Personal data - any information relating to an identified or identifiable natural person.

Processing - any operation or set of operations that is performed on personal data or sets of personal data.

Data subject - a natural person whose personal data is being processed.

We / us (whether or not capitalised) - ImmoPad

We are committed to the following data protection principles:

• Processing is lawful, fair and transparent. Our processing activities have legitimate reasons. We always consider your rights before processing personal data. We will provide you with information about the processing on request.

• Processing is limited to its purpose. Our processing activities correspond to the purpose for which the personal data was collected.

• Processing is carried out with a minimum of data. We collect and process only the minimum amount of personal data required for any purpose. Processing is limited in time. We will not keep your personal data longer than necessary.

• We will do our best to ensure the accuracy of the data.

• We will do our best to ensure the integrity and confidentiality of the data.

• Rights of the data subject

The data subject may exercise his/her rights:

1. Right to information - which means you need to know whether your personal data is being processed; what data is being collected, where it came from, why and by whom it is being processed.

2. Right of access - this means that you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your collected personal data.

3. Right of rectification - you have the right to request rectification or erasure of your personal data that is inaccurate or incomplete.

4. Right of deletion - in certain circumstances, you may request that your personal data be deleted from our records.

5. Right to restrict processing - under certain circumstances you have the right to restrict the processing of your personal data.

6. Right to object to processing - in certain circumstances you have the right to object to the processing of your personal data, for example in the case of direct marketing.

7. Right to object to automated processing - you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. You can exercise this right whenever there is a result of profiling that produces legal effects on you or significantly affects you.

8. Right to data portability - you have the right to obtain your personal data in a machine-readable format or, if feasible, as a direct transfer from one processor to another.

9. Right to complain - in the event that we refuse your request under your access rights, we will provide you with a reason why this is not possible. If you are not satisfied with the way your request has been handled, please contact us.

10. Right to assistance from the supervisory authority (CNIL France) - means that you have the right to assistance from a supervisory authority and the right to other legal remedies such as claiming damages.

11. Right to withdraw your consent - you have the right to withdraw any consent given for the processing of your personal data.

Collected data

Information you have provided to us

This may include your email address, name, billing address, home address, etc., primarily information needed to deliver a product/service to you or to enhance your customer experience with us. We store the information you provide to us so that you can, for example, comment or perform other activities on our website. This information includes, for example, your name and email address.

Information collected automatically about you

This includes information stored automatically by cookies and other session tools. For example, your IP address, email address, user ID, etc. This information is used to improve your customer experience. When you use our services or view content on our website, your activities may be logged.

Information from our partners

If we need to collect information from our trusted partners, we will do so with the confirmation that they have legal grounds to share this information with us. This may be information that you have provided to them directly or that they have collected about you for other legal reasons.

Publicly available information

If necessary we may collect information about you that is publicly available.

How we use your personal data

We use your personal data to :

• provide you with our best service, but also to simply communicate and interact with you, sometimes to inform you of changes to our services

• improve your customer experience

• fulfil a legal or contractual obligation

We use your personal data for legitimate reasons and/or with your consent.

Due to the conclusion of a contract or the performance of contractual obligations, we process your personal data for the following purposes

• to identify you

• to provide you with a service or send / offer you a product

• to communicate with you either for sales or billing purposes

On the basis of a legitimate interest, we process your personal data for the following purposes

• to administer and analyse our customer base (purchasing behaviour and history) in order to improve the quality, variety and availability of our services

• to conduct customer satisfaction surveys

Unless you inform us otherwise, we will continue to do so.

With your consent, we process your personal data for the following purposes

• to send you newsletters and campaign offers from us only

• For other purposes, we have asked for your consent to process your briefing, contact, application, training and other requests.

We process your personal data in order to fulfil obligations arising from the law and/or to use your personal data for options provided by law. We reserve the right to anonymise the personal data collected and to use this data. We will not use data outside the scope of this policy unless it is anonymised. We will retain your billing information and other information collected about you for as long as necessary for accounting purposes or other obligations under the law.

We may process your personal data for other purposes not listed here, but which are consistent with the original purpose for which the data was collected. In doing so, we will ensure that:

• the link between the purposes, context and nature of the personal data is appropriate for further processing

• further processing would not adversely affect your interests

• there would be an appropriate safeguard for the processing.

We will inform you of any further processing and its purposes.

Who else can access your personal data

We do not share your personal data with outside entities. In some cases, personal data about you is provided to our trusted partners to enable us to provide you with the best possible service or to improve your customer experience. We may share your data with our freelancers, financial partners and third party partners.

We take care to work only with processing partners who can provide an adequate level of protection for your personal data. We only disclose your personal data to third parties when we are legally required to do so. We may disclose your personal data to third parties if you have consented or if there are other legal grounds.

How we secure your data

We do our best to protect your personal data. We use secure protocols for communication and data transfer (such as HTTPS). We use anonymisation and pseudonymisation where appropriate. We monitor our systems for vulnerabilities and attacks. Our computer systems are protected (firewall, antivirus) and updated regularly (security updates, system, software...). Regular maintenance operations are in place to anticipate possible problems.

Although we do our best, we cannot guarantee the security of the information. However, we are committed to informing the relevant authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything reasonably possible to prevent security breaches and to assist the authorities in the event of a breach.

If you have an account with us for any service (email, online account, cloud access...) please be aware that you must keep your username and password secret and that you and we are jointly responsible in the event of a problem.

We use cookies for the following purposes:

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users' movements and collect information about users. This is done in order to personalise and enhance your experience with us.

A cookie is a small text file stored on your computer. Cookies store information used to help make the sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may prevent you from using certain features.

We may use cookies in the following cases:

• Necessary cookies - these cookies are necessary for you to be able to use certain important features on our website, such as logging in (if applicable). These cookies do not collect any personal information.

• Functionality cookies - these cookies provide features that make using our service more convenient and may offer more personalised features. For example, they may remember your name and email address in comment forms. This means you don't have to re-enter this information the next time you comment.

• Analytical cookies - these cookies are used to track the use and performance of our website and services

• Advertising cookies - these cookies are used to serve ads relevant to you and your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed on the website by advertising networks with the permission of the website operator. These cookies "remember" that you have visited a website and that this information is shared with other organisations such as advertisers. Often, targeting or advertising cookies will be linked to site features provided by another company.

You can delete cookies stored on your computer via your browser settings. You can also control certain third-party cookies by using a privacy-enhancing platform. For more information on cookies, visit cnil.fr.

We use Google Analytics to measure traffic to our website. Google has its own privacy policy which you can read here. If you wish to opt out of Google Analytics tracking, please visit the Google Analytics opt-out page.

Data protection contact (DPO)

Jean-Pascal Launay : contact@immopad.com

Changes to the privacy policy

The agency may make changes to this privacy policy.

The last modification was made on 04 October 2018.