Privacy statement

Hometwin ("we") is a digital home record. This statement explains which personal data we process, why, how long we keep it and what rights you have.

Do you have a question about your data? Email us at hello@hometwin.com.

This statement applies to:

• Participants: residents and homeowners who use Hometwin, on their own or through an invitation from an organisation.
• Contact persons of organisations: employees of organisations that offer Hometwin to their customers or members.
• Visitors of hometwin.com: including when you fill in a contact form or request a quote.

For your Hometwin account and your home record, we are responsible for processing your data (controller). You decide what goes into your record and who you share it with.

If an organisation offers Hometwin to you, that organisation gives us, for example, your email address to invite you. The organisation is responsible for that data, and we process it on its behalf under our data processing terms. Data you share with an organisation is used by that organisation under its own responsibility.

Your account

To give you an account and let you log in.

• Data: name, email address, login details (you log in with a link sent by email, without a password), language preference.
• Legal basis: performance of the agreement with you.

Your home record

To store and organise your home's information and make it work for you.

• Data: address and home details, documents and photos you upload, notes, maintenance, appliances, meter readings and energy data, and the choices you make.
• Legal basis: performance of the agreement with you.

Public data about your home

To add information that is known about your home to your record, such as year of construction, floor area, energy label, WOZ value, map images, climate risk and air quality. We retrieve this from public and other sources using your address.

• Data: your address and the data about the home we retrieve with it.
• Legal basis: performance of the agreement with you.

Smart features

To recognise and read documents, recognise appliances in photos, keep out inappropriate content and answer your questions in the chat. For this we use AI models from Google (Vertex AI), within the European Union. Your data is not used to train those models. The results are suggestions: we do not use AI to make decisions that have legal effects on you or otherwise significantly affect you.

• Data: the documents, photos and messages you use for these features.
• Legal basis: performance of the agreement with you.

Sharing with others

To share your record with whoever you choose, such as an organisation, your bank, an adviser or a family member.

• Data: the parts of your record you share.
• Legal basis: your choice to share, as part of the agreement with you. You can stop sharing at any time.

Invitations through an organisation

To invite you to Hometwin on behalf of an organisation.

• Data: your name and email address as provided to us by the organisation.
• Legal basis: the organisation is responsible for this; we process this data on its behalf.

Payments

To handle payments for Hometwin and keep our accounts.

• Data: name, email address, payment details and invoice details.
• Legal basis: performance of the agreement and the statutory retention obligation.

Notifications

To send notifications to your phone, such as a maintenance reminder.

• Data: a technical code of your device.
• Legal basis: your consent, which you give and withdraw in your phone's settings.

Usage statistics

To see how Hometwin is used and improve it. We use Google Analytics for this, in the app and on the website. In the app we only measure which screens you use, never your name, address or home data.

• Data: use of screens and pages, device and browser details.
• Legal basis: your consent. You can withdraw it at any time, in the app through your profile and on the website through the cookie settings.

Contact and quotes

To answer your questions and handle quotes and orders from organisations.

• Data: name, email address, phone number, organisation, invoice details and the content of your message.
• Legal basis: legitimate interest in answering your question, and performance of the agreement in the case of an order.

• As long as your account exists, we keep the data needed to make Hometwin work for you.
• If you delete your account or ask us to delete your data, we delete as much as possible straight away. What cannot be deleted straight away, such as copies in backups, is deleted within 90 days at the latest.
• Data we are required by law to keep, we keep for as long as the law requires. Data needed for an energy label is kept for 15 years. This is data about the building, which we separate from you as a person wherever possible. Invoices and accounting records are kept for 7 years.

• Organisations and people you share your record with.
• Service providers that process data on our behalf, such as Google for hosting, AI, email, notifications and maps, and Mollie for payments. We have made agreements with them about security and confidentiality. A current overview is in our data processing terms.
• Authorities, when the law requires us to.

We do not sell your data.

Your data is stored in Google Cloud data centres in the Netherlands and Belgium, and the smart features run within the European Union. Some Google services, such as email, notifications and maps, may also process data outside the European Economic Area. Google uses the standard contractual clauses approved by the European Commission for this and participates in the EU-US Data Privacy Framework.

We protect your data with appropriate technical and organisational measures, such as encrypted connections, encrypted storage, login without passwords, role-based access and recording who does what. Employees only have access to data when their work requires it and are bound by confidentiality.

You have the right to:

• access your data;
• have incorrect data corrected;
• have your data deleted. You can also delete your account yourself in the app;
• receive your data in a common format or have it transferred to someone else;
• object to processing based on legitimate interest;
• have processing restricted;
• withdraw your consent at any time.

Send your request to hello@hometwin.com. We may ask you to confirm your identity. We respond within one month; for a complex request this may be extended by two months, in which case we will let you know.

If you are not satisfied with how we handle your data, let us know at hello@hometwin.com. If we cannot resolve it together, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

We may change this privacy statement. The current version is always at hometwin.com/privacyverklaring. We will let you know about important changes.