GDPR and Confidentiality
We collect information when you register for our Website or applications, when you log into your account, make a purchase, enter a competition and/or when you log out. The information we collect includes your last name, first name, Company name, email address, and phone number.
Additionally, we automatically receive and record information from
your computer and browser, including your IP address, software and hardware, and the page you are requesting.
1. How we use the information
Any information we collect from you may be used to:
- Customize your experience and meet your individual needs
- Provide personalized advertising content
- Improve our Website
- Improve customer service and better cater for your needs
- Contact you by email
- Manage a competition, promotion, or survey
2. E-commerce privacy
We are the sole owners of the information collected on this Website. Your personal information shall not be sold, exchanged, transferred, or provided to any other Company outside the Marketing Immobilier group for any reason, without your consent, other than as required to fulfill a request and/or transaction, such as shipping an order.
3. Disclosure to third parties
We do not sell, exchange, or transfer your personally identifiable information to third parties. This does not include trusted third parties who help us to operate our Website or conduct our business, provided these parties agree to keep such information confidential.
We believe sharing information is necessary to investigate, prevent, or take measures against illegal activity, suspected fraud, situations involving potential threats to the physical safety of any person, infringements of our terms of use, or when we are so required by law.
However, information that is not private may be provided to other parties for marketing, advertising, or other purposes.
4. Information Protection
We employ a range of security measures to safeguard your personal information, and your customers’, when using the application. We use state-of-the-art encryption to protect sensitive information transmitted online. We also protect your information offline. Only employees who need to perform a specific task (such as billing or customer service) have access to personally identifiable information. The computers and servers used to store personally identifiable information are kept in a secure environment.
Do we use cookies?
Yes. Our cookies improve access to our Website and identify regular visitors. Our cookies also enhance the user experience, by tracking and targeting their interests. However, in no way is this use of cookies linked to any personally identifiable information on our Website.
5. Unsubscribing
We use the email address you provide to send you information and updates regarding your order, periodic Company news, information on related products, etc. If you would like to unsubscribe from receiving emails at any time, detailed instructions for unsubscribing are provided at the bottom of each email.
6. Consent
By using our Website and our STARTLOC application, you consent to our privacy policy.
7. GDPR
The Company undertakes to comply with current regulations on personal data processing and, in particular, Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (GDPR).
The processing of the personal data used by the STARTLOC service is secure, relevant, reasonable, and strictly necessary to fulfill our purposes, in accordance with the aforementioned regulation. These items are set out in a summary table below.
As such, the Company acts:
- as data controller when processing the personal data of Subscribers to the STARTLOC service;
- as data processor when processing the data of customers of Subscribers to the STARTLOC service.
1. Our Obligations as Data Controller.
1.1 Data Processing (Durations and Purposes).
The personal data entered by Subscribers to the STARTLOC service is collected by the Company for the purposes and durations set out in the table below:
Purpose of the Processing | Data concerned | Legal basis for the Processing | Data storage period |
Managing customer accounts | First name, last name, email address, phone number | Consent received by the customer from the data subject, | 5 years after the move-out inventory |
Managing user accounts | First name, last name, email address, phone number | Consent received by the customer from the data subject, | 5 years after cancelation of subscription/5 years after date of last activity |
1.2. Right to DataPortability and Erasure.
The Subscriber has the right to the portability and erasure of their personal data, which they may exercise free of charge by sending their request for portability or erasure to the following email address: kevin.colombe@groupe-realty.fr
The Company shall respond to the Subscriber’s request by email, within a reasonable period of 2 months, which may be extended to 3 months if there are particularly complex or a large number of requests.
2. Our obligations as data processor.
Purpose of the Processing | Data concerned | Legal basis for the Processing | Data storage period |
Creating and managing contacts | First name, last name, email address, phone number | Consent received by the customer from the data subject, | 5 years after the move-out inventory |
Creating and managing properties | Type of property, address, description, and list of fixtures and fittings | Consent received by the customer from the data subject, | 5 years after the move-out inventory |
Creating and managing inventories | General condition of fixtures and fittings, photos, address, name of parties, electronic signatures | Consent received by the customer from the data subject, | 5 years after the move-out inventory |
The Parties acknowledge that the Company acts solely as data processor when hosting the data of the Subscriber’s customers, the obligations of which are set out in article 28 of the GDPR. The Subscriber therefore remains solely responsible for determining the purposes and means for processing personal data, and acts solely as data controller within the meaning of French Law 78-17 of January 6, 1978, as amended, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
As such, the Subscriber is solely responsible for complying with the conditions for obtaining consent from customers, and cannot transfer their obligations and responsibility to the data processor under any circumstances.
As data processor, the Company reminds the Subscriber of their obligations as data controller under the aforementioned legal and regulatory provisions, namely ensuring personal data is collected lawfully and fairly.
Principals, the Company, and tenants must be able to object to the collection of their data or modify data collected by the data controller for the purpose of the rental, or at any time before, during, or after the term of the rental mandate, management mandate, or simply for the entire term of the rental.
The Subscriber declares that they are fully aware that the STARTLOC application is not able to determine whether or not a tenancy has been canceled if the move-out inventory is not carried out through the application. In such circumstances, the Subscriber undertakes to inform the Company of the cancelation of the tenancy by any lasting means, particularly with a view to enabling the latter to calculate the period for which data related to the Subscriber’s customer is retained after the contractual period.
The data controller must inform and, where necessary, obtain the explicit consent of the data subjects and:
- Ensure compliance with the rights of access, rectification, erasure, restriction, portability, and objection to the processing of data, and allow data subjects to set out future instructions for their data after their death;
- Define a suitable and relevant retention period of no more than 5 years after the last commercial relationship for all personal data, including last name, first name, phone number, email address, property address, inventory, and photographs of the property. This period is justified by the need for access to data with a view to managing potential disputes.
The Company and the Subscriber jointly guarantee the protection, confidentiality, integrity, and security of any personal data collected. In the event of a physical or technical incident, the Company shall ensure the technical ability to restore the availability of and access to personal data in a timely manner, and implement processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. If the Subscriber requires any further information regarding GDPR compliance, our DPO can be contacted at the following address: kevin.colombe@groupe-realty.fr
