Personal data protection policy.

For the sake of transparency, KONECTAS has defined this General Data Protection Policy so that any person can know at any time the commitments made and the practices applied by KONECTAS to the personal data collected.

KONECTAS undertakes to process all data collected in accordance with the current regulations applicable to the processing of personal data and, in particular, the General Personal Data Protection Regulation (Law n°78-17 relating to data processing, files and freedoms of 6 January 1978 as amended and the General Personal Data Protection Regulation (GDPR) n° (EU) 2016/679 of 27 April 2016), both hereinafter referred to as the “Regulation”).

Definitions:

“Personal data” means information relating to an identified or identifiable natural person.

“Processing” means an operation or an organized set of operations performed on personal data (collection, structuring, storage, modification, communication, etc.).

The “data controller” is the person, natural or legal, who executes the purposes and means of processing. In this case, the data controller of the user’s data is KONECTAS.

The “data subjects” are the persons whose data is collected and processed.

“Personal Data Breach” means any incident that results in the unauthorized destruction, loss, alteration or unauthorized disclosure of Personal Data.

2. Processing of personal data:

The personal data of the persons concerned are collected and processed in a fair and lawful manner during their interactions with KONECTAS, in particular

– Directly from a KONECTAS real estate agent.

– During your browsing and/or entering information in the data collection forms and alerts that appear on o KONECTAS websites such as konectas.com, konectas.es, konectasrealty.com o KONECTAS mobile applications o KONECTAS partner websites o KONECTAS contracts and agreements o KONECTAS contracts and agreements.

– Through other possible sources such as online advertising sites, real estate sites, business providers or so-called “public” information.

– With respect to recruitment operations carried out by KONECTAS in particular: through job boards, social networks, franchisee websites or so-called “public” information.

3. Data Protection Officer (DPO):

KONECTAS has appointed a Data Protection Officer to ensure compliance with the Regulation and the rules described in this General Data Protection Policy.

He can be reached at the following address:

Postal Address: calle Sant Bartomeu, 31, 1ª, Sitges (Barcelona), Spain.

E-mail: info@konectas.com

4. Data collected:

In the course of its business, KONECTAS collects personal data in the following categories:

– Data allowing the performance of prospecting activities, loyalty, studies, surveys, improvement of the online experience on the KONECTAS websites, in particular:

Traffic and browsing history (cookies), including information relating to the traceability of actions, location data (IP address, for example), data relating to the terminal or even data relating to the tracking of actions with respect to emails that KONECTAS may send to the interested parties (openings, clicks, etc.). KONECTAS websites offer the interested parties the possibility to consult the cookie policy and to save their preferences;

o Data relating to the interactions of the interested parties with KONECTAS, in particular a contact request, a quotation, information or documentation, possibly the exchanged correspondence;

o Data that enable marketing or telemarketing campaigns, such as e-mail address or telephone number; o Data related to satisfaction surveys.

– Data allowing the exercise of real estate transactional activity (monitoring of mandates and sales), in particular:

Identification data such as title, surname and first name, KBis (if the company), contact details (telephone number, e-mail, postal address), date and place of birth, photocopy of identity card when necessary;

o data related to the sale, purchase or rental project;

o data relating to the characteristics of the property to be sold, bought or rented, such as number of rooms, surface area, location;

o data relating to the family, personal or professional situation of the persons affected by the project;

o data allowing a personalized and qualitative follow-up of the client, such as visit reports or in the case of a sales mandate, the data relating to the mandate and the legally required supporting documents (such as the DPE, title deed, copy of the real estate tax), as well as photos and/or videos of the property in question;

or in the case of a search mandate, the details of the mandate and proof of solvency of the buyer(s);

or in the case of a promise of sale, the supporting documents required by law (such as the land plan, invoices and various taxes);

o customer testimonials on the quality of service and satisfaction surveys.

– Data that enables the management of corporate contributors (also known as “prescribing partners”) or sponsors, in particular :

Identification data such as name and surname, information about the company or the association if applicable, contact details;

o data relating to information on sales or purchase projects provided by the interested parties as a result of their personal action and following the consent of their selling or purchasing contacts;

or data for administrative, accounting and financial follow-up;

or data allowing the animation of the community, such as e-mail or telephone number, contact preferences;

or data enabling the recruitment, integration, training and support of KONECTAS real estate agents, in particular;

o identification data such as title, surname and first name, contact details (telephone number, e-mail, postal address), date and place of birth;

o data and documents communicated in the framework of the applications, such as resumes, economic or financial information and information concerning personal life, if applicable;

o the data and documents required by law for the exercise of the activity of proxy advisor (such as the signed contract, copy of the identity card, insurance certificate or K statement), for the purpose of administrative follow-up;

or data allowing accounting and financial follow-up, such as VAT or invoices;

or data that allow your personalized and qualitative support, such as the history of your training courses or interaction reports;

o data that enable community animation and sharing of best practices, such as photos/videos of events, rankings, marketing materials, testimonials, surveys.

The mandatory nature of the collection of personal data is indicated on the collection forms by the presence of an asterisk next to the corresponding field or fields. If there is no asterisk, the information requested is optional.

If the mandatory information is not provided, the request related to this data collection (e.g., request for information, application) may not be processed or its processing may be delayed.

5. Collection objectives

KONECTAS undertakes to ensure that the data processing is carried out for an explicit, legitimate and specific purpose.

Depending on the case, KONECTAS processes the data collected through the above-mentioned collection points in whole or in part for the following main purposes:

– Carrying out activities of prospecting, loyalty, studies, surveys and improvement of the online experience on KONECTAS websites:

Management and processing of requests from site users and, more generally, from KONECTAS contacts;

or access and benefit from online features and services, such as free quotes;

o management and execution of marketing, teleprospecting and personalized communication operations;

or put you in contact with a KONECTAS real estate agent;

o analysis of the use of the website and the browsing behavior of users with a view to its optimization;

o studies, analyses, reports and statistics.

– Real estate transaction activity (follow-up of mandates and sales):

Management and execution of commercial prospecting and acquisition operations;

o Execution of the contract between KONECTAS and its end customers (sellers, buyers, lessors, lessees);

o Fulfillment of the legal and regulatory obligations derived from the real estate agent activity;

o Solicitation of service providers or partners in connection with the end customer’s project;

o Monitor the quality of service, reputation and customer satisfaction with KONECTAS.

– Administrative, accounting and financial follow-up;

Putting a buyer or seller contact in contact with your KONECTAS real estate consultant as a result of your personal action and after having obtained the consent of such contact;

– Recruitment, integration, training and support for KONECTAS real estate agents:

Follow-up and processing of applications, as well as operations prior to contracting;

o administrative and accounting follow-up of real estate agents;

o monitoring the activity of the consultants;

o development of consultant loyalty through community animation and sharing of improvements;

6. Recipient of the data:

The personal data of the customers are intended for the departments and authorized personnel of the KONECTAS Group, the real estate agents of the KONECTAS network, as well as, as the case may be, their partners or service providers in connection with the end customer’s project, in particular real estate listing sites, real estate photography service providers, brokerage professionals, printers and communication service providers. The personal data of KONECTAS real estate agents are intended to be used by the authorized departments and staff of the KONECTAS Group, as well as by potential clients, customers or candidates for this function. It may also be communicated to its partners or service providers for the execution of tasks necessary for the management of the agent’s contract, such as printers or event agencies.

In addition, the data may be communicated to any authority legally entitled to know them, in particular in case of request from judicial, police or administrative authorities.

It is specified that the recipients referred to are not recipients of all the data of the interested parties, but only those necessary for the purpose of such communication.

7. Retention of collected data:

In general, the data is retained for the time necessary to achieve the above purposes, without prejudice to the obligations to retain certain data in application of legal or regulatory provisions (e.g. accounting and statutory retention periods), the settlement of disputes and to assert, exercise and/or defend the rights of KONECTAS.

For example, it has been set at 14 months for connection, navigation and traffic data (cookies); a maximum of 5 years for commercial prospecting; 10 years for mandate contracts and associated supporting documents, due to real estate regulations; a maximum of 10 years for applications for real estate agent positions.

However, it is specified that all such data may be retained for longer than the aforementioned periods after obtaining the consent of the data subject.

The aforementioned retention periods have been defined in such a way as to allow KONECTAS to process the mandate contracts, the various requests (information, contact, online quotes, etc.) and/or to carry out its commercial, communication, marketing and recruitment operations, while respecting the principle of proportionality, according to which personal data should not be kept longer than necessary to achieve the purpose for which they were collected.

8. Rights of users:

In accordance with the aforementioned legal and regulatory provisions, data subjects have the right to consultation, access and portability of their personal data.

They also have the right to object to the use of their data for prospecting purposes, in particular for commercial purposes. In addition, a link is included at the end of the mailings so that the persons concerned can easily unsubscribe.

They also have the right to rectify and suppress the processing of their data to a certain extent.

They have the right to define general and/or specific guidelines on the destination of their personal data and the way they wish their rights to be exercised after their death. In this regard, in the event of your death, brought to the attention of KONECTAS, your data will be deleted, unless it is necessary to keep them for a certain period of time for reasons related to legal and regulatory obligations and/or KONECTAS prescription periods and after communication to a third party, where appropriate, designated by them.

All requests for the exercise of these rights, as well as all requests for information relating to the protection of personal data, should be addressed to the Data Protection Officer (DPO) at the following address with the words “RGPD” in the subject line

– By mail: calle Sant Bartomeu, 31, 1º, Sitges (Barcelona), Spain

– Electronically: info@konectas.com

A response will be given within a maximum period of one month from the date of receipt of the request, in accordance with current regulations. For the sake of confidentiality and protection of personal data, KONECTAS must ensure the identity of the data subjects before responding to such requests. Therefore, any request to exercise these rights must be accompanied by a copy of a signed identity document.

In any case, the individuals concerned have the possibility of lodging a complaint with a national authority responsible for the protection of personal data (in France, this is the Commission Nationale de l’Informatique et des Libertés or “CNIL”) if they consider that their data are not being processed in accordance with the applicable provisions.

9. Safety:

To ensure the security of personal data, the KONECTAS Group and the real estate agents of the KONECTAS network take all useful and appropriate precautions and measures, whether physical, logical, technical, functional, administrative or organizational, in relation to the state of knowledge, the costs of implementation and the nature, scope, the context and purposes of the processing, as well as the risks, the degree of likelihood and severity of which vary, to the rights and freedoms of natural persons, in order to preserve the security and confidentiality of the data and to ensure a level of security appropriate to the risk, and in particular to prevent them from being falsified, damaged or accessed by unauthorized third parties.

In case of difficulties, the KONECTAS Group and the real estate agents of the KONECTAS network will make every effort to limit the risks and will take all appropriate measures, in accordance with their legal and regulatory obligations (corrective actions, informing the national authority responsible for the protection of personal data and, where appropriate, the persons concerned, etc.).

In case of subcontracting all or part of the processing of personal data, KONECTAS contractually requires its subcontractors to provide guarantees of security and, in particular, confidentiality of personal data to which they may have access (appropriate technical and organizational measures to protect these data).

It is specified that the KONECTAS Group and/or the real estate agents of the network may put the interested parties in contact with real estate agencies, companies, craftsmen or third-party websites outside KONECTAS. In this regard, their personal data protection policies may differ from those of KONECTAS. Therefore, it is recommended to read their personal data protection policies in all cases. In any case, KONECTAS cannot be held responsible in the event that the data processing carried out contravenes the applicable legal and regulatory provisions.

10. Updates to this policy:

This privacy policy may be modified or adjusted at any time. In case of modification or adjustment, the new Policy will be published on the site in the dedicated section. In addition, all personal data collection forms on KONECTAS websites provide a link to this Policy. Interested parties are invited to consult it regularly.