Privacy Policy for hi-robin.ai

1. Controller & General Information

Service and Operator

This Privacy Policy applies to the AI-powered real estate search service hi-robin.ai (the "Service"). The Service is operated by SwissBid GmbH, a Swiss limited liability company (GmbH) with registered address at Alte Steinhauserstrasse 19, 6330 Cham, Switzerland. SwissBid GmbH ("we", "us", or "our") is the data controller responsible for processing personal data in connection with hi-robin.ai.

Applicable Laws

We are committed to protecting your privacy in compliance with the Swiss Federal Data Protection Act (Datenschutzgesetz, "DSG") and the EU General Data Protection Regulation ("GDPR"). These laws aim to safeguard the privacy and fundamental rights of individuals whose personal data is processed. This Policy is designed to meet the transparency and information requirements of both the DSG and the GDPR.

Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, you can contact us at info@robinrent.io. This is the dedicated contact for data protection inquiries. We do not currently have a designated Data Protection Officer, but we will ensure that any privacy-related request or complaint is handled in accordance with applicable law.

Global Availability

hi-robin.ai is a globally accessible service. However, our primary user base and business focus are in Switzerland and the European Union. We do not actively target users outside of these regions. By using the Service, you acknowledge that your personal data may be processed under the jurisdiction of Switzerland and (where applicable) the EU. (Note: Switzerland is recognized by the EU as providing an adequate level of data protection, facilitating data flows between the EU and Switzerland.)

2. Scope of Application

This Privacy Policy describes how we collect, use, disclose, and protect personal data when you use hi-robin.ai in any capacity. It applies to all users and use-cases, including:

• Visitors to our website (hi-robin.ai) and related webpages
• Individuals who interact with our AI assistant via the website or mobile app (with or without creating an account)
• Logged-in users of the Service (including those using third-party login like Google)
• Users of our in-app features or those who access hi-robin.ai through an embedded widget or third-party integration (e.g. via a ChatGPT SDK on partner websites)
• Both B2C individual users and B2B clients/partners who may incorporate our Service into their platforms

This Policy covers personal data processing for all of the above. Note that some features of the Service can be used without an account (e.g. an anonymous session), while other features require registration. In all cases, we handle personal data as described herein. By using hi-robin.ai, you agree that your data will be processed according to this Policy.

3. Description of the Service

hi-robin.ai is an AI-powered conversational real estate search and recommendation tool. It provides users with a chatbot-style interface to help find rental or sale property listings and receive personalized recommendations. Key characteristics of the Service include:

Conversational Interface

You can interact with the AI assistant by typing natural-language queries or preferences (for example, "I need a 2-bedroom apartment in Zurich with a budget of CHF 2,000"). The assistant will respond with property suggestions, answers, or follow-up questions to refine the search.

AI-Driven Recommendations

The Service uses artificial intelligence to filter and rank property listings based on your input. It analyzes your requirements and queries to identify relevant real estate listings from our database and third-party sources, then presents those results in a chat-based format.

Informational Use Only

hi-robin.ai is provided for informational and assistive purposes. No content or recommendation from the AI constitutes a legally binding offer, advice, or decision. The Service does not sign contracts, make guarantees, or enter into agreements on your behalf. All decisions (such as contacting a landlord, visiting a property, or signing a lease) are made by you (the human user). The AI's role is to help you discover and evaluate options, not to make decisions for you.

Human-In-The-Loop

We emphasize that a human is always in control of important outcomes. While the AI provides automated suggestions, you have the opportunity to review, ask follow-up questions, request clarifications, or ignore the recommendations. You can always consult a human expert (e.g. a real estate agent) before making any important decision. We do not engage in fully automated decision-making that would have a legal or significant impact on you (see Section 6 below).

No Professional Advice

Although the Service may provide information on neighborhoods, pricing, or general rental processes in response to your questions, this is for general guidance. It should not be taken as professional legal, financial, or real estate advice tailored to your situation. Always exercise your own judgment or consult professionals when making real estate decisions.

4. Categories of Personal Data Processed

We process personal data ("personal data" meaning any information relating to an identified or identifiable natural person) when you use hi-robin.ai. The types of personal data we handle fall into the following categories:

4.1 Data You Provide Explicitly

These are details you deliberately share with us. For example:

• Account Information: If you register an account, we collect the information you provide on sign-up such as your name, email address, phone number, and postal address. You will also create login credentials (e.g. a password). If you choose to sign in via Google Login, we receive basic account information from Google (such as your Google-connected name and email address). We do not receive or store your Google account password – authentication is handled by Google and we only get confirmation of your identity and the shared profile details.
• User Communications: If you communicate with us or provide input through the Service, we collect the content of those communications. This includes chat messages you send to the AI assistant, feedback or ratings you provide, and any inquiries you send to our support (e.g. emails to our contact address).
• Profile Details (Optional): You may have the option to enter additional profile information in the Service (for instance, indicating your housing preferences or personal circumstances). This could include data like your family status (e.g. whether you live alone or have a family), whether you have pets, preferred languages, or other preferences relevant to property searching. Providing this information is voluntary – it is intended to help tailor your search experience, but you are not required to fill out such fields to use the Service.

4.2 Data Collected or Generated Automatically

When you interact with hi-robin.ai, certain data is collected automatically by our systems or generated as a by-product of your usage. This includes:

• Conversation and Query Logs: We record the queries and messages you enter into the chatbot, as well as the AI's responses. This conversation content may include any personal information you choose to mention during the chat.
• Usage Metadata: Our servers automatically log metadata about your interactions, such as the times and dates of access, chat session lengths, features used, and referral information (how you arrived at our site or widget).
• Device and Technical Information: We collect information that web browsers and devices typically make available when you use online services. This includes your IP address (Internet Protocol address), which can give a general indication of your approximate location. We also collect your device type, operating system, browser type and version, and similar technical identifiers.
• Cookies or Similar Technologies: As detailed in Section 11, we use minimal cookies. Any cookies or local storage used are primarily for technical operation (like maintaining your session) or first-party analytics. We do not use third-party tracking cookies.

4.3 Data You Enter Voluntarily for Recommendations

Beyond basic account details, you might choose to input additional personal details into the Service to refine your property recommendations. This can include information about your lifestyle or needs, such as:

• Household & Preferences: For instance, you might tell the AI assistant about your household composition, your budget, preferred commute distance, or other lifestyle needs.
• Search Criteria: Any specific criteria you enter (desired number of rooms, property type, amenities, etc.) are considered in generating results.
• Feedback and Content: If you give feedback on property listings (for example, marking a recommended listing as "not suitable"), that feedback is stored and associated with your session or account to improve your future results.

Special Category Data

We do not ask for or intentionally process any special categories of personal data about you. Sensitive personal information such as your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, or information about your sex life or sexual orientation is not required for using our Service, and we do not aim to collect it.

Profiling and Special Processing

We do not engage in profiling that produces legal or similarly significant effects on you. In other words, we do not create extensive "personality profiles" of users or make consequential decisions about you using algorithms alone. The Service may adapt its responses to your inputs (which is a form of basic personalization), but it does not evaluate or categorize you in ways that would affect your rights or opportunities.

5. Purpose of Processing

We process personal data for the following purposes in connection with operating hi-robin.ai:

• Providing and Operating the Service: First and foremost, we use your data to deliver the functionalities of our Service. This includes using your input data to retrieve property listings and generate AI-driven responses, maintaining your account and login session, and generally making sure the platform works as intended for you.
• Personalization and Recommendation Relevance: We aim to make our property recommendations as relevant as possible. We use the information you provide (explicitly or through usage) to tailor the search results and suggestions to your needs.
• Improvement of the Service and AI Model Prompts: We continuously work on improving hi-robin.ai's performance, user experience, and the quality of AI interactions. Importantly, this does not involve using your data to train the underlying AI model (see Section 9 for details on AI training).
• Customer Support and Communication: If you contact us with questions, feedback, or support requests, we will use your provided contact information and message content to assist you and respond. We will not send you marketing emails or newsletters unless you have explicitly subscribed to them.
• Security and Abuse Prevention: We process certain data to protect the security and integrity of our Service and its users. For example, we may use IP addresses and device information to detect and prevent malicious activities.
• Legal Compliance and Obligations: Where necessary, we will process personal data to comply with our legal obligations. We only do so to the minimum extent required by applicable laws.

We will not use your personal data for any purpose that is incompatible with the above-listed purposes without informing you and obtaining your consent if required. We do not engage in unsolicited marketing or sale of your personal data.

6. AI & Automated Processing

hi-robin.ai uses artificial intelligence and other automated processing to provide its core functionality. It's important to understand what the AI does – and what it does not do – with regard to your personal data:

• AI-Powered Filtering and Ranking: When you enter a query or specify your preferences, our system automatically processes that input to filter through a large number of property listings. The AI and supporting algorithms will rank or select listings that best match your criteria.
• Natural Language Responses: The conversational AI (leveraging technology from OpenAI) generates human-readable answers and follow-up questions. It takes your query in plain language and produces a helpful response.
• No Solely-Automated Legal Decisions: Crucially, no decision that could have a legal effect or similarly significant impact on you is made solely by the AI without human involvement. The AI does not, for instance, approve or reject any application, determine your eligibility for housing, set your credit terms, or anything of that nature. Its role is advisory and supportive.
• Transparency and Explanations: We strive to maintain transparency about how the AI works. You can always ask the AI follow-up questions if something isn't clear.
• Human Oversight: Our team monitors the AI's outputs and overall system performance. We have the ability to intervene, update, or correct the AI's processes.

In summary, automation and AI are used to enhance the speed and quality of property searches on hi-robin.ai, but these automated processes do not override human control or judgment.

7. Data Sources for Property Information

The property listings and information that hi-robin.ai provides come from a variety of data sources:

• Licensed Feeds & Partner APIs: We receive property listings from real estate partners, agencies, or listing platforms through data feeds and APIs.
• Publicly Accessible Sources: Our system may gather information from publicly available websites and databases where properties are listed.
• Direct Listings from Users or Clients: In some cases, landlords, property owners, or real estate brokers may directly list properties on hi-robin.ai or through our B2B integrations.

We emphasize that we do not collect or process personal data about landlords, owners, or brokers beyond what is necessary to link you to the property listing. When we show listings sourced from third parties, we provide attribution or links to the original source of the listing.

8. Legal Bases for Processing

We process your personal data only when there is a valid legal basis to do so. Under the GDPR (Article 6) and the principles of Swiss law, the main legal grounds that apply to hi-robin.ai's processing are:

• Consent: In certain cases, we rely on your consent. Where processing is based on consent, you have the right to withdraw your consent at any time.
• Performance of a Contract: Much of our data processing is necessary for the performance of the contract between you and us – or in order to take steps at your request prior to entering into a contract.
• Legitimate Interests: We also process data as necessary for our legitimate interests, provided those are not overridden by your interests or fundamental rights.
• Legal Obligation: In some situations, we process personal data to comply with a legal obligation to which we are subject.

If you have questions about the legal basis for any specific processing of your personal data, please contact us.

9. AI Training & Model Use

We understand that users might be concerned about how their data is used in relation to our AI systems. Here we clarify our conservative stance on AI data usage:

• No Use of Personal Data for AI Model Training: We do not use your conversations or personal information to train the underlying AI models. The AI that powers hi-robin.ai's chat responses is provided by OpenAI (through their API). We have configured and use this AI in a way that does not feed your data back into OpenAI's general model training.
• No Fine-Tuning with User Data: We do not perform our own custom "fine-tuning" of AI models using your personal data either.
• Limited Use for Prompt and Service Quality Improvement: We may internally review some anonymized or sampled conversation transcripts to help improve the service, but this is done in a controlled manner and not to train the AI model itself.
• No Sharing of Raw Data with AI Vendor: Other than the necessary real-time query to the AI to get a response, we do not send your personal data to any AI or machine learning service. We have a data processing agreement in place with OpenAI that incorporates Standard Contractual Clauses for data transfer.
• No Opt-Out Required (By Design): Because we have architected the system to not use your data for AI training or any secondary purposes, we do not present additional opt-out choices to users for AI training.

In summary, we treat the personal data processed by hi-robin.ai with high sensitivity and do not contribute it to the broader AI ecosystem. This conservative approach reflects our commitment to privacy.

10. Third-Party Processors and Service Providers

In operating hi-robin.ai, we rely on certain trusted third-party service providers to perform technical operations on our behalf. Each of these providers is bound by contractual obligations to process personal data only for our purposes:

• Hosting and Infrastructure: The hi-robin.ai platform is hosted on secure servers located in the European Union. All data storage and backups are likewise in EU-based systems.
• Artificial Intelligence API (OpenAI): We use OpenAI as our AI technology provider to generate the conversational responses. OpenAI is restricted from using your data for any purpose other than providing the response to us.
• Analytics (PostHog): We use PostHog for collecting analytics about how users interact with hi-robin.ai. PostHog is configured in a self-hosted, first-party manner within the EU.
• Authentication (Google Sign-In): If you choose to log in using Google Sign-In, Google acts as an identity provider.
• Email and Communications: We use standard email services to send communications.

All third-party processors only act on our instructions. We do not sell or share your personal data with third parties for their own independent use.

International Data Transfers

We store and process data primarily in Switzerland and the EU. In cases where our processors are outside of Switzerland/EU (for example, OpenAI and Google in the USA), we take legally required steps to ensure your data remains protected. This includes using European Commission-approved Standard Contractual Clauses (SCCs) as a transfer mechanism.

11. Cookies & Tracking Technologies

We value a clean and privacy-friendly user experience. As such, we do not use any non-essential cookies or third-party tracking technologies on hi-robin.ai that would require a cookie consent banner.

• No Third-Party Advertising or Social Media Cookies: We do not deploy any cookies for advertising, marketing, or social media purposes. You will not find Google Analytics, Facebook Pixel, or similar trackers on our Service.
• Minimal Use of Cookies: Our website may use a very limited number of cookies, and only for technical purposes such as authentication (session cookies) and preferences.
• Analytics (First-Party): We use PostHog for analytics in a self-hosted manner. If a cookie is used for analytics, it is only to distinguish new versus returning users on our own site, and it does not track you across other sites.
• No Cookie Consent Banner Required: Given that we only use cookies that are strictly necessary for the service or are privacy-neutral first-party analytics, we do not present a cookie consent popup.

In summary, hi-robin.ai's use of cookies is minimal and purely functional. You can use the Service without worrying about hidden third-party tracking.

12. Data Storage & Security

We take the security of your personal data very seriously and implement a range of technical and organizational measures to protect it:

• Data Location: All personal data collected through hi-robin.ai is stored on secure servers located in Switzerland or the European Union.
• Encryption in Transit and At Rest: We use encryption to safeguard your data both during transmission (TLS/SSL) and when stored. Passwords are stored as salted cryptographic hashes, not in plain text.
• Access Controls (Need-to-Know and RBAC): We limit access to personal data strictly on a need-to-know basis with role-based access control.
• Audit Logs and Monitoring: We maintain audit logs for critical systems that record access and actions performed on personal data.
• Network Security: Our servers are protected by firewalls and network segmentation. We conduct periodic security assessments and penetration testing.
• Data Minimization: We minimize what data we collect and retain to reduce risk.
• Incident Response: We have a data breach response plan in place and will notify affected users and authorities within the required timeframes if necessary.

In summary, we employ state-of-the-art security measures, including encryption, strict access control, and monitoring, to protect your data.

13. Data Retention

We keep personal data only for as long as it is necessary to fulfill the purposes described in this Privacy Policy, or as required by law:

• Account Information: We retain your account data for as long as your account is active. If you delete your account, we will remove or anonymize your personal information.
• Chat Logs and Conversation Data: Conversational data is retained for a reasonable period to enable continuity and improve service. After that, we may aggregate or anonymize it.
• Usage Data and Analytics: Raw logs containing IP addresses or device identifiers are kept for a short period, then either deleted or anonymized.
• Communications: Support communications are kept for a period necessary to address your issue and for our records.
• Legal Retention Requirements: We may retain certain data for a longer period if required by applicable law.

When we no longer have a legitimate need or legal obligation to retain your personal data, we will delete it or anonymize it in our systems.

14. Your Rights as a Data Subject

As a user of hi-robin.ai and as a data subject under applicable data protection laws, you have certain rights regarding your personal data:

• Right of Access: You have the right to request confirmation of whether we are processing personal data about you, and if so, to obtain a copy of that data.
• Right to Rectification: If you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure: Also known as the "Right to be Forgotten," this allows you to request the deletion of your personal data in certain circumstances.
• Right to Restrict Processing: You have the right to request that we restrict (pause) the processing of your data under certain conditions.
• Right to Data Portability: For data that you have provided to us, you have the right to request a copy in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to certain types of processing, including processing based on legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent to process data, you have the right to withdraw that consent at any time.
• Right to Complaint: If you have concerns about our data practices, you have the right to lodge a complaint with a supervisory authority. For Swiss users, this would be the Federal Data Protection and Information Commissioner (FDPIC).

To exercise any of your rights, please contact us at info@robinrent.io. We will respond to your request as soon as possible, and at latest within the timeframe required by law.

15. Minors

hi-robin.ai is not specifically targeted at children, but it is a general service that could potentially be useful to teenagers (for example, those looking for student housing or helping parents with a search).

• Usage by Minors: Individuals under 18 years of age are not prohibited from using hi-robin.ai. The content provided by our Service is generally appropriate for all ages.
• Parental Guidance: If you are under the age of 16, we advise that you use hi-robin.ai with the consent and/or guidance of a parent or guardian.
• No Collection of Data on Age: We do not ask users for their age or date of birth when signing up or using the Service.
• Content Moderation: We use the underlying AI's content moderation filters to prevent disallowed or harmful content from being shown.
• No Minor-Specific Profiling: We do not knowingly create profiles of minors or target them with any marketing.

If you are a parent or guardian and you believe your child under 16 has provided personal data to us without your consent and you want it removed, please contact us and we will promptly address it.

16. Updates to this Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we do so, we will notify users in an appropriate manner:

• Posting the New Policy: Any changes will be posted on this page (the Privacy Policy page), and the "Last updated" date will be revised accordingly.
• Notice of Material Changes: If we make material changes to the Policy, we will provide a more prominent notice. This may include an email notification to registered users, an in-app alert, or a banner on our website.
• Consent for New Uses: If any update would require your consent, we will seek your consent before processing.

Your continued use of hi-robin.ai after the effective date of an updated Policy will signify your acceptance of the revised terms. If you have any questions or concerns about any changes, please reach out to us via the contact information provided.