PRIVACY POLICY
PROPERTIPS APPLICATION AND WEBSITE
NOVEMBER 2023

ATTENTION: propertips regularly updates its documentation on the protection of personal data

This policy is subject to change and propertips invites Users of the Site and Application to consult it regularly

• propertips (the trading name of the company NosRezo) is attentive to the protection of the personal data of its Users and ensures a high level of protection of this data, in compliance with the applicable legislation and regulations.

• It protects this data in accordance with
  - Regulation (EU) n°2016/679 of 27 April 2016 (RGPD),
  - the French Data Protection Act no. 78-17 of 6 January 1978, as amended by Act no. 2018-493 of 20 June 2018 and Order no. 2018-1125 of 12 December 2018 on the protection of personal data and amending Act no. 78-17 of 6 January 1978 on data processing, data files and individual liberties and various provisions on the protection of personal data.

• This Privacy Policy informs Users of the Site and the Application about how propertips collects and processes their Personal Data. This policy also outlines propertips' practices for collecting and processing Personal Data from Users of the Site and the Application, including the types of information collected about Users of the Site and the Application and how propertips processes such information

• The Site and the Application are the property of NosRezo (trade name propertips), a société par actions simplifiée (simplified joint stock company) registered with the Melun Trade and Companies Register and having its registered office at IMMEUBLE CARRÉ HAUSSMANN III Allée de la Ferme de Varâtre 77127 LIEUSAINT, France.

• This privacy policy applies to all Users of the Site and the Application.

• propertips is the designer and publisher of the Site and the Application.

• All Users of the Site and the Application can be informed at any time about the protection of their personal data by contacting propertips:

• by post, to the address: IMMEUBLE CARRÉ HAUSSMANN III Allée de la Ferme de Varâtre 77127 LIEUSAIN

• par email, à l’adresse : privacy@propertips.com

I. INFORMATION ON THE PERSONAL DATA OF USERS OF THE PROPERTIPS WEBSITE AND APPLICATION

1.DEFINITIONS

• The following words and expressions are used herein with the following meaning :

• The terms "personal data" ("personal data"), "process/processing", "controller", "processor", "recipient(s)", "consent", "file", have the same meaning as set out in Article 4 of the RGPD.

• The Application" means the propertips Application;

• The User" refers to any person using the Site and the Application and in particular :

• The Affiliate" refers to any natural person of legal age registered on the Site and the Application, holding an account and ensuring contact between a seller or buyer and a partner;

• The Partner" refers to any Affiliate holding an account and acting in a professional capacity, likely to receive a recommendation or to be contacted by an Affiliate. The Partner may be a Benefit Partner or a Fee Partner;

• The "Partner with benefits" refers to any Partner for whom the Site and the Application allow the User to give a recommendation or to make contact.

• The "Hot List" refers to the list of contacts that a User of the propertips Application enters

• Matching" refers to the possibility for a User to contact a Partner for a fee, to organise a match between another Affiliate and a Partner for a fee and to organise a match between a Contact and a Partner for a fee

• The Site" refers to the www.propertips.com website

2.WHO IS THE DATA CONTROLLER? :

The controller of the personal data processed via this Site and the Mobile Application is NosRezo (trading name Propertips), a simplified joint stock company registered in the Melun Trade and Companies Register under number R.C.S 800118788 and whose registered office is located at: IMMEUBLE CARRÉ HAUSSMANN III Allée de la Ferme de Varâtre 77127 LIEUSAINT, represented by its current legal representative.

3. WHAT PERSONAL DATA IS PROCESSED? :

Your personal data is processed when you register on the Site and the Application and when you use it.

The information provided by Users includes, but is not limited to:

• Civil status data: account ID, profile photo, surname, first name, email address, postal address, country, date of birth, gender, place of birth, nationality; Bank details ;

• Bank details

• Social security number;

• Data related to your contacts and exchanges with propertips ;

• Data related to your comments and opinions on professionals.

• Technical data relating to browsing and interaction: visitor statistics: IP address, cookies, for example the pages you visit and the date and time you visit them (see Cookie Policy);

• Geolocation data: you can choose to communicate your geolocation coordinates via the geolocation function on the propertips Site and Application, by clicking on the button provided for this purpose;

• If you have any questions regarding the processing of your personal data or the grounds for such processing, you may contact propertips by e-mail privacy@propertips.com or by post.

Your data is collected by propertips when you create your account and throughout your use of the Site and the Application.

When you fill in your personal data, we indicate whether it is compulsory or optional by means of an asterisk, as well as the consequences of failing to provide this information.

Your personal data is collected for the following purposes :

Purpose of processing	Description	Legal basis	Retention periods
Contact us	Matching an Affiliate with a propertips Partner; Management, follow-up, validation and publication of the referral; Affiliate team management	Legitimate interest Legitimate interest Legitimate interest	The duration of the relationship between the Affiliate and the Partner The duration of the relationship between the Affiliate and the Partner The duration of the relationship between the Affiliate and the Partner
Account creation / referral creation	Application registration Registration by an Affiliate of another Affiliate Sending notifications User tracking	Consent Legitimate interest Legitimate interest	The duration of the use of a User's account The duration of the Affiliate's use of its account 13 months from notification Duration of account use
Partner relationship management	Partner tracking	Contract/Legitimate interest	10 years from the end of the relationship with Partners
Management of affiliate banking information	Affiliate information for commission tracking purposes propertips records affiliate's bank details for tracking purposes Payment of commissions and membership fees	Contract Consent Legal obligation	Retention for the duration of the Affiliation and 10 years after the end of the Affiliation (if commissions are paid) Retention for the duration of the Affiliation and 10 years after the end of the Affiliation (if commissions are paid) 10 years from payment of commission
Administrative and financial follow-up	propertips complies with its reporting obligations	Legal obligation	Legal and regulatory retention periods
Communication	Newsletter dispatch Advertising and targeted marketing	Consent	Newsletter subscription period
Rights management - personal data protection	Exercise of personal rights (propertips contact) Litigation	Legal obligation	13 months from date of collection (to measure site traffic) / 3 years from last commercial contact 5 years (from request) Duration of litigation (and exhaustion of appeal periods)

5.DATA CONSERVATION DURATION

• propertips undertakes to keep the Personal Data of Users of the Site and the Application only for as long as is necessary to carry out the activities for which they were collected, in particular to meet its legal obligations or as part of its contractual relations with Users.

• propertips implements secure archiving procedures in order to prevent any infringement or violation of Personal Data. This Personal Data is securely destroyed at the end of the established retention periods.

• The data collected by propertips is kept for the time necessary to carry out the processing and for the purposes defined above

• Your personal data is kept for as long as your account is active and may in some cases be kept longer, in particular to enable propertips to fulfil its legal or contractual obligations.

• You can contact propertips for further information on how long we keep your data.

• Once these periods have elapsed, propertips undertakes to delete this data in a secure manner or to store it in an intermediate database before deleting it permanently in the same way.

6.SUB-CONTRACTING:

• In the course of our business, propertips may need to use subcontractors for whom it undertakes to maintain an adequate level of protection. However, it is possible that, in the context of the services offered, certain subcontractors may be located outside the territory of the European Union. In this case, the transfers are regulated and offer all the appropriate guarantees, in particular by means of the European Commission's standard contractual clauses, which ensure an adequate level of protection and the protection of your fundamental rights.

• In the event of subcontracting, propertips undertakes to formalise contracts with appropriate guarantees in accordance with the law applicable to the protection of personal data.

7.RECIPIENTS OF PERSONAL DATA :

• Your personal data will not be communicated or transmitted to third parties, except in the case of specific and limited exceptions.

• propertips also reserves the right to transmit your personal data within the framework authorised by the law in force and in particular :

• to satisfy the requirements of a law or regulation in force, a summons, a requisition, an administrative request or legal proceedings when imposed or authorised by the law in force;

• to protect and/or defend the general terms and conditions or other applicable regulations, in particular to investigate possible breaches;

• to preserve the security of the Site or the Application or of third parties or to protect rights or titles of ownership; and/or

• to detect, prevent or otherwise deal with technical, fraud or security problems.

Data accessible to third parties:

• Your personal data may be transmitted by propertips to the following third parties for the purposes described above:

• Our authorised personnel and our sub-contractors will have access to the personal data collected in the course of using our services;

• Our Partners will have access to your personal data in the context of matchmaking or recommendations made on the Application.

8.INTERNATIONAL TRANSFERS OF PERSONAL DATA :

Your Personal Data may be processed outside the European Union, including via remote access. We undertake not to carry out any transfer of Personal Data outside the European Union without implementing appropriate safeguards in accordance with applicable regulations. In this case, transfers are governed by and present all appropriate guarantees, in particular by means of the European Commission's standard contractual clauses, which ensure an adequate level of protection and the protection of your fundamental rights.

9.SECURITY OF PERSONAL DATA :

• propertips ensures the confidentiality, integrity and security of the personal data entrusted to us by implementing appropriate organizational and technical measures, as well as enhanced IT protection. These security measures are regularly audited.

• In particular, propertips takes all necessary precautions to prevent access to Personal Data by unauthorized third parties (physical protection of premises, security of computer workstations, password policy, employee empowerment, etc.). It also ensures that all access to the Personal Data of Site and Application users by all authorized persons is subject to appropriate confidentiality measures.

• propertips has also put in place procedures to prevent and deal with any breach of personal data.

• propertips nevertheless reminds Users that it cannot guarantee the security of all data and personal data transmissions over the Internet, of all wireless transmissions and of all electronic information storage systems.

10.RIGHTS OF THE PERSONS CONCERNED

• You have a right of access to your personal data, a right of rectification, a right of opposition, as well as a right to erasure, in accordance with applicable regulations.

• Your right to deletion applies subject to any necessity that propertips may have to retain your personal data, in particular with regard to our legal obligations.

• If you exercise your right to object, we will cease processing your personal data, unless there are compelling legitimate grounds for doing so, or for the establishment, exercise or defense of legal claims, in accordance with applicable law.

• You may also, subject to the conditions of the applicable regulations, request a restriction on the processing of your personal data.

• Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.

• You also have a right to the portability of some of your personal data, enabling you to request a computer copy in a readable and usable form of your personal data processed by us as part of your contractual relationship with us for the supply of products or services to which you have subscribed, This excludes personal data that we may have generated for our own purposes or in order to meet our legal obligations, in particular accounting, social or fiscal obligations, as well as information relating to the history of reservations made, amounts paid or payable, as well as all information that we may have generated in the context of the legitimate interests that we pursue.

• Where appropriate, we will inform you of the reasons why the rights you are exercising cannot be satisfied in whole or in part.

• Requests to exercise these rights should be sent to propertips at the following e-mail address: privacy@propertips.com

• We will have a period of one month to respond after receipt of the request, which may be extended by two months in the event of complexity or a large number of requests.

  You can also consult the CNIL website for further information, or lodge a complaint.

II. MORE ABOUT THE PROCESSING OF YOUR PERSONAL DATA

1. You are an affiliate or a sponsor

As an Affiliate, or as a Sponsor on the Application, you can :

• Register on the Site or Application;

• Share your QR Code with your login and password;

• Manage level 1 of your Affiliate network as a Sponsor;  

• Recommend a Partner;

• Rate a Partner after recommendation;

• Suggest a professional;

• Consult the list of Partners;

• Receive or not marketing campaigns;

• Contact a Partner in trades with benefits;

• Make a recommendation of a Partner in professions with remuneration;

• Add contacts or import contacts into the hot list;

• Using the hot list;

• Use the to-do list tool;

• Offer a contact an account;

• Set up a team (with different levels and up to 6 levels of Affiliates);

• Use simulators;

• Add an Afterwork by propertips , participate or contact the organizer of an Afterwork by propertips;

• Contact a propertips trainer;

• Withdraw your kitty;

• Follow our recommendations;

• Delete or deactivate your account.

• What personal data of Affiliates and Sponsors does propertips collect and process?

• This includes the following data:

• Civil status and identification data: account ID, profile photo, surname, first name, email address, postal address, country, date of birth, gender, place of birth, nationality.

• Bank details

• Social security number;

• Data related to your contacts and exchanges with propertips ;

• Data related to your comments and opinions on professionals.

• Technical navigation and interaction data: connection data, traffic statistics: IP address, cookies, e.g. the pages you consult and the date and time of consultation (see Cookie Policy)

• Geolocation data: you can choose to communicate your geolocation coordinates via the geolocation function of the propertips Application, by clicking on the button provided for this purpose.

• If you have any questions regarding the processing of your personal data or the grounds for such processing, you may contact propertips by e-mail privacy@propertips.com or by post.

2. You are a Partner :

• As a Partner with benefits, you can also:

• Manage your Partner account;

• Access your account reporting (name, first name of Affiliates who have consulted your profile, date of consultation, information on the consultation channel, Application or Site);

• Receive notifications.

• As a Partner with remuneration, you can also:

• Manage your Partner account;

• Access your account reporting (name and surname of Affiliates who have consulted your profile in the event of a recommendation);

• Access information on other Partners (date of registration on propertips );

• Receive notices at the end of a Partnership;

• Rate Affiliates at the end of a matchmaking session.

• Participate in challenges (subject to participation conditions).

What personal data about Partners is collected and processed by propertips?

This includes the following data:

• Civil status and identification data: account ID, profile photo, surname, first name, email address, postal address, country, date of birth, gender, place of birth, nationality.

• Partner number;

• Bank details

• Social security number;

• Data related to your contacts and exchanges with propertips ;

• Data related to your comments and opinions on professionals.

• Data linked to your results in the organization of challenges;

• Technical navigation and interaction data: connection data, traffic statistics: IP address, cookies, e.g. the pages you consult and the date and time of consultation (see Cookie Policy)

• Geolocation data: you can choose to communicate your geolocation coordinates via the geolocation functionality of the propertips application, by clicking on the button provided for this purpose;

• Partner account data;

• Partner account reporting data (first and last names of Affiliates who have consulted your account, Affiliate data);

• Business data (business number, insurance certificate);

• Current recommendations.

• If you have any questions regarding the processing of your personal data or the grounds for such processing, you may contact propertips by e-mail privacy@propertips.com or by post.

III. CHANGES TO THIS PRIVACY POLICY

• propertips reserves the right to modify or supplement this Privacy Policy at any time without notice.

• Users of the Site and the Application are advised that their continued use of the Site or the Application after publication of a modified privacy policy will be deemed acceptance of said modified policy. Consequently, propertips invites Users to consult the privacy policy on a regular basis.

• The modified privacy policy will come into effect on the date of its publication or on any later date specified in the modified policy. It applies to all use from that date.