Privacy Policy

1. Introduction

This Privacy Policy explains how Breathe Technology d.o.o. collects, uses, stores and protects personal data when you use Domus, visit our website, contact us or use our rental property and tenancy record platform.

Domus is designed to help landlords keep rental property and tenancy records organised, and to allow tenants to access shared tenancy records when invited by a landlord.

2. Who we are and our role

Breathe Technology d.o.o. operates Domus and is responsible for personal data processed for account creation, website enquiries, platform access, support, security, service emails and subscription access management.

Landlords decide what property and tenancy information they enter into Domus. Where a landlord enters or shares tenancy information about a tenant, that landlord may also be responsible for how that tenancy information is used in relation to the rental relationship.

Paddle processes payment, checkout, billing, tax, invoice and order support information under its own legal terms.

3. Contact

Domus is operated by Breathe Technology d.o.o., company registration number / matični broj 22147781, PIB 115366147, with its registered office / headquarters at Luke Ćelovića Trebinjca 40, 11102 Belgrade (Savski Venac), Serbia.

For privacy questions, requests or concerns, contact us at support@domusproperty.org.

4. Personal data we process

Depending on how you use Domus, we may process the following categories of personal data:

• Account and profile data: name, email address, authentication data handled through our authentication provider, user type or role (such as landlord, tenant, invited tenant or admin), preferred language and email preferences.
• Contact and support data: contact form messages, support emails and other communications with Domus.
• Landlord and property data: property name, address, property details entered by the landlord, active or archived status, and tenancy setup information.
• Tenant and tenancy data: tenant name, tenant email, tenant phone if entered, preferred language, tenancy dates, tenancy status, primary tenant link, and additional named people entered by a landlord where applicable.
• Rent and financial record data: rent periods, rent amount and currency, payment submitted status, landlord confirmation status, payment notes, dates and any attachments or proof uploaded by users. Domus records rent-related information. Domus does not process rent payments.
• Utilities and bills data: utility bill batches, provider names, amounts, due dates, payment status and uploaded bills or supporting documents.
• Deposit data: deposit amount, currency, received status, deposit outcome at tenancy closeout, and notes or supporting records.
• Lease and document data: lease documents, addendums, building rules, house rules and other uploaded tenancy documents.
• Keys and access item data: key types, access cards, fobs, garage remotes, quantities, notes and images if uploaded.
• Maintenance data: maintenance requests, planned maintenance notices, issue details, urgency, access notes, status, and images or attachments uploaded by users.
• Entry and exit condition report data: area names, condition notes, damage or issue notes, photos and review notes.
• Tenancy closeout data: keys returned status, final rent status, final utilities status, deposit outcome, closeout acknowledgement and notes.
• Invitation and access data: tenant invitations, invite email, invite status, expiry date, accepted or cancelled status, and access links between landlords, tenants, properties and tenancy records.
• Subscription and payment access data: Paddle customer ID, Paddle subscription ID, plan tier, subscription status, trial dates, current period dates, and payment failed or past due status where received from Paddle. Domus does not collect or store card details directly. Payment method details are handled by Paddle.
• Technical and security data: IP address, device and browser information, authentication events, security logs, usage logs, audit logs, email delivery logs, and cookie or similar technology data where applicable.

5. Uploaded content and sensitive information

Domus allows users to upload documents, bills, photos, notes and other records connected to a rental property or tenancy. These uploads may contain personal data.

Users should only upload information that is relevant to the tenancy record and should avoid uploading unnecessary sensitive personal data. Domus is not intended for storing unrelated personal, medical, financial or identity documents unless they are genuinely relevant to the tenancy record.

6. Why we process personal data and legal basis

We process personal data for the purposes below. The legal basis may depend on the specific context and applicable law.

• Create and manage user accounts (name, email, login data, role, preferred language): contract, legitimate interests.
• Provide the Domus platform (property records, tenancy records, module data, shared record access): contract, legitimate interests.
• Enable landlord and tenant shared records (tenant invitations, tenant links, shared tenancy data, confirmations, acknowledgements): contract, legitimate interests.
• Send service emails (email address, language preference, event data, notification preferences): contract, legitimate interests, consent where required.
• Respond to enquiries and support requests (contact messages, support emails, account information): legitimate interests, contract.
• Manage subscription access (plan tier, Paddle customer and subscription IDs, subscription status, trial and period dates): contract, legitimate interests, legal obligation.
• Keep the platform secure (IP address, authentication events, device and browser information, logs, audit records): legitimate interests, legal obligation where applicable.
• Maintain legal, accounting and business records (subscription records, invoices and receipts handled by Paddle, account records, support communications): legal obligation, legitimate interests.
• Improve Domus (usage patterns, support feedback, technical logs): legitimate interests, consent where required.
• Handle legal requests or disputes (account records, tenancy records, communications, logs): legal obligation, legitimate interests.

7. Shared tenancy records

Domus allows landlords to create tenancy records and invite tenants to access shared parts of those records. When a tenancy record is shared, the invited tenant can see information made available to them in Domus, such as rent records, utility records, lease documents, key records, maintenance records, reports and closeout information, depending on the modules used.

Landlords should only enter and share information that is relevant to the rental property and tenancy.

8. No tenant scoring or automated decisions

Domus does not create tenant scores, landlord scores, public rental ratings or automated decisions about tenancy eligibility. Domus is a record platform. It does not decide whether a tenant should be accepted, rejected, renewed or removed.

9. Who we share data with

Domus may share relevant personal data with:

• Paddle, for checkout, billing, subscription payments, tax, invoices and order support.
• Authentication providers.
• Hosting, database and cloud infrastructure providers.
• Email delivery providers.
• File storage providers.
• Security, monitoring or logging providers, if used.
• Analytics or product improvement tools, if used.
• Legal, accounting and compliance advisers.
• Public authorities where legally required.
• Landlords and tenants, where data is shared within a tenancy record according to the product's access rules. A tenant invited to a shared tenancy record can see information shared with them in that record. A landlord can see tenancy and property information connected to records they manage. Additional named people entered by a landlord are landlord-only in the current product unless product behaviour changes later.

We do not sell personal data to advertisers or other third parties for their own marketing purposes. We only share personal data as described in this Privacy Policy and where necessary to provide our services, comply with legal obligations, or protect our legitimate interests.

10. Payments and Paddle

Domus uses Paddle for checkout, billing and subscription payments. Paddle may process payment method details, billing details, tax information, invoices, receipts, refunds and order support information under its own legal terms.

Domus receives subscription and access information from Paddle, such as customer ID, subscription ID, plan, status, trial dates and billing period dates. Domus does not collect or store card details directly.

11. International transfers

Domus and our service providers may process personal data in Serbia, the European Economic Area (EEA), the United Kingdom, the United States, and other countries where our providers operate. As a result, your personal data may be transferred to, stored in, or accessed from countries outside the country where you are located.

Where Serbian data protection law applies, personal data may be transferred from Serbia to a state party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. Personal data may also be transferred from Serbia to a state that is not party to that Convention, or to an international organisation, where that state or international organisation provides an appropriate level of personal data protection under applicable law or where a valid data transfer mechanism applies.

Where required by applicable data protection laws, we use appropriate safeguards designed to protect the confidentiality and security of personal data transferred internationally. These safeguards may include Standard Contractual Clauses approved by the European Commission, standard contractual clauses or other contractual safeguards approved by the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia, or other lawful transfer mechanisms.

We take reasonable steps to ensure that international transfers of personal data are carried out securely and that personal data continues to receive an appropriate level of protection regardless of where it is processed. For more information about the safeguards we use for international transfers, you may contact us using the details provided in this Privacy Policy.

12. Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this policy, unless a longer period is required or permitted by law.

• Account data is retained while the account exists and for a reasonable period after closure.
• Property and tenancy records are retained while needed to provide Domus, including read-only access to ended tenancy records where applicable.
• Subscription and payment access records are retained as needed for service operation, accounting, legal and compliance purposes.
• Paddle may retain payment and billing records under its own legal terms.
• Contact and support messages are normally retained for up to 24 months, unless further communication, legal, security or business reasons require longer retention.
• Technical, security and audit logs are normally retained for shorter periods, unless needed for security, misuse prevention, troubleshooting or legal reasons.
• Backups may retain copies for a limited backup cycle before deletion is fully reflected.

We may retain certain records where necessary to comply with legal obligations, resolve issues, enforce terms or protect rights and security.

13. Your rights

Subject to applicable law, you may have the right to:

• Be informed about how we collect, use, share and protect your personal data, including through this Privacy Policy (Right to Be Informed).
• Access the personal data we hold about you and obtain information about how we process it, including the purposes of processing, categories of data, recipients, retention periods and other information required by applicable law (Right of Access).
• Correct inaccurate or incomplete data (Right to Rectification).
• Request deletion of your data (Right to Erasure / Right to Be Forgotten).
• Restrict certain processing (Right to Restrict Processing).
• Object to certain processing (Right to Object).
• Receive your data in a portable format, where applicable (Right to Data Portability).
• Withdraw consent, where processing is based on consent (Right to Withdraw Consent).
• Lodge a complaint with a relevant data protection authority (Right to Lodge a Complaint).
• Not be subject to certain automated decisions, where applicable (Automated Individual Decision Making).

To exercise these rights, contact support@domusproperty.org. In Serbia, you may also contact the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, 11120 Belgrade, Serbia, telephone +381 11 3408 900, email office@poverenik.rs, website https://www.poverenik.rs.

14. Children

Domus is not directed at or intended for use by children, and we do not knowingly create accounts for children or collect personal information from children.

Users should avoid uploading unnecessary personal data about children or other third parties unless it is relevant to the tenancy record.

If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using our official contact details.

15. Security

We use technical and organisational measures designed to protect personal data, including access controls, encrypted connections, authentication controls and operational security monitoring where appropriate.

No system can be guaranteed fully secure, and we cannot promise absolute security. We use reasonable measures to protect your personal data, but no internet transmission is completely secure.

Please keep your username, password and other account details confidential. If you believe your account has been compromised, contact us immediately.

16. Cookies

Domus currently does not use non-essential cookies for advertising or third-party tracking. We may use essential cookies or similar technologies needed for login, security and service operation. If analytics, advertising or other non-essential cookies are introduced later, this policy will be updated and consent will be handled where required.

17. Updates to this policy

We may update this Privacy Policy from time to time. The latest version will be published on this page with an updated date. If we make material changes, we will take reasonable steps to notify users where required.