Policy of confidentiality

5. PERSONAL DATA

5.1 DEFINITIONS

For the purposes of these Terms of Use, terms in capital letters have the following meaning: “DATA”: refers to personal data as defined in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “General Data Protection Regulation”) which are provided by the Users at the Company or collected by the Company when using the Website and/or the Mobile Application. “WEBSITE”: refers to the interactive electronic service published and operated by the Company ComptApart, accessible in particular at the address www.qlower.com, from which it allows access to its Services. “MOBILE APPLICATION”: refers to the interactive electronic service published and operated by the Company ComptApart, accessible from any type of personal terminal and downloadable on the Google Play© and Apple Store© Stores. in particular, from which it allows access to its Services. “SERVER”: refers to a computer device intended to host an application service and having a large amount of disk space where files are stored. “WEBSITE SERVER” and “MOBILE APPLICATION SERVER”: refer to the servers hosting the Website and the mobile application respectively on which the Services made available to the User by the Company are installed and provided, respectively, on which the Services made available to the User by the Company are installed and provided. “SERVICES”: refer to the services provided by the Company via its Sites, respectively. Internet and its Mobile Applications, whether via interactive screens, notifications, alerts, electronic messages. “USER”: refers to any natural person or representative of a legal entity who accesses the Website or the Mobile Applications for strictly private use.

5.2. DPO CONTACT DETAILS

The Data Protection Officer is Mr. Christophe Duprat. The User has the option of contacting the Data Protection Officer by simple mail to the address indicated in article 1 above, or by email to the address admin [at] qlower.com.

5.3. NATURE OF PERSONAL DATA COLLECTED BY THE COMPANY

The following personal data, necessary for the production of the proposed service, may be collected from the User or from his terminal and saved in the Servers: — title, — name and surname, — full postal address, — electronic mail address (email), — email address, — email address, — email address, — email address, — telephone number, — telephone number, — telephone number, — consent to receive commercial offers, — consent to receive commercial offers — consent to receive commercial offers — date of creation of his account, — address of his property (s) offered for rent, — details of the properties — fiscal situation of the User — details of transactions emanating from bank accounts linked via the Mobile Application or the website and indicators calculated from this data, — information related to its navigation and its interactions with the Services offered via its Mobile Application and Website (history, forms, cookies and others). The Company collects information provided by Users in particular: — via contact forms on the Mobile Application and/or Website, — via extraction of data from shared documents for this purpose — via data resulting from browsing the Website and Mobile Applications (consultation of articles, searches, etc.). Data collection can be either mandatory or optional. Mandatory data is necessary for the provision of the Service delivered by the Company. Optional data makes it possible to refine the Service provided by the Company. A lack of certain answers will limit access to some of the Services offered by the Company.

5.4 PURPOSE OF THE TREATMENTS

As part of the acceptance of the CGU, and in application of article 6.1 of the General Data Protection Regulation, the User is informed that the various treatments of his Data mentioned below are necessary for the execution and realization of the Services offered by the Company and whose provision is governed by these CGU constituting the contract subscribed by the User. These treatments are also necessary for the legitimate interests pursued by the Company to improve its Services and to understand the expectations of Users, in particular allowing the protection of the User's rights and Data. Precisely, the User Data processed by the Company is used for the following purposes: — subscription to the Services — access to the Services via the Website and/or Mobile Applications — the establishment of indicators necessary for the detailed monitoring of traffic. Exchanges of information, notifications, alerts, e-mails and papers, or knowledge of Users and prospects, including the measurement of satisfaction, User Data processed by the Company may also be used for marketing purposes to respond to requests for information and prospecting sent by Users to third party partners, subject to the express agreement of the Users.

5.5. RECIPIENTS OF PERSONAL DATA

The Data may be communicated, in compliance with the laws applicable to the Company, for one or more of the purposes described in Article 5.4, to the persons listed below: — to the authorized and authorized personnel of the Company who may be required to process the Data, — to the Company's IT service providers responsible in particular for providing a service adapted to Users and measuring the use of the Website in accordance with the provisions of article 5.4, — to the administrative or judicial authorities authorized by law. French, — to the Company's commercial partners when Users have expressly agreed to receive promotional offers from them.

5.6. DURATION OF STORAGE OF THE USER'S PERSONAL DATA AND RIGHT TO OBJECT

The Data is kept by the Company, in compliance with the laws applicable to the Company, for 5 years from the last contact with the Company. In accordance with the laws applicable to the Company, the User has the right: — to oppose, at any time for reasons relating to his personal situation, to the processing of his Data as part of the Services provided by the Company, — to oppose, at any time to the processing of Data for prospecting purposes, — to oppose the communication of Data to third parties, — to access all of his Data processed as part of the Services provided by the Company, — to rectify, update and delete its Data processed within the framework of Services provided by the Company, — to request access only to the personal data that he has provided to the Company when technically possible and subject to justifying their identity. In the event of exercise of the right to object by the User, the Company will cease the processing of his Data, except in the case of legitimate and compelling reason (s) for the processing, or to ensure the establishment, exercise or defense of his rights in court, in accordance with the General Data Protection Regulation. Where appropriate, the Company will inform the User of the reasons why the rights he exercises cannot be satisfied in whole or in part. To exercise his rights, the User must send a simple letter to the Company at the address indicated in article 1 or to contact the Company by sending an email to the address admin [at] qlower.com, taking care to attach proof of identity to his request (mention his name, first name, email address) in accordance with Chapter III of the General Data Protection Regulation.

5.7. SECURITY AND ARCHIVING OF PERSONAL DATA

The Company collects and processes Data with the utmost confidentiality and security, and in compliance with the laws applicable to the Company. The Company undertakes to take all reasonable measures necessary to secure and protect the Data of Users of its Website and Services, collected and processed by it (in particular firewalls, physical access controls to data centers, authorizations, etc.).

5.8. RESOLUTION OF DISPUTES CONCERNING DATA PROCESSING

In the event of a dispute between the Company and the User concerning the processing of Data, the User may send a complaint to the Company by contacting it by simple mail at the address indicated in article 1 or by sending an email to the address admin [at] qlower.com. The Company will endeavour to find a satisfactory solution for the User, to ensure compliance with applicable regulations. In the absence of a response from the Company or if the dispute persists despite the Company's proposal, the User has the possibility, in accordance with the provisions of the General Data Protection Regulation, to file a complaint with the National Commission for Information Technology and Freedoms or the supervisory authority of the Member State of the European Union in which the User usually resides.

6. AUDIENCE MEASUREMENTS AND COOKIE INFORMATION

The Company uses cookies on its website and navigation markers (Logs) on its Mobile Applications. Cookies are information files that are placed on your computer by the websites you visit. Cookies make it possible to store browsing information, such as browsing preferences or user profiles, locations, and the type of equipment used. When browsing the Website and/or Mobile Applications, the Company's Services may send to third party sites a certain number of automatically recognized elements such as the timestamp of connections, the IP address, the domain name, the navigation software and the operating system used (if the browser communicates this information), the address of the page previously visited (if the browser provides it), the requested object and the operating system used (if the browser provides this information), the address of the page previously visited (if the browser provides it), the requested object and the execution status of the request. Any User can choose to refuse cookies by using the “tool” tab on their browser and then using the tab that allows you to manage privacy or browsing preferences. To find out more about the management of cookies from your browser, we invite Users to visit the CNIL site.

6.1. LIST OF COOKIES ON THE WEBSITE

What is a cookie or a tracker?

A cookie is a small text file that is downloaded to your computer when you visit certain websites and allows a website to recognize a user's computer. Cookies are used to help users navigate websites more efficiently and to use certain features, as well as to provide information to website owners.

Cookies are the device most used by websites but there are also other technologies that allow the analysis of a user's connections and which are generically referred to as “tracers” (local storage, local shared object, etc.).

What cookies and other trackers are used on the Site and/or the Application?

The list below lists the cookies and other tracers used by the Site, as well as their purpose and their retention period:

1. Hotjar : Quali audience measurement | Legal basis: User consent
2. Google Analytics 4 : Quanti audience measurement | Legal basis: User consent
3. Google Ads : Google conversion tracking and campaign optimization | Legal basis: User consent
4. Facebook Ads : The use of the Pixel for the optimization of advertising campaigns and conversion tracking | Legal basis: User consent
5. Intercom : Conversation window/Chat | Legal basis: User consent
6. Acceptio : Retention of choices relating to cookies | Legal basis: User consent

The retention period of data collected through cookies is variable but does not exceed 13 months. The data collected is not transferred to third parties or used for other purposes. Personal data from cookies may be kept for a maximum period of 25 months. At the end of this period, they will be deleted.

How do I block or delete cookies?

Your Internet browser may allow you to block or delete cookies placed by the Site. The Help function in your browser should tell you what to do. Otherwise, you can visit the website www.allaboutcookies.org which provides general information about cookies and how you can manage them on your computer.

Please note that if you uninstall a cookie or if you oppose the installation of cookies on your machine, you may not be able to benefit from some of the services of the Site, the Application and the Platform.