Privacy policy
5. PERSONAL DATA
5.1 DEFINITIONS
For the purposes of these GTCU, capitalized terms shall 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 individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “General Data Protection Regulation”) that are provided by the User to the Company or that are collected by the Company in connection with the use of the Website and/or the Mobile Application. “WEBSITE”: refers to the interactive electronic service published and operated by the Company ComptAppart, accessible in particular at the address www.qlower.com, from which it allows access to its Services. “MOBILE APPLICATION”: means the interactive electronic service published and operated by ComptAppart, accessible from all types of personal terminals and downloadable from Google Play© and Apple Store© in particular, from which it allows access to its Services. “SERVER”: means 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”: designate 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. “SERVICES”: refers to the services provided by the Company via its Websites and Mobile Applications, whether via interactive screens, notifications, alerts or electronic messages. “USER”: refers to any individual or representative of a legal entity who accesses the Website or the Mobile Applications for strictly private use.
5.2. CONTACT DETAILS OF THE DPO
The Data Protection Officer is Mr Christophe Duprat. The User may contact the Data Protection Officer by sending a letter to the address indicated in article 1 above, or by e-mail to the admin address [ at ] qlower.com.
5.3. NATURE OF THE 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 his terminal and saved in the Servers: – first and last name, – full postal address, – e-mail address, – telephone number, – consent to receive commercial offers, – date of creation of his account, – address of his property(ies) offered for rent, – details of the properties, – tax situation of the User, – details of transactions from bank accounts linked via the Mobile Application or the Website and indicators calculated from this data, – information related to his navigation and his interactions with the Services offered via his Mobile Application and Website (history, forms, cookies and others). The Company collects the information provided by Users, in particular: – via contact forms on the Mobile Application and/or Website, – via extraction of data from documents shared for this purpose, – via data from browsing on the Website and the Mobile Applications (consultation of articles, searches, etc.). Data collection may be either mandatory or optional. Mandatory data is necessary for the provision of the Service provided by the Company. Optional data allows the refinement of the Service provided by the Company. Failure to provide 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 GCU, and in application of article 6.1 of the General Regulations on Data Protection, the User is informed that the various processing of his Data mentioned below are necessary for the execution and performance of the Services offered by the Company and whose supply is governed by these GCU constituting the contract subscribed to by the User. This processing is also necessary for the legitimate interests pursued by the Company to improve its Services and to understand the expectations of Users, in particular to protect the User’s rights and Data. Specifically, 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 the Mobile Applications – the establishment of indicators necessary for the detailed monitoring of traffic. Exchanges of information, notifications, alerts, e-mails and paper, or the 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 issued by Users to third party partners, subject to the express agreement of 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 Company’s authorised staff 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 for measuring the number of visits to the Website in accordance with the provisions of Article 5.4, – to the administrative or judicial authorities authorised by French law, – to the Company’s commercial partners when Users have expressly agreed to receive promotional offers from them.
5.6. DURATION OF RETENTION OF THE USER’S PERSONAL DATA AND RIGHT OF OPPOSITION
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 : – to oppose, at any time for reasons relating to his personal situation, the processing of his Data within the framework of the Services provided by the Company, – to oppose, at any time, the processing of Data for canvassing purposes, – to oppose the communication of Data to third parties, – to access all of his Data processed within the framework of the Services provided by the Company, – to rectify, update and delete his Data processed within the framework of the Services provided by the Company, – to request access only to the personal data he has provided to the Company when this is technically possible and subject to proof of identity. In the event that the User exercises his right to object, the Company will cease processing his Data, except in the event of legitimate and compelling reason(s) for the processing, or to ensure the establishment, exercise or defence of his rights in court, in accordance with the General Regulations on Data Protection. Where appropriate, the Company will inform the User of the reasons why the rights he or she is exercising cannot be satisfied in whole or in part. To exercise his rights, the User must send a letter to the Company at the address indicated in article 1 or contact the Company by sending an email to the admin [arobase] qlower.com address, taking care to attach proof of identity to his request (mentioning his surname, first names, email address) in accordance with Chapter III of the General Regulations on Data Protection.
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 the Users of its Website and Services, collected and processed by it (in particular firewalls, physical access controls to data centres, clearances, etc.).
5.8. SETTLEMENT 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 address his or her complaint to the Company by contacting it by post at the address indicated in article 1 or by sending an email to the admin [arobase] qlower.com address. The Company will endeavour to find a satisfactory solution for the User, to ensure compliance with the 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 Regulations on Data Protection, to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés or the supervisory authority of the European Union Member State in which the User is normally resident.
6. AUDIENCE MEASUREMENTS AND INFORMATION RELATING TO COOKIES
The Company uses cookies on its website and navigation markers (Logs) on its Mobile Applications. Cookies are information files installed on your computer by the websites you visit. Cookies allow the storage of navigation information, such as navigation preferences or user profile, location, type of hardware used. When browsing the Website and/or the Mobile Applications, the Company’s Services may send to third party sites a number of elements that are automatically recognised, such as the connection timestamp, IP address, domain name, browsing software and operating system used (if the browser provides this information), the address of the page previously visited (if the browser provides it), the object requested and the execution status of the request. Any User may choose to refuse cookies by using the “tool” tab of their browser and then using the tab allowing you to manage privacy or browsing preferences. To find out more about managing cookies from your browser, we invite Users to visit the CNIL website.
6.1. LIST OF COOKIES ON THE WEBSITE
Statistical Cookies Statistical cookies allow the Company to understand how Users interact with the Website by collecting and communicating information anonymously (IP addresses are anonymised before the information is collected). Google Analytics cookies: in the form _utm, _dc_gtm or_ga. If the User does not wish to communicate their personal data related to their browsing on sites equipped with the Google Analytics tracking code, Users can block these cookies by installing the add-on module of their browser allowing the deactivation of Google Analytics. This tool is available for download at: https://tools.google.com/dlpage/gaoptout Marketing Cookies Marketing cookies are used to track visitors through the Site and to share this information with social media partners and online advertising. These cookies are collected by Google among other organisations.
