Privacy Policy
Last updated: September 11, 2026
This policy explains what personal data Flatswaps collects, why we collect it, who we share it with and what control you have over it. It is written to meet Regulation (EU) 2016/679 (the General Data Protection Regulation, “GDPR”) and the Irish Data Protection Act 2018, and it applies to everyone who uses Flatswaps, wherever you live.
1. Who is responsible
The controller of your personal data within the meaning of Art. 4(7) GDPR is:
Flatswaps Limited
77 Sir John Rogerson's Quay
Dublin 2, D02 VK60, Ireland
Companies Registration Office no. 765432 · VAT IE1234567A
Email: privacy@flatswaps.com
Full company details are in our Imprint. Because Flatswaps Limited is established in Ireland, the GDPR governs our processing of your data regardless of where you are located.
2. What we process, why, and on what legal basis
Art. 13 GDPR requires us to tell you the purpose and the legal basis for every kind of processing. The table below covers all of it.
| Purpose | Data | Legal basis | Retention |
|---|---|---|---|
| Creating and running your account | Name, email address, password hash, profile photo, languages, city and country, about text, member since date | Art. 6(1)(b) GDPR — performance of the contract between you and us | For the life of the account, then deleted or anonymised within 30 days of closure |
| Publishing your listing and matching you with swap partners | Property address and approximate location, property type, size, rooms, rent, amenities, photos, availability dates, search criteria and saved searches | Art. 6(1)(b) GDPR — performance of the contract | Until you delete the listing, then 30 days in backups |
| Messaging between members, swap proposals and cycles | Message content, attachments, timestamps, read state, conversation membership, block list | Art. 6(1)(b) GDPR — performance of the contract | Up to 24 months after the conversation ends, or until account closure, whichever is earlier |
| Rental application pack (Bewerbermappe in Germany) | Proof of income (payslips or tax returns), Schufa / credit report, rent-arrears certificate, copy of ID card or passport, tenant self-declaration, cover letter | Art. 6(1)(a) GDPR — your explicit consent, which you may withdraw at any time by deleting the documents | Until you delete the document or close your account; sharing stops immediately when you disable the share link |
| Identity and phone verification, fraud and abuse prevention | Phone number, verification status, IP address, device and browser information, abuse event records | Art. 6(1)(f) GDPR — our legitimate interest in keeping the platform safe and preventing fraud | Verification records for the life of the account; abuse records up to 24 months |
| Swap contracts and electronic signatures | Contract versions, participant state, signature records, signing timestamps and IP address, generated PDF documents | Art. 6(1)(b) GDPR — performance of the contract; Art. 6(1)(c) GDPR for statutory record-keeping | Up to 10 years, where required by Irish and EU commercial and tax record-keeping law |
| Payments and premium subscriptions | Billing name, billing address, payment method token, transaction amount, currency, entitlement status, invoice records. We never receive or store your full card number. | Art. 6(1)(b) GDPR — performance of the contract; Art. 6(1)(c) GDPR for invoicing and tax obligations | Transaction and invoice records for 10 years under Irish tax law |
| Support and contact enquiries | Your name, email address, the topic you select, the content of your message, the language of the page, a salted hash of your IP address and your browser user agent | Art. 6(1)(b) GDPR where your enquiry concerns an existing or prospective contract with us; Art. 6(1)(f) GDPR — our legitimate interest in answering enquiries and in preventing abuse of the contact form | 24 months from the date of your enquiry, so that we can follow up and see the history of a recurring issue |
| Transactional email and in-app notifications | Email address, notification preferences, delivery and bounce logs | Art. 6(1)(b) GDPR for service messages; Art. 6(1)(a) GDPR — consent — for the newsletter | Delivery logs for 12 months; preferences for the life of the account |
| Swapilot move-planning assistant | The messages you send to the assistant, including route, dates, volume and budget details you choose to provide | Art. 6(1)(a) GDPR — your consent, given by choosing to use the assistant | Prompts are sent to OpenAI for generation and are not used by us to train models; conversation history is kept for 90 days |
| Audience measurement and performance monitoring | Pages viewed, referrer, approximate region, device type, page load timings | Art. 6(1)(a) GDPR — your consent, given through the cookie banner | Aggregated after 25 months |
| Recording your consent choices | Consent ID, categories granted, policy version, locale, salted hash of your IP address, user agent, timestamp | Art. 7(1) GDPR — demonstrating that consent was validly obtained | 3 years from the date the consent was recorded |
Where we rely on legitimate interests under Art. 6(1)(f) GDPR, we have carried out a balancing test weighing our interest against your rights and freedoms. You can request a summary of that assessment at privacy@flatswaps.com.
3. Your tenant application portfolio
The rental application pack lets you store the documents landlords normally ask for: proof of income, a Schufa or equivalent credit report, a rent-arrears certificate, a copy of your ID card or passport, a tenant self-declaration and a cover letter. These are sensitive financial and identity documents, so they are handled separately from the rest of your profile:
- Uploading is entirely voluntary. Nothing on Flatswaps requires you to provide these documents, and we do not read or analyse their contents.
- Documents are stored in a private bucket. Row-level security limits every file to the account that uploaded it.
- Nobody sees them unless you turn sharing on. Sharing generates a private link that you pass to a landlord yourself. Turning sharing off revokes the link immediately.
- A share link is an unlisted URL, not a password. Anyone you send it to can open it, and can forward it. Only share it with landlords you have chosen to deal with.
- You can delete any document at any time from your profile. Deletion removes it from storage and from any active share link.
- If your documents reveal data covered by Art. 9 GDPR — for example health information visible on a payslip — you are giving explicit consent under Art. 9(2)(a) GDPR by uploading them. You can withdraw it by deleting the file.
4. What other members can see
Flatswaps only works if members can evaluate each other, so parts of your profile are visible to others. Specifically:
- Visible to anyone, including people without an account: your listing, its photos, its approximate location, your first name, your profile photo and your verification badges.
- Visible to members you are in a conversation or swap with: your full name, the messages and attachments you send them, and the exact address once a swap is confirmed.
- Never visible to other members: your email address, your phone number, your payment details and your tenant portfolio documents, unless you deliberately share them.
Your listing shows an approximate location on the map rather than your exact address until a swap is confirmed. Anything you write in a message or listing description is your own choice to disclose, so avoid putting identity or financial details there.
5. Processors and recipients
We do not sell your personal data and we do not share it with advertisers. We do use service providers who process data on our instructions under a data processing agreement meeting Art. 28 GDPR:
| Provider | What they do for us | Processing location |
|---|---|---|
| Supabase | Database, authentication and file storage | EU (Frankfurt region) |
| Vercel | Website hosting and Web Analytics | EU and USA |
| Stripe | Card payments and subscription billing | Ireland and USA |
| PayPal | PayPal payments | Luxembourg and USA |
| Twilio | Phone number verification by SMS | Ireland and USA |
| Brevo | Transactional email delivery | EU (France and Germany) |
| Mapbox | Interactive maps and geocoding | USA |
| OpenAI | Swapilot move-planning assistant | USA |
Stripe and PayPal act as independent controllers for the payment itself and apply their own privacy notices to that part of the processing.
We may also disclose data to public authorities, courts or our legal advisers where we are legally required to, or where it is necessary to establish, exercise or defend legal claims.
6. Transfers outside the EEA
Most of your data stays in the EU. Some of the providers listed above process data in the United States. For those transfers we rely on:
- the European Commission's adequacy decision for the EU–US Data Privacy Framework, where the provider is certified under it; or
- Standard Contractual Clauses adopted by the Commission under Art. 46(2)(c) GDPR, together with supplementary technical measures such as encryption in transit and at rest.
You can request a copy of the safeguards we rely on for any given transfer by writing to privacy@flatswaps.com.
7. Your rights
Under the GDPR you have the following rights. All of them are free to exercise.
- Access (Art. 15)
- Download a complete copy of your data at any time from Settings → Your data. The file lists every category we hold, why we hold it and how long we keep it. You can also ask us by email instead.
- Rectification (Art. 16)
- Have inaccurate data corrected and incomplete data completed. Most profile and listing fields you can edit yourself in your account settings.
- Erasure (Art. 17)
- Ask us to delete your data. Closing your account triggers deletion automatically, except for records we must keep for tax, accounting or fraud-prevention reasons.
- Restriction (Art. 18)
- Ask us to pause processing while a dispute about accuracy or legitimate interest is being resolved.
- Data portability (Art. 20)
- The same download is machine-readable JSON, and the data you provided to us is flagged as portable so another provider can import just that part. Ask us if you would rather we transmit it directly.
- Objection (Art. 21)
- Object at any time to processing based on our legitimate interests, including profiling for match suggestions. We will stop unless we can show compelling legitimate grounds that override your interests.
- Withdraw consent (Art. 7(3))
- Withdraw any consent you have given — cookies, newsletter, the tenant portfolio, the Swapilot assistant — at any time. Withdrawal does not affect processing that already took place.
- Automated decisions (Art. 22)
- We do not make decisions producing legal or similarly significant effects about you by automated means alone. Match suggestions are ranked automatically, but they are only suggestions and never restrict your access to the service.
Access and portability are self-service: go to Settings → Your data and download the file. For anything else, email privacy@flatswaps.com. We will respond within one month as required by Art. 12(3) GDPR. If a request is complex we may extend that by two further months and will tell you why within the first month. We may ask you to confirm your identity before we act on a request.
8. Complaining to a supervisory authority
If you believe we have handled your data unlawfully, you have the right under Art. 77 GDPR to lodge a complaint with a supervisory authority. Our lead supervisory authority is:
You may also complain to the supervisory authority in the EU or EEA country where you live or work.
9. Cookies
We set only the cookies strictly necessary to run the site unless you consent to more. Our Cookie Policy lists every cookie, what it does and how long it lasts, and you can change or withdraw your choice there at any time.
10. Security
We apply the technical and organisational measures required by Art. 32 GDPR, including encryption in transit (TLS) and at rest, row-level security on every database table holding personal data, private storage buckets scoped to the owning account, hashed passwords, and access controls limiting staff access to what their role requires.
If a breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay as required by Art. 34 GDPR, and the Data Protection Commission within 72 hours under Art. 33 GDPR.
11. Is providing data mandatory?
Providing your name, email address and a password is necessary to enter into the contract with us; without them we cannot create an account. Everything else — your phone number, photos, tenant portfolio documents and assistant conversations — is optional, and declining costs you only the feature it relates to.
12. Children
Flatswaps is not directed at children. You must be at least 18 to create an account. If we learn that we hold data about a child, we will delete it without undue delay. If you believe a child has given us data, contact privacy@flatswaps.com.
13. Changes to this policy
We will update this policy when our processing changes. Every version carries a date, and we keep a record of which version you accepted. If a change materially affects your rights, we will tell you by email or in the app before it takes effect, and where the change relies on consent we will ask for it again.