PRIVACY POLICY
APPLICATION AND WEBSITE propertips
March 23, 2023

ATTENTION: Propertips regularly updates its documentation on personal data protection.

This policy is subject to change, and Propertips invites Users of the Website and Application to review it regularly.

• Propertips (the trade name of NosRezo) is committed to protecting the personal data of its Users and ensures a high level of protection of this data, in compliance with applicable laws and regulations.

• It protects this data in compliance with:
  - Regulation (EU) No 2016/679 of April 27, 2016 (GDPR),
  - The French Data Protection Act No. 78-17 of January 6, 1978, as amended by Law No. 2018-493 of June 20, 2018, and Ordinance No. 2018-1125 of December 12, 2018, relating to the protection of personal data and amending Law No. 78-17 of January 6, 1978, on information technology, files, and liberties, as well as various provisions concerning the protection of personal data.

• This privacy policy informs Users of the Website and Application about how Propertips collects and processes their personal data. This policy also details Propertips' practices regarding the collection and processing of Users' Personal Data, including the types of information collected about Users of the Website and Application and how Propertips handles them.

• The Website and Application are owned by NosRezo (trade name Propertips), a simplified joint-stock company registered with the RCS of Melun, with its headquarters located at IMMEUBLE CARRÉ HAUSSMANN III, Allée de la Ferme de Varâtre, 77127 LIEUSAINT. Propertips is the designer and publisher of the Website and Application.

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

• Each User of the Website and Application can obtain information at any time regarding the protection of their personal data by contacting Propertips:

• By mail, at the address: IMMEUBLE CARRÉ HAUSSMANN III, Allée de la Ferme de Varâtre, 77127 LIEUSAINT

• By email, at: privacy@propertips.com

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

1- DEFINITIONS

• The following words and expressions are used in this document with the following meanings:

• The terms 'personal data', 'processing', 'data controller', 'processor', 'recipient(s)', 'consent', and 'file' have the same meaning as stated in Article 4 of the GDPR.

• ‘The Application’ refers to the Propertips Application.

• ‘The User’ refers to any person using the Website and Application, including:

• - ‘The Affiliate’ refers to any legal adult registered on the Website and Application, holding an account and facilitating connections between a seller or buyer contact and a partner.

• - ‘The Partner’ refers to any Affiliate holding an account and acting as a professional, who may receive recommendations or be contacted by an Affiliate. The Partner may be a Partner with benefits or a Partner with remuneration.

• - ‘The Partner with benefits’ refers to any Partner for whom the Website and Application allow the User to leave a review or get in touch.

• - ‘The Partner with remuneration’ refers to any Partner with whom an Affiliate can establish a connection, potentially entitling them to remuneration.

• - ‘The Sponsor’ refers to any person registered on the Website and Application who holds an account and has provided at least one Affiliate with an account.

• ‘The Contact’ refers to any person entered by a User on the Website and Application.

• ‘The Hot List’ refers to the list of contacts entered by a User in the Propertips Application.

• ‘The Connection’ refers to the possibility for a User to connect with a Partner with remuneration, to organize a connection between another Affiliate and a Partner with remuneration, or to organize a connection between a Contact and a Partner with remuneration.

• ‘The Website’ refers to the website www.propertips.com.

2- WHO IS THE DATA CONTROLLER?

The data controller responsible for processing personal data via this Website and the mobile Application is the company NosRezo (trade name Propertips), a simplified joint-stock company registered with the Melun Trade and Companies Register under number R.C.S 800118788, with its registered office at: IMMEUBLE CARRÉ HAUSSMANN III, Allée de la Ferme de Varâtre 77127 LEUSAINT, represented by its current legal representative.

3- WHAT PERSONAL DATA IS PROCESSED?

Your personal data is processed during the registration process on the Website and Application, as well as during its use.

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

• Personal identification data: Account ID, profile picture, surname, first name, email address, postal address, country, date of birth, gender, place of birth, nationality.

• Banking data (IBAN) and social security number.

• Social Security Number (NIR).

• Data related to your interactions and communications with Propertips.

• Data related to your comments and reviews on professionals.

• Technical navigation and interaction data: traffic statistics, such as IP address, cookies, pages visited, and the date and time of visits (refer to the Cookie Policy).

• Geolocation data: You can choose to share your geolocation data via the geolocation feature on the Propertips Website and Application by clicking the designated button.

• For any questions regarding the processing of your personal data or the legitimacy of the processing, you can contact Propertips via email at privacy@propertips.com or by postal mail.

4- PURPOSES, LEGAL BASIS, AND RETENTION PERIOD: WHY DO WE COLLECT YOUR PERSONAL DATA?

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

When you provide your personal data, we indicate whether the information is mandatory or optional with an asterisk, as well as the consequences of failing to provide it.

Your personal data is collected for the following purposes:

Processing Purposes	Description	Legal Basis	Retention Period
Connection Facilitation	Facilitating the connection between an Affiliate and a Propertips Partner. Managing, tracking, validating, and publishing recommendations and connections. Managing the Affiliate network.	Legitimate Interest Legitimate Interest Legitimate Interest	For the duration of the relationship between the Affiliate and the Partner. For the duration of the relationship between the Affiliate and the Partner. For the duration of the relationship between the Affiliate and the Partner.
Account Creation / Recommendation Creation	Registering on the Application. Registering an Affiliate through another Affiliate. Sending notifications.	Consent Legitimate Interest Legitimate Interest	For the duration of the User’s account usage. For the duration of the Affiliate’s account usage. 13 months from the notification date.
User Relationship Management	Tracking Users.	Contract / Legitimate Interest	For the duration of account usage.
Partner Relationship Management	Tracking Partners.	Contract / Legitimate Interest	10 years from the end of the relationship with Partners.
Affiliate Banking Information Management	Providing Affiliate banking details for commission tracking. Recording banking details by Propertips for follow-up. Processing commission payments.	Contract Consent Legal Obligation	Retention throughout the Affiliate relationship and 10 years after its termination (if commissions were paid). Retention throughout the Affiliate relationship and 10 years after its termination (if commissions were paid). 10 years from the commission payment date.
Administrative and Financial Tracking	Ensuring Propertips meets its tax obligations (pre-tax declarations).	Legal Obligation	Legal and regulatory retention periods.

5 - DATA RETENTION PERIOD

• Propertips is committed to retaining the Personal Data of Users of the Website and the Application only for the time necessary to carry out the activities for which they were collected, particularly to fulfill its legal obligations or within the framework of its contractual relationships with Users.

• Propertips has implemented secure archiving methods to prevent any compromise or violation of Personal Data. These Personal Data will be securely destroyed at the end of the established retention periods.

• The data collected by Propertips is retained for as long as necessary to carry out processing and for the purposes defined above.

• Your personal data is retained for the duration of your account activity and may, in some cases, be kept beyond that period, particularly to allow Propertips to meet its legal or contractual obligations.

• You may contact Propertips to obtain further details about the retention period of your data.

• Once these periods have expired, Propertips undertakes to delete the data securely or to retain it in an intermediate database before permanently deleting it in the same secure manner.

6 - SUBCONTRACTING

• As part of our activities, Propertips may use subcontractors, for which it undertakes to maintain an adequate level of protection. However, some subcontractors may be located outside the European Union. In such cases, the transfers are regulated and provide all appropriate guarantees, particularly through the European Commission’s standard contractual clauses, ensuring an adequate level of protection and the safeguarding of your fundamental rights.

• In the event of subcontracting, Propertips undertakes to formalize contracts with appropriate guarantees in accordance with applicable personal data protection laws.

7 - RECIPIENTS OF PERSONAL DATA

• Your personal data is not disclosed or transmitted to third parties, except in specific and strictly regulated cases.

• Propertips also reserves the right to transmit your personal data within the framework permitted by applicable law, particularly in the following cases:

• To comply with legal or regulatory requirements, a subpoena, a requisition, an administrative request, or a legal proceeding when imposed or authorized by applicable law;

• To protect and/or defend the general terms and conditions or other applicable regulations, particularly to investigate possible violations;

• To preserve the security of the Website or the Application or third parties or to protect rights or property titles; and/or

• To detect, prevent, or otherwise address technical issues, fraud, or security concerns.

Data Accessible to Third Parties

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

• Our authorized personnel and subcontractors will have access to the personal data collected in the context of using our services.

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

8 - INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your personal data may be processed outside the European Union, including through remote access. We undertake not to transfer Personal Data outside the European Union without implementing appropriate safeguards in accordance with applicable regulations. In such cases, transfers are governed and provide all necessary guarantees, particularly through the standard contractual clauses of the European Commission, ensuring an adequate level of protection and safeguarding your fundamental rights.

9 - SECURITY OF PERSONAL DATA

• Propertips ensures the confidentiality, integrity, and security of personal data entrusted to us by implementing appropriate organizational and technical measures, including enhanced IT security. These security measures are subject to regular audits.

• Propertips takes all necessary precautions to prevent unauthorized third-party access to Personal Data.

• Propertips has also established procedures to prevent and address any personal data breaches.

• Propertips, however, reminds Users that it cannot guarantee the security of all data transmissions and personal data on the Internet, all wireless transmissions, and all electronic storage systems.

10 - RIGHTS OF DATA SUBJECTS

• You have the right to access your personal data, the right to rectification, the right to object, and the right to erasure, in accordance with applicable regulations.

• Your right to erasure applies subject to Propertips’ legitimate needs to retain personal data, particularly in view of our legal obligations.

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

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

• When 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 the right to portability of certain personal data, allowing you to request a machine-readable copy of your personal data processed by us as part of your contractual relationship with us for the provision of products or services to which you have subscribed. This excludes personal data that we may have generated for our own purposes or to comply with our legal obligations, such as accounting, social, or tax requirements, as well as information related to past bookings, payments made or due, and all information generated as part of our legitimate interests.

• If applicable, we will inform you of the reasons why the rights you exercise cannot be fully or partially fulfilled.

• Requests to exercise these rights must be sent to Propertips at the email address: privacy@propertips.com.

• We will respond within one month after receiving the request, which may be extended by two months in cases of complexity or a high number of requests.

  You may also visit the CNIL website for more information or to file a complaint.

II. LEARN MORE ABOUT THE PROCESSING OF YOUR PERSONAL DATA

1- You are an Affiliate or a Sponsor.

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

• Register on the Site or the Application

• Share your QR Code with your identifiers

• Manage level 1 of your Affiliate network as a Sponsor  

• Recommend a Partner

• Rate a Partner after recommendation

• Propose a professional

• View the list of Partners

• Receive or opt-out of marketing campaigns

• Contact a Partner in professions with benefits

• Make a recommendation for a Partner in remunerated professions

• Add or import contacts into the hot list

• Use the hot list

• Use the to-do list tool

• Offer an account to a contact

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

• Use the simulators

• Add an Afterwork by Propertips, participate in it, or contact the organizer of an Afterwork by Propertips

• Contact a Propertips trainer

• Withdraw your earnings

• Track the recommendations made

• Delete or deactivate your account

• What personal data of Affiliates and Sponsors is collected and processed by Propertips?

• This includes the following data:

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

• Banking data (RIB) and social security number.

• Social Security Number (NIR).

• Data related to your contacts and exchanges with Propertips;

• Data related to your comments and reviews on professionals.

• Technical data related to browsing and interaction: connection data, site traffic statistics: IP address, cookies, such as the pages you view and the date and time of viewing (see the Cookie Policy).

• Geolocation data: you can choose to share your geolocation details via the Propertips Application’s geolocation feature by clicking the dedicated button.

• For any questions regarding the processing of your personal data or the legitimacy of the processing, you can contact Propertips by email at privacy@propertips.com or by postal mail.

2- You are a Partner:

• As a Partner with benefits, you can also:

• Manage your Partner account;

• Access your account reports (first name, last name of Affiliates who viewed your profile, consultation date, information on the consultation channel, Application or Site);

• Receive reviews.

• As a Partner with remuneration, you can also:

• Manage your Partner account;

• Access your account reports (first name, last name of Affiliates who viewed your profile in case of a recommendation);

• Access information about other Partners (registration date on Propertips);

• Receive reviews at the end of a connection;

• Rate Affiliates at the end of a connection.

• Participate in challenges (subject to participation conditions).

What personal data of Partners is collected and processed by Propertips?

This includes the following data:

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

• Partner number.

• Banking data (RIB) and social security number.

• Social Security Number (NIR).

• Data related to your contacts and exchanges with Propertips;

• Data related to your comments and reviews on professionals.

• Data related to your results in challenge events.

• Technical data related to browsing and interaction: connection data, site traffic statistics: IP address, cookies, such as the pages you view and the date and time of viewing (see the Cookie Policy).

• Geolocation data: you can choose to share your geolocation details via the Propertips Application’s geolocation feature by clicking the dedicated button.

• Partner account data.

• Partner account reporting data (name and first name of Affiliates who viewed the account, Affiliate data).

• Business-related data (KBIS, SIRET number, insurance certificate).

• Ongoing recommendations.

• For any questions regarding the processing of your personal data or the legitimacy of the processing, you can contact Propertips by email at privacy@propertips.com or by postal mail.

III. CHANGES TO THIS PRIVACY POLICY

• Propertips reserves the right to modify or supplement this privacy policy at any time and without prior notice.

• Each User of the Site and the Application is informed that by continuing to use the Site or the Application after a modified privacy policy has been published, they will be deemed to have accepted the said modified policy. Therefore, Propertips encourages Users to regularly review the privacy policy.

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