Address: DomuHq s.r.o., Poličanská 1487, 190 16 Praha - Újezd nad Lesy, Czech Republic
• –Data Protection Contact: privacy@domuhq.cz

1.2 Applicable Laws

• –Regulation (EU) 2016/679 (GDPR)
• –Act No. 110/2019 Coll., on Personal Data Processing (Czech GDPR implementation)
• –Act No. 127/2005 Coll., on Electronic Communications (ePrivacy)
• –EU AI Act (Regulation (EU) 2024/1689)
• –Digital Services Act (Regulation (EU) 2022/2065)
• –Other applicable Czech and EU data protection laws
• –For users in Canada and the United States, see also Section 15.

1.3 Scope of This Policy

• –All users of the DomuHQ platform (website, web app and iOS app)
• –Visitors to our websites, including our app download pages and our North America site (domuhq.com), even without creating an account
• –People who open a shared DomuHQ profile or listing link without an account
• –Anyone who communicates with us via email, forms, or customer support

1.4 Children’s Privacy

• –DomuHQ is only for people aged 18 and over, in every country where it is available.
• –We do not knowingly collect personal data from anyone under 18.
• –If we find out that someone under 18 has an account, we delete it promptly.

2. Personal Data We Collect

2.1 Information You Provide Directly

• Account Registration
  • –Email address or phone number (one required for signup; in Canada and the United States, we verify new accounts by email)
  • –Password (encrypted/hashed; we cannot see it)
  • –Or social login via Google, Apple, or Facebook where offered (name and email received from provider)
• Roommate Profile (onboarding)
  • –First name, last name, date of birth, gender, pronouns (required during profile setup)
  • –Occupation (free text)
  • –Current city, preferred city, preferred areas/districts
  • –Location visibility: you can hide the city you currently live in. Your preferred city and areas stay visible, because matching needs them.
  • –Preferred roommate gender, move-in timeframe, flexibility toggle
  • –About me (free text, up to 500 characters)
  • –Budget range (slider, in your local currency per month)
  • –Photos (up to 5 images, jpg/png, max 10 MB each)
• Lifestyle and Compatibility (onboarding)
  • –Lifestyle sliders (cleanliness level, noise tolerance, sleep schedule, guest frequency)
  • –Smoking habits, drinking habits, pet preferences (dropdowns)
  • –Deal breakers (tag selection from predefined options)
  • –Interests and hobbies (selected from categories, plus custom entries)
  • –Psychometric personality test responses (optional, used for compatibility scoring)
• Privacy and Visibility Settings (onboarding)
  • –Profile visibility (Public or Verified Users Only)
  • –Hide last name toggle
  • –Hide the city I live in now toggle (your preferred city and areas stay visible)
• Renter Profile (if activated)
  • –First name, last name, phone number, date of birth, gender
  • –Occupation, work/study location
  • –Profile photo
• Host Profile (if activated)
  • –First name, last name, email, phone number
  • –About me (free text, up to 500 characters)
  • –Host role type (spare room host, private landlord, agent at a real estate agency, or independent agent)
  • –Business ID (IČO) and Tax ID (DIČ) for professional hosts
  • –Profile photo
• Property Listings (For Hosts)
  • –Property type, room configuration, condition
  • –Property description (free text or AI-generated, up to 500 characters)
  • –Size (usable area, total area), floor information, elevator
  • –Building details (type, year of construction, renovations, energy class, energy certificate upload)
  • –Address (auto-filled via a map provider, see Section 5.2), city, area, postal code, flat/unit number
  • –Location privacy setting (exact address, area only, or approximate on map)
  • –Nearby civic amenities (auto-populated from property location)
  • –Rental price, utilities, security deposit, payment terms
  • –House rules, policies, availability dates
  • –Photos per room (exterior, living room, kitchen, bedroom, bathroom, balcony)
  • –Proof of ownership documents (land registry extract, property deed, or ownership certificate)
  • –ČÚZK verification consent (explicit consent checkbox for property verification against the Czech Cadastral Registry)
• Rental Applications and Lease Signing
  • –Applications you send or receive (who applied, squad members applying together, application status, viewing bookings)
  • –Electronic lease signing: the signer’s name, email address and phone number, and the lease document, sent to our e-signature provider (DigiSign) to create and sign the contract; signing status
• Messages, Reports and Feedback
  • –Messages sent via the Platform
  • –Reviews and ratings
  • –Reports you submit about another user or listing (reason and details)
  • –When you end a match: the reason you choose and any note you add (for example, that you felt unsafe). This is visible to our moderation team, not to the other person.
  • –Customer support inquiries
  • –Feedback and survey responses
• Real Estate Agency Applications
  • –Company name, Business ID (IČO), Tax ID (DIČ, optional), registered address
  • –Contact person: first and last name, email, phone number
  • –Trade licence and professional liability insurance details
  • –Agency members and agents you invite (name, email, role)
• Android Interest List
  • –If you leave your email on an app download page because you use Android: your email address, language, and the page you came from. Used only to tell you when the Android app is available.
• Payment Information
  • –Card details on the web (processed by Stripe; we do not store full card numbers)
  • –In-app purchases on iOS (processed by Apple; we receive only the receipt and subscription status)
  • –Payment history and transaction records
  • –Subscription status and plan type
• Verification Documents
  • –Government-issued ID (processed by Didit)
  • –Selfie/biometric photo (processed by Didit for liveness detection)
  • –Property ownership docs (Hosts, verified via ČÚZK)
  • –Business registration (IČO/DIČ for professional Hosts)
  • –Additional documents if requested by a landlord (e.g., income verification, references)
• Squad Information
  • –Squad name/description
  • –Member roster
  • –Shared property searches/favorites and votes
  • –Group communications

2.2 Information We Collect Automatically

• Device and Usage Data
  • –IP address
  • –Device type/model/OS; browser type/version
  • –Screen resolution/display settings; app version; language preferences
• Platform Activity
  • –Pages/features used; searches; profiles/properties viewed
  • –Time spent; clicks/taps/navigation
  • –Errors and crashes (debugging)
• Location Data
  • –Approximate location via IP (city/region)
  • –Precise GPS (only if enabled in app and permission granted)
  • –Used for nearby results, localization, fraud detection
• Cookies and Similar Technologies (website)
  • –Essential cookies (login, security, language, your cookie choices): always on
  • –Analytics (Google Analytics 4, PostHog): only if you allow analytics cookies
  • –Advertising measurement (Meta Pixel, Google Ads, LinkedIn Insight Tag, Sklik retargeting): only if you allow marketing cookies
  • –Campaign attribution: if you arrive from an ad or a tagged link, we store the campaign source (UTM parameters) once you allow analytics cookies
  • –See Cookie Policy: domuhq.cz/cookies
• iOS App: Advertising Measurement
  • –The iOS app asks for permission through Apple’s App Tracking Transparency (ATT) prompt.
  • –Only if you tap Allow: your device’s advertising identifier (IDFA) and a limited set of in-app events (for example, completing sign-up) are sent to Meta to measure our ad campaigns.
  • –If you don’t allow tracking, none of this is sent. We never send your name, email, phone number or user ID to Meta.
  • –You can change this anytime in iOS Settings > Privacy & Security > Tracking.
• Account and Onboarding Events
  • –When you create an account or set up a profile, on the web or in the app, our servers record it in PostHog: the sign-up method (Apple, Google or email), whether it happened in the app or on the web (read from your device’s user agent), and whether a profile was created or refused (the role, the field and the reason).
  • –These events are linked to your user ID and used only to find and fix problems in sign-up and onboarding. Nothing is stored on your device for this.
• iOS App: Product Analytics (only with your consent)
  • –If you switch on app analytics, the PostHog SDK records the screens you open, taps and the step where you leave a flow, and stores an identifier and a queue of events on your device.
  • –No session recording, no advertising identifier and no tracking across other apps.
  • –You can switch it off anytime in Profile > Data & Security.

2.3 Information From Third Parties

• Identity Verification Provider (Didit)
  • –Verification result (approved/rejected). Processed by Didit Identity Spain SL (AWS Ireland, EEA)
  • –Document authenticity checks
  • –Biometric verification data
  • –Watchlist screening results (AML/KYC)
• Payment Processors (Stripe and Apple)
  • –Stripe (web): payment success/failure status, transaction IDs, fraud risk scores
  • –Apple (iOS in-app purchases): subscription receipt validation, transaction status
• E-Signature Provider (DigiSign)
  • –Signing status of a lease (sent, signed, declined) and the signed document
• Social Login Providers
  • –Google OAuth: name, email address, profile photo (when you sign in with Google)
  • –Google Calendar: calendar event data (date, time, title only, used for scheduling viewings, requires separate consent)
  • –Facebook Login: name, email address (when you sign in with Facebook, where this option is offered)
  • –Apple Sign-In: name, email address (when you sign in with Apple)
• Google User Data: Limited Use Disclosure
  • –DomuHQ's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
  • –Google user data (name, email, profile photo from Google Sign-In, and calendar event data from Google Calendar) is used ONLY to: (1) authenticate your account and display your identity within the app, and (2) schedule property viewings in your calendar.
  • –Google user data is NOT used for: AI/ML model training, advertising, marketing, analytics, profiling, or any purpose other than providing or improving user-facing features of the DomuHQ platform.
  • –Google user data is NOT sold, transferred to third parties, or used to serve ads.
  • –Google user data is NOT shared with any third-party AI/ML providers.
• Advertising Platforms
  • –Aggregated campaign reports (for example, how many people installed the app after an ad). These reports do not identify you.
• Third-Party Data Enrichment (optional, with consent)
  • –Public info (e.g., LinkedIn) to verify occupation/credentials

2.4 Sensitive Personal Data

• –Biometric data (selfies for verification). Used solely for identity verification; processed by Didit Identity Spain SL (AWS Ireland, EEA); retained per AML/KYC requirements.
• –Health data (optional): disability/accessibility needs if voluntarily provided; used only for matching.
• –We do not request racial/ethnic origin, religious beliefs, or sexual orientation; if voluntarily shared in profiles/messages it is processed as User Content.

3. How We Use Your Personal Data

3.1 Purposes of Processing

• Provide and Operate the Service (Contract, GDPR 6(1)(b))
  • –Create/manage account
  • –Enable matching and compatibility scoring
  • –Display listings and facilitate connections
  • –Process messages, requests, applications
  • –Prepare and send leases for electronic signature
  • –Translate chat messages, profile bios, squad descriptions and listing descriptions when you use translation
  • –Enable Squad features
  • –Process payments/subscriptions
  • –Provide customer support
• Verify Identity, Keep People Safe and Prevent Fraud (Legitimate Interests, GDPR 6(1)(f))
  • –Identity verification
  • –Property ownership confirmation
  • –Reviewing reports and ended-match feedback, including safety concerns
  • –Fraud/scam/abuse detection
  • –Policy violation monitoring
  • –Security and audit logging
  • –AML/KYC compliance
• Improve and Personalize (Legitimate Interests, GDPR 6(1)(f))
  • –Analyze usage patterns (website and app analytics only with your consent, see Sections 2.2 and 11)
  • –Record account and onboarding events on our servers to find and fix sign-up problems
  • –A/B testing and product research
  • –Develop/train AI/ML models (excludes Google user data; see Google User Data Limited Use Disclosure in Section 2.3)
  • –Optimize performance and fix bugs
  • –Personalize recommendations/search
• Advertising Measurement (Consent, GDPR 6(1)(a))
  • –Measure which ads and campaigns bring people to DomuHQ
  • –Show our ads to people who visited our website (retargeting)
  • –Website: only if you allow marketing cookies. iOS app: only if you tap Allow in the App Tracking Transparency prompt.
• Communications (Contract / Legitimate Interests / Consent)
  • –Transactional emails (verification, reset, receipts, application and listing updates)
  • –Notifications (matches, messages, activity)
  • –Service updates/policy changes
  • –Surveys/feedback (with consent)
  • –Marketing (with consent; opt-out available)
  • –Android launch email (only if you joined the Android interest list)
• Legal Obligations (Legal Obligation, GDPR 6(1)(c))
  • –Respond to legal requests
  • –Tax/accounting compliance
  • –Report suspected illegal activity where required
  • –Retain records as required by law
• Enforce Terms and Protect Rights (Legitimate Interests, GDPR 6(1)(f))
  • –Investigate/enforce ToS violations
  • –Defend legal claims/disputes
  • –Protect IP
  • –Prevent misuse

3.2 AI and Automated Decision-Making

• –Matching and compatibility scoring
• –Content moderation
• –Fraud/spam detection
• –Listing optimization recommendations
• –DomuBot AI customer support

3.3 Marketing and Promotional Communications

• –You can opt-out anytime via Unsubscribe, Profile > Preferences, or privacy@domuhq.cz.
• –Transactional emails cannot be opted out.

4. Legal Basis for Processing

4.1 Contract Performance (GDPR 6(1)(b))

• –Providing platform features
• –Processing payments/subscriptions
• –Facilitating communication, matching, applications and lease signing

4.2 Legitimate Interests (GDPR 6(1)(f))

• –Fraud prevention, safety and security
• –Platform improvement
• –Finding and fixing sign-up and onboarding problems (account and onboarding events)
• –Customer support
• –Enforcement and legal defense
• –Internal administration and business intelligence

4.3 Consent (GDPR 6(1)(a))

• –Marketing emails
• –Optional data collection (e.g., health data)
• –Non-essential cookies (analytics and marketing)
• –Advertising measurement in the iOS app (App Tracking Transparency)
• –Product analytics in the iOS app
• –Non-essential location processing
• –Sharing for non-essential purposes

4.4 Legal Obligation (GDPR 6(1)(c))

• –Tax/accounting retention
• –AML/KYC compliance
• –Law enforcement/court orders
• –Breach notifications (GDPR Art. 33)

4.5 Vital Interests (GDPR 6(1)(d))

• –Emergency support in urgent safety situations
• –Preventing imminent harm or danger

4.6 Public Interest (GDPR 6(1)(e))

5. How We Share Your Personal Data

5.1 Sharing With Other Users

• Public Profile Information (visible to others)
  • –Name (last name hidden if you choose), age, gender (if provided)
  • –Profile photo, bio, interests
  • –Preferred city and areas, budget range, move-in timeframe
  • –Compatibility score (signed-in users only)
  • –Verification status (badge)
  • –Property listings (Hosts)
  • –Reviews and ratings
• Shared Links
  • –You or other users can share a link to a profile or listing. People who open it without an account can see the public profile or listing, subject to your visibility setting, but not your compatibility score, messages or contact details.
  • –Messaging and social apps may show a link preview with your first name and last initial (or first name only if you hide your last name), photo, age, city, budget and move-in date.
• Not Shared by default
  • –Email address and phone number (unless you choose to share)
  • –Full date of birth (only age is shown)
  • –Payment info
  • –Verification documents
  • –Reports and ended-match feedback you submit
• Messages
  • –Messages are visible to recipients.
  • –We don’t read private messages except: automated moderation; abuse reports (human review); legal requirements.

5.2 Sharing With Third-Party Service Providers

• Identity Verification Provider (Didit)
  • –Data shared: ID docs, biometric photos, name, DOB
  • –Purpose: verification, authentication, AML/KYC screening
  • –Provider: Didit Identity Spain SL (AWS Ireland, EEA)
  • –Provider retention: typically 5 years
• Payment Processors
  • –Stripe (web payments): card details and payment amount (card-only, no billing address collected). We do not store full card numbers (PCI DSS compliance handled by Stripe).
  • –Apple (iOS in-app subscriptions): Apple handles all payment data under its own privacy policy. DomuHQ receives only transaction receipts and subscription status.
• Electronic Signatures (DigiSign)
  • –Provider: DigiSign s.r.o. (Czech Republic)
  • –Data shared: signer’s name, email address and phone number, and the lease document
  • –Purpose: creating and signing rental contracts electronically (the signer receives an email and a one-time SMS code)
• Cloud Hosting and Infrastructure (AWS EU)
  • –Provider: Amazon Web Services (AWS), EU-Frankfurt and EU-Ireland regions
  • –Services: authentication, database, file storage, compute, caching and content delivery
  • –Our primary infrastructure stores and processes data within the EEA.
  • –Encryption in transit and at rest
• Analytics and Monitoring
  • –Google Analytics 4 (Google Ireland Ltd.): website usage statistics; only with your consent to analytics cookies
  • –PostHog (EU cloud, Frankfurt): product analytics. Website and app usage only with your consent; account and onboarding events from our servers to fix sign-up problems (see Section 2.2)
  • –Application monitoring and error logs, used to keep the service running
• Advertising Measurement (only with your consent)
  • –Meta Platforms Ireland Ltd.: Meta Pixel on our website (marketing cookies) and the Meta SDK in our iOS app (only after you tap Allow in the App Tracking Transparency prompt). Data: cookie or advertising identifier, pages visited or a limited set of app events, IP address and device information. No name, email, phone number or user ID; advanced matching is off.
  • –Google Ireland Ltd. (Google Ads): conversion tracking for our Google ad campaigns
  • –LinkedIn Ireland Unlimited Company (Insight Tag): conversion tracking and audiences for LinkedIn ads
  • –Seznam.cz, a.s. (Sklik): retargeting for our ads on Seznam
• Email and SMS Providers
  • –Mailgun (Sinch): transactional email delivery via notify.domuhq.cz (EU API endpoint)
  • –MessageBird/Bird: SMS OTP verification codes sent to your phone number
• Translation and Maps
  • –DeepL SE: automatic translation of chat messages, profile bios, squad descriptions and listing descriptions (the text is sent to DeepL for translation; no account identifiers are included)
  • –Mapy.cz (Seznam.cz): address search and maps on the web
  • –Mapbox, Inc.: maps and address search in the iOS app (search text and map location only)
  • –OpenStreetMap (Overpass API): nearby amenities for a listing (listing coordinates only)
• Property Verification
  • –ČÚZK (Czech Office for Surveying, Mapping and Cadastre): property ownership verification via REST API (property data only, no personal user data sent)
• Push Notifications
  • –Apple Push Notification Service (APNS): device tokens for iOS push notifications
• AI and Machine Learning Providers
  • –AWS Bedrock (EU-Frankfurt): powers roommate compatibility matching, listing optimization, and DomuBot AI assistant. Data shared: pseudonymized assessment scores, usage patterns. No raw personal data sent.
  • –AWS Rekognition (EU-Frankfurt): image content moderation for profile photos and listing images. Data shared: uploaded images are scanned and results returned; images are not retained by Rekognition.
  • –Anthropic (Claude API): powers DomuBot AI assistant for product support (currently internal; planned for user-facing support). When user-facing: conversation text is processed; no personal identifiers are included in prompts.

5.3 Sharing With Legal Authorities

• –Required by law (subpoenas/court orders/legal process)
• –Protecting rights and safety (fraud/abuse/illegal activity; preventing harm)
• –National security requests where legally mandated
• –Enforcement and legal defense

5.4 Business Transfers

• –If merger/acquisition/sale/bankruptcy: data may transfer to successor
• –Successor bound by this policy or will notify you of changes
• –We will notify you via email and Platform notice

5.5 Sharing With Your Consent

• –Integrations you authorize
• –Marketing partnerships (opt-in only)
• –Research/academic studies (anonymized only)

5.6 We Do NOT Sell Your Personal Data

6. International Data Transfers

6.1 Data Storage Location

• –Our primary infrastructure stores and processes personal data within the European Economic Area (EEA).
• –Primary infrastructure: AWS EU-Frankfurt (Germany) and AWS EU-Ireland.
• –Identity verification: Didit, hosted on AWS Ireland (EEA).
• –Email delivery: Mailgun EU endpoint.
• –Product analytics: PostHog EU cloud (Frankfurt).
• –File storage: Hetzner (Germany) for internal operations.

6.2 Transfers Outside the EEA

• –Stripe (payments), Apple (app distribution, in-app purchases, push notifications), Anthropic (AI services), Mapbox (maps in the iOS app)
• –Google (Analytics, Ads), Meta (Pixel, iOS SDK) and LinkedIn (Insight Tag): only if you consent to analytics or marketing cookies, or allow tracking in the iOS app
• –Safeguards: the EU-US Data Privacy Framework where the provider is certified, otherwise Standard Contractual Clauses (SCCs) approved by the European Commission (GDPR Chapter V).

6.3 Your Rights Regarding Transfers

• –Request information about transfers and safeguards
• –Object if you believe transfers violate GDPR
• –Request a copy of safeguards (e.g., SCCs) for specific providers

7. Your Data Protection Rights

7.1 Right of Access (GDPR Art. 15)

• –Profile > Data & Security > Download My Data
• –Request via privacy@domuhq.cz or domuhq.cz/gdpr
• –Format provided: PDF or JSON
• –Response: within 30 days (may extend by 60 days for complex requests)

7.2 Right to Rectification (GDPR Art. 16)

• –Update most info in Profile > Manage Profile
• –For non-editable data (e.g., verification status) contact privacy@domuhq.cz with evidence
• –Corrections processed within 30 days

7.3 Right to Erasure (GDPR Art. 17)

• –Delete account via Profile > Data & Security > Delete Account, or request via privacy@domuhq.cz / domuhq.cz/gdpr
• –Deletion within 30 days (subject to legal exceptions, see Section 9.3)
• –Exceptions: legal retention (financial 10 years; verification 5 years), legal claims, shared messages, reviews (may be anonymized), backups up to 90 days

7.4 Right to Restriction (GDPR Art. 18)

• –Request restriction via privacy@domuhq.cz with reason
• –We store data but suspend processing except with consent/legal claims/protect third parties
• –Response within 30 days

7.5 Right to Data Portability (GDPR Art. 20)

• –Download via Profile > Data & Security > Download My Data, or request via privacy@domuhq.cz
• –Applies to data you provided and processing based on consent/contract
• –Includes: account/profile, assessment responses, sent messages (your copies), listings, transaction history
• –Response within 30 days

7.6 Right to Object (GDPR Art. 21)

• –Object via privacy@domuhq.cz with specific processing you object to
• –We stop unless compelling grounds override your interests
• –Absolute right to object to direct marketing (we stop immediately)

7.7 Right to Withdraw Consent (GDPR Art. 7(3))

• –Marketing emails: Profile > Preferences > Notifications (toggle off Marketing Communications), or the unsubscribe link in any marketing email
• –Cookies on our website: the “Cookie Settings” link in the website footer
• –Tracking in the iOS app: iOS Settings > Privacy & Security > Tracking
• –Analytics in the iOS app: Profile > Data & Security
• –Any other consent: email privacy@domuhq.cz
• –Withdrawal does not affect prior lawful processing

7.8 Right to Lodge a Complaint

• –Czech authority: ÚOOÚ (uoou.cz)
• –Address: Pplk. Sochora 27, 170 00 Prague 7
• –Phone: +420 234 665 111
• –Email: posta@uoou.cz
• –EU residents may also complain in their country
• –Users in Canada and the United States: see Section 15

7.9 Automated Decision-Making and Profiling (GDPR Art. 22)

• –Right not to be subject to solely automated decisions with legal/similarly significant effects
• –Right to contest AI decisions, request human review, and understand AI logic

8. Artificial Intelligence and Automated Decision-Making

8.1 AI Systems We Use

• Matching and Recommendations
  • –Personality compatibility scoring (Five-Factor Model)
  • –Roommate and property recommendations
  • –Squad compatibility analysis
• Content Moderation
  • –Detection of prohibited content (hate speech, nudity, scams) using AWS Bedrock and AWS Rekognition
  • –Spam and fraud detection
• Platform Optimization
  • –Listing quality recommendations
  • –UX personalization
• Customer Support
  • –DomuBot AI assistant (powered by Anthropic Claude)
  • –Currently used internally for product support; planned for user-facing customer assistance
  • –When user-facing: processes conversation text to provide housing and platform support

8.2 Legal Basis for AI Processing

• –Legitimate interests: safety, fraud prevention, UX improvement
• –Contract performance: providing matching/platform services
• –Consent: optional AI features (advanced analytics, listing optimization)

8.3 Your Rights Under GDPR Article 22

• –Human oversight for high-impact decisions (bans, verification failures)
• –Right to contest AI decisions
• –Right to explanation
• –How to request: email privacy@domuhq.cz with subject “AI Decision Review Request” and details; response within 30 days

8.4 AI Data Retention and Security

• –Training data is anonymized/aggregated; individual training points pseudonymized
• –AI decision logs retained 12 months (unless needed for legal/compliance); encrypted and access-controlled

8.5 EU AI Act Compliance

• –Designed to comply with the EU AI Act (Regulation (EU) 2024/1689) as its obligations apply
• –High-risk: personality matching (audits, transparency, human oversight, governance, documentation, conformity assessment where required)
• –Limited-risk: DomuBot/content moderation (transparency, testing, human escalation)
• –User rights: contest decisions, request review, opt-out of non-essential AI features, complain to ÚOOÚ

8.6 AI Fairness and Non-Discrimination

• –Diverse training data; bias testing; fairness metrics; human review of high-impact decisions
• –Report discrimination concerns to support@domuhq.cz or privacy@domuhq.cz

8.7 Third-Party AI Providers

• –Identity verification AI: Didit Identity Spain SL (biometric liveness detection, document authenticity checks, hosted on AWS Ireland)
• –Content moderation AI: DomuHq internal system using AWS Bedrock (text moderation) and AWS Rekognition (image moderation), both EU-Frankfurt
• –Roommate matching AI: DomuHq internal system using AWS Bedrock (compatibility scoring from psychometric assessments), EU-Frankfurt
• –DomuBot AI assistant: powered by Anthropic Claude API (currently internal; planned for user-facing product support)
• –Translation: DeepL SE (machine translation, not used for decisions about you)

9. Data Retention

9.1 Retention Principles

• –We keep personal data only as long as needed for purposes or legal requirements.
• –Retention depends on purpose, legal obligations, legitimate interests, and consent.

9.2 Retention Periods by Data Type

• Account Data
  • –Active: while account is active
  • –Deleted: deleted within 30 days (subject to exceptions, see Section 9.3)
  • –Inactive: if no login for 2 years, may delete after notice
• Listings
  • –A listing stays live for 60 days from publishing, then unpublishes unless the host renews it. We email the host 7 days before it expires.
  • –Unpublished listings are kept in the host’s account until the host deletes them or the account is deleted.
• Applications and Signed Leases
  • –Kept while your account exists, so you can see your application history and signed documents
  • –The e-signature provider keeps its own record of the signing under its retention policy
• Verification Data
  • –5 years from verification date (AML/KYC; Act No. 253/2008 Coll.)
• Transaction and Payment Data
  • –10 years from transaction date (Accounting Act No. 563/1991; Tax Code No. 280/2009)
• Messages and Communications
  • –Until deletion or as needed for disputes (up to 3 years), enforcement, or legal obligations
  • –You can delete messages from your inbox view; recipient may retain
• Reports, Ended-Match Feedback and Moderation Records
  • –Up to 3 years after the case is closed, for safety, enforcement and legal defense
• Reviews and Ratings
  • –Remain visible unless deleted
  • –After account deletion: may be anonymized (name removed) to preserve integrity
• Support Tickets
  • –3 years from ticket closure
• Real Estate Agency Applications
  • –For the duration of the agency relationship, then as long as needed for contract and accounting records
  • –Applications that do not go ahead: deleted within 12 months
• Android Interest List
  • –Until we send the Android launch email or you ask us to remove you, and no longer than 2 years
• Security and Audit Logs
  • –1 year
• Analytics and Usage Data
  • –24 months (individual usage); anonymized analytics retained indefinitely
• AI Training Data
  • –Anonymized/pseudonymized training data retained indefinitely (de-identified/aggregated)
• Backups
  • –Up to 90 days (disaster recovery); deleted data may persist until rotation

9.3 Account Deletion and Data Erasure

• Immediate (within 24 hours)
  • –Account access terminated and all sessions invalidated
  • –Profile hidden from other users
  • –Personally identifiable information (name, email, phone, photos, profile bio, assessment responses, social login IDs) anonymized in production systems
  • –Active listings and squad memberships removed
• Within 30 days
  • –Account row permanently purged from production database
  • –Identity provider account permanently deleted
  • –Profile photos and documents permanently deleted from object storage
  • –Data anonymized but retained where legal retention obligations apply (see Exceptions below)
  • –Until the purge is complete, the same email address cannot be used to create a new account
• Exceptions (data retained beyond 30 days)
  • –Verification data: 5 years from verification date (AML/KYC; Act No. 253/2008 Coll.)
  • –Financial and transaction records: 10 years (Czech accounting law)
  • –Ongoing disputes, litigation, or investigations: until resolved + applicable limitation periods
  • –Reports and moderation records: up to 3 years after the case is closed
  • –Messages you sent: remain in recipients' inboxes (their copies)
  • –Reviews you wrote: may be anonymized (your name removed) and kept to preserve integrity for other users
  • –Encrypted backups: deleted data may persist up to 90 days until backup rotation

10. Data Security

10.1 Security Measures

• Technical Safeguards
  • –Encryption in transit and at rest
  • –Passwords stored only as salted hashes
  • –Role-based access controls; multi-factor authentication for admins
  • –Firewalls, DDoS protection, rate limiting
  • –Code reviews, security testing and vulnerability scanning
• Organizational Safeguards
  • –Security training for people with access to personal data
  • –Confidentiality agreements (NDAs)
  • –Data minimization
  • –Incident response plan
• Third-Party Security
  • –DPAs required
  • –Audits/certifications where appropriate
  • –Breach notification to DomuHq without undue delay

10.2 Data Breach Notification

• –Notify ÚOOÚ within 72 hours where required (GDPR Art. 33).
• –Notify affected users without undue delay for high-risk breaches (GDPR Art. 34).
• –Contain/remediate, investigate, prevent recurrence; offer assistance if appropriate.

10.3 Your Responsibility

• –Use strong, unique password; don’t share it.
• –Secure your device and keep software updated.
• –Report suspicious activity to privacy@domuhq.cz.
• –Be cautious of phishing/social engineering.

11. Cookies and Tracking Technologies

11.1 What Are Cookies?

11.2 Types of Cookies We Use

• –Necessary cookies: login, security, session, language and your cookie choices. Always on.
• –Analytics cookies: Google Analytics 4 and PostHog. Only with your consent.
• –Marketing cookies: Meta Pixel, Google Ads, LinkedIn Insight Tag and Sklik (Seznam) retargeting. Only with your consent.

11.3 Managing Cookies

• –Cookie banner options: Accept; Reject All; Cookie Settings (choose analytics and marketing separately).
• –Change your choice anytime: the “Cookie Settings” link in the website footer.
• –Browser settings can also control cookies (may affect functionality).

11.4 Third-Party Cookies

12. Children’s Privacy

12.1 Minimum Age Requirement

• –DomuHQ is only for people aged 18 and over.
• –We do not knowingly collect personal data from anyone under 18.

12.2 Discovery and Deletion

• –If we find an account of someone under 18: we delete it and its data within 7 days and notify the parent/guardian if possible.

12.3 Parental Rights

• –Parents/guardians of anyone under 18 can ask us to access or delete that person’s data, and can complain to ÚOOÚ.
• –To exercise: contact privacy@domuhq.cz with proof of guardianship.

13. Changes to This Privacy Policy

13.1 Amendments

• –We may update this policy for new features, practice changes, legal/regulatory updates, or feedback.
• –Material changes communicated via email, prominent platform notice, and/or in-app notification.
• –Notice period: at least 30 days before changes that reduce your rights take effect (longer if required by law).
• –Continued use after effective date = acceptance; you can delete your account if you disagree.

13.2 Version History

• –Version 1.2: Effective October 15, 2026 (Advertising measurement on web and iOS, app analytics, new providers, lease signing, shared links, retention periods, 18+ minimum age, users in Canada and the United States).
• –Version 1.1: Effective April 1, 2026 (Updated vendor disclosures, international transfers, AI providers).
• –Previous versions available upon request: privacy@domuhq.cz.

For questions, concerns, or requests regarding this Privacy Policy, please contact:

15. Users in Canada and the United States

15.1 Who Is Responsible

• –DomuHq s.r.o., Poličanská 1487, 190 16 Praha - Újezd nad Lesy, Czech Republic, is responsible for your personal information.
• –Our privacy officer is Emmanuel Omoruan, reachable at privacy@domuhq.cz.

15.2 Where Your Information Is Stored

• –Your information is stored and processed mainly in the European Economic Area (Germany and Ireland).
• –Some providers process limited data in the United States (see Section 6.2), including Apple, Stripe, Mapbox, and, only with your consent, Meta and Google.
• –Information held outside your country may be accessible to courts, law enforcement and national security authorities there under local law.

15.3 Consent

• –We collect, use and share your personal information with your consent, as described in this policy, or as permitted or required by law.
• –You can withdraw consent at any time by contacting privacy@domuhq.cz. Withdrawing consent may mean some features no longer work.

15.4 Your Rights

• –You can access, correct or delete your information using the in-app tools in Section 7 (Profile > Data & Security), or by emailing privacy@domuhq.cz.
• –We respond within 30 days.

15.5 We Do Not Sell Your Personal Information

• –We do not sell personal information or share it for money.
• –Advertising measurement on our website and app runs only after you agree to it, and you can turn it off at any time (Section 7.7).

15.6 Marketing Messages

• –We send marketing emails only with your express consent, and every one includes a way to unsubscribe.

15.7 Complaints

• –Please contact privacy@domuhq.cz first.
• –Canada: you can complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca).
• –United States: residents of some states may also contact their state attorney general.

15.8 Age and Availability

• –DomuHQ is only for people aged 18 and over.
• –DomuHQ is available in Canada outside Quebec and in the United States.