Privacy Notice – Apartment Search

This notice describes what happens to your personal data when you use neoflat to search for an apartment – searching, filtering, creating a search profile, saving a search, shortlisting a listing, registering for a viewing, joining a waiting list, or applying for an apartment.

This notice stands on its own. It supplements two existing documents that it deliberately does not replace: the website privacy notice at /datenschutz (cookies, server log files for a plain website visit – it expressly covers only visiting this website, not apartment searching itself), and the milo portal privacy notice for the tenant role (contract management, consumption data, energy brokerage).

neoflat and the milo portal share one account. Anyone who holds both roles – a tenant who is also searching for a new, larger, or smaller apartment – reads this notice in addition to the tenant privacy notice, not instead of it. This notice describes only the processing that arises from apartment searching itself. The terms of use for the search side are the separate page /nutzungsbedingungen.

The search and filter function (city, rooms, rent, features) is open without an account. This produces the same technical data as any visit to this website (server log files, IP address) – details are in the website privacy notice (/datenschutz, section 3).

For anything beyond searching, filtering, and viewing, you need an account (terms of use, section 3). The account is managed together with the milo portal: your login details (email, name, password hash) are collected under the same rules as a milo registration. The processing of this account data itself is described in the tenant privacy notice. This notice only adds what specifically arises from using neoflat as an apartment seeker – the following sections.

With an account you can create a search profile. It contains what you are looking for: number of rooms, size, budget, move-in window, feature preferences, who will move in, preferred districts, commute addresses, accessibility requirements, and further details you may add freely. We automatically match your search profile against available listings (Art. 6(1)(b) GDPR) and show you suitable matches. Providers cannot browse search profiles; they only see aggregated numbers without names. You can change or delete your search profile at any time.

One exception: the property management of a provider with whom you – as a tenant – already have a tenancy can view a single search profile within its own organization (the case "property management suggests a suitable apartment to an existing tenant"). It never sees search profiles of other organizations, and the aggregated overview across all search profiles shows it only numbers, never names.

If you save a search, we automatically match it against new listings and notify you by email about matches (Art. 6(1)(b) GDPR). Every such email contains an unsubscribe link that permanently deactivates the saved search without requiring you to be logged in. You can also turn off the notification in your account.

The shortlist stores which listings you have saved (Art. 6(1)(b) GDPR, convenience function). The provider of a listing only learns an aggregated number once it reaches three, never who shortlisted it.

If you gave separate consent when creating your account – via its own, not pre-checked box, separate from agreeing to the terms of use – neoflat may email you to invite you to express interest in a shortlisted listing. The sole legal basis for this is your consent (Art. 6(1)(a) GDPR / § 7 UWG), not the terms of use (see docs/decisions/2026-08-06-merkzettel-einladung-einwilligung.md). Without this consent you will not receive such an email. The sender is always neoflat, never the provider. You will receive at most one such invitation per listing. You can withdraw this consent at any time with effect for the future.

You register for a viewing directly on the listing; for this we need your name and at least one way to contact you (email and/or phone number). This information is passed to the provider of the listing so the appointment can take place (Art. 6(1)(b) GDPR). We confirm the registration by email or, if no email is available, by SMS (section 11).

If you register for a viewing without an existing application, this additionally creates an "interested party" record with the same contact details – the technical intermediate stage between an anonymous search and an application. This record is deleted at the latest twelve months after registration, regardless of whether you later turn it into an application; the period is fixed and cannot be extended. If you register for a viewing while already having an application, no second interested-party record is created.

If a viewing appointment is full, you are placed on the waiting list for that appointment. Some listings additionally have a waiting list for the apartment itself; order is based on the time of registration, and there is no paid priority. Waiting-list entries for the apartment are deleted at the latest six months after registration. You can leave the waiting list at any time – via your account or via the link in the confirmation email, which also works without being logged in.

By applying, you send the provider of a listing: name, contact information, desired move-in date, number of people moving in, employment, and – if you wish or the listing requires it – documents such as proof of income (Art. 6(1)(b) GDPR). The application goes exclusively to the provider of that specific listing; other providers do not see it.

We request sensitive information in stages: the exact amount of income and a credit report (such as Schufa) only once the provider shows recognizable interest – not already with the first application (data minimization, Art. 5(1)(c) GDPR).

neoflat helps the provider organize many applications: your application is automatically structured and given a score that is derived traceably from your information (section 12). The decision on your application is made by the provider, not the system.

If you invite other people to join your application (such as a partner or roommate), we process their information to the same extent as your own. You can withdraw an application at any time and remove uploaded documents individually.

Note for legal review: the specific retention period for closed applications is a per-provider placeholder in the code (ScoringConfig.retentionMonths, TODO(legal) in applicants/retention-cron.ts) – the same open question as A6 in the terms-of-use draft. This text therefore deliberately states no number, see section 13.

If a listing mentions a fixture buyout ("Ablöse"), that is an agreement between you and the previous tenant. neoflat only displays the information involved and does not become a party to that agreement.

To deliver the messages named in this notice, we use the following processors, each within the EU/EEA: email via Scaleway (transactional email); SMS via seven.io, sender "mieterOS" – your phone number is recorded masked in our own logs (only the last four digits), never the message text; hosting via Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (as in the website privacy notice).

If an acceptance (section 09) cannot be delivered to you by email because no email address is on file but an address is, you additionally receive it by letter through the mail service provider LetterXpress (A&O Fischer GmbH & Co. KG – processing exclusively within the EU/EEA per the data processing agreement). Your name, address, and the content of the letter are stored for 60 days and then fully deleted (data processing agreement §6.19).

If you use the milo app (not the neoflat web interface), you can enable push notifications. We then store a technical push endpoint with the origin marker "neoflat" so it remains identifiable through which interface the subscription was created.

Applications receive an automatically calculated score that helps the provider compare many applications (section 9). The final decision is always made by the provider, not the system – based on the system's current state, no decision that is exclusively automated within the meaning of Art. 22 GDPR takes place.

Search profile: persists until you change or delete it yourself – there is currently no automatic age-based deletion period. Saved searches: persist until you turn them off or deactivate them via the unsubscribe link. Shortlist entries: persist until you remove them individually. Waiting list for an apartment: deleted at the latest six months after registration. Viewing registration / interested-party record: deleted at the latest twelve months after registration, a fixed period (section 8). Application including documents: kept for a limited time after the application process concludes; the exact number of months is not yet fixed (section 9, an open question like A6 in the terms-of-use draft) – this text therefore deliberately states no number. Account: until account deletion, see the tenant privacy notice.

If you delete your account entirely, that removes or anonymizes the records named above, not just your access to them: the search profile is deleted, and a viewing registration plus any already-booked viewing appointment are anonymized (your identifier is replaced with a technical placeholder, while the appointment itself remains as an operational record). Independent of that, you can delete your search profile, shortlist entries, and viewing registrations yourself and individually at any time, even before deleting your account.

Question B4 of this draft (2026-08-07 version) is closed: measured against the code, a full account deletion now also removes/anonymizes the search profile and viewing registrations automatically (not only waiting-list entries and the interested-party record as before) – see apps/api/src/modules/compliance/deletion-job.ts. The previously open question of whether the user-initiated individual deletion, available at any time, was sufficient for Art. 17 GDPR is now moot: both mechanisms exist side by side.

You have the right to access, rectification, erasure, restriction of processing, data portability, and objection (Art. 15 to 21 GDPR), as well as the right to withdraw consent at any time with effect for the future. For rectification, restriction, and objection we currently handle a request manually via datenschutz@m4ma.com. The automated self-service export described in the tenant privacy notice runs through the same account shared with the milo portal (section 4) and, as of this version, also includes the search-track data named in this notice (search profile, shortlist, saved searches, waiting list, interested-party/application record, viewing registration and appointment).

In the event of violations of the GDPR, you have the right to lodge a complaint with a supervisory authority. The competent supervisory authority is the Bavarian State Office for Data Protection Supervision (BayLDA, Ansbach).

We update this notice whenever the processing it describes changes. The "last updated" indication at the top of the page shows the most recently substantively changed version.

Note for legal review: there are no active users yet. Unlike the terms of use, a privacy notice is an information duty (Art. 13 GDPR), not a declaration of intent – a version change here does not trigger re-acceptance, see the versioning section of the draft document.

• B1 Does the description above (paragraph 2) satisfy the Art.
• B5 For Scaleway and seven.io, a data-processing-agreement review as thorough as the one already completed for LetterXpress (docs/avv-letterxpress-2026-08-06.md) is still missing – to be completed before the first go-live..
• B3 Does the wording above satisfy the transparency duties of Art.

Related, but outside this document: A2, A3, and A6 in the terms-of-use draft (docs/reviews/2026-08-06-neoflat-nutzungsbedingungen-entwurf.md) describe the same three underlying facts from a contractual rather than a data-protection perspective – both sets of questions should be discussed with legal counsel together.