GENERAL PRIVACY POLICY Belles Demeures

GENERAL DATA PROTECTION POLICY
SELOGER GROUP WEBSITE AND APPLICATIONS

Digital Classifieds France, SeLoger Group (hereinafter “DCF”) is committed to protecting the privacy and personal data of its users (hereinafter the “Users”).

The purpose of this privacy policy is to inform you in a transparent manner about the processing of your personal data by DCF and the extent of your rights in connection with the use of the websites

DCF collects the following data about you in the context of the following activities and contexts:
• seloger.com and edito.seloger.com
• selogerneuf.com
• selogerconstruire.com
• bellesdemeures.com
• bureaux-commerces.seloger.com

(hereinafter “the Website”) and the associated application, if any (hereinafter “the Application”).

IDENTITY OF THE DATA CONTROLLER

DCF (SeLoger Group) - S.A.S, having its registered office at 65, rue Ordener 75018 Paris, registered with the Paris Trade and Companies Register under number 789 177 391 - is responsible for the processing of personal data collected on the Website and the Application within the meaning of EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”).

1. What is personal data?

Personal data means any information relating to a natural person allowing him/her to be identified directly such as his or her surname, first name, postal address or e-mail, or indirectly such as a User ID, an IP address, browsing data, etc.

2. What data do we collect and under what circumstances?

DCF collects the following data about you in the context of the following activities and contexts:

• Data that you provide directly to us when completing a form or creating an account.
• Browsing data collected automatically when you use the Website or the SeLoger Application.
• Data provided by our partners. In this context, we expressly and contractually ask our partner to provide us with the appropriate legal basis so that the latter can provide us with your data.
• Data relating to the characteristics of real estate properties sold provided by our clients, real estate professionals who have subscribed to an offer to publish advertisements with DCF or made available using the DVF database (Request for Real Estate Value) made accessible by the government

Purposes	Website / Application	Data collected
Managing your account	seloger.com	When creating your account, you provide us with your account creation data (email address and password created) and we generate a unique identifier to allow you to verify your identity, personalise your experience and send you service emails (account creation, password change request, etc.). If you wish, you can also fill in the following optional personal information in order to personalise your experience on the Website and the Application: • civil status, • telephone number, • year of birth, • postal address, • reason for presence on SeLoger You can add and view in your personal space • your bookmarks, • your saved searches • and your advertisements placed. In addition, your browsing data relating to viewing property pages is collected automatically in order to list the advertisements you have seen previously. When certifying your lessee profile via SeLoger pass, you provide us with the following data in order to verify the validity of your identity document with the help of a subcontractor specialising in the verification and security of documents: • civil status, • date of birth, • email address, • official proof of identity. Your data may be processed for the purpose of improving the performance of the service based on our legitimate interest.
		You can add and view in your personal space • your bookmarks, • your saved searches • and your advertisements placed.
		When certifying your lessee profile via SeLoger pass, you provide us with the following data in order to verify the validity of your identity document with the help of a subcontractor specialising in the verification and security of documents: • civil status, • date of birth, • email address, • official proof of identity. Your data may be processed for the purpose of improving the performance of the service based on our legitimate interest.
	bureaux-commerces.seloger.com	When you are a professional and you create an account, you provide us with the following information in order to enable you to verify your account, publish your contact details on our directory and allow Users that are not Real Estate Professionals to contact you in connection with a real estate project: • civil status. • company name, SIRET. • Occupation. • email address, password created (identification data). • region, department. • postal address. • telephone/fax number. • optional website.
Managing your alerts and newsletter subscription	seloger.com edito.seloger.com selogerneuf.com bellesdemeures.com bureaux-commerces.seloger.com seloger.com selogerneuf.com bellesdemeures.com bureaux-commerces.seloger.com	When you register for a newsletter of a Website or Application, you provide us with your email address in order to receive this newsletter.
		When you activate an alert or fill in a contact form with a real estate professional or information form for a real estate program without objecting to the sending of an email alert for Similar Advertisements, you provide us with the following data in order to receive alerts by email or notification for similar properties corresponding to your search criteria: • civil status, • email address, telephone number, • search criteria, title and reason for the alert (optional).
	selogerneuf.com	When you check the box “Receive our partners’ offers” on this form, your search criteria are sent to real estate professionals, which are DCF clients, which can offer you properties similar to your search.
Manage your requests and connect with real estate professionals via online forms	seloger.com selogerneuf.com bellesdemeures.com bureaux-commerces.seloger.com	When you fill in the contact form with a real estate professional via an Advertisement page or a page of the Directory, you provide us with the following information in order to forward your request to the real estate professional • civil status, • email address, telephone number, • search criteria, title and reason for the alert, • message. Unless you object, you will also receive similar properties corresponding to your search criteria as well as our service proposals regarding your real estate project (that we qualify as Similar Services) by email or notification.
		Subject to your consent, we collect certain browsing data (number of contact requests associated with your email address and pages visited) in order to enable the real estate professional to better understand your real estate project, automatically assess the degree of interest of your search and communicate this indication to the real estate professional to help it improve its contact request management, and to inform the real estate professional of any advertisements that may be of interest to you.
		When you fill in the “Contact Us” contact form, you provide our customer service with the following information in order to answer your questions: • name, • email address, • subject of your request, • message, • Client/non-client status, • postcode and city (optional) • telephone number (optional), • Company name (optional),
		When you fill in some of our forms and unless you object, you provide us with the following information in order to contact you by email as part of satisfaction surveys, studies and polls • name, • email address. • Management of your browsing and real estate search
	seloger.com	When you fill in the contact form with an individual renting a property, you provide us with the following information in order to forward your request to the lessor • civil status, • email address, telephone number, • lifestyle habits, family situation. In order to send the information to be declared by the applying lessee allowing the lessor to assess his/her financial situation, you provide us with information • on the composition of your household, • your professional situation, • your income and any guarantors • as well as those of your co-lessees. You may also provide us with information relating to the certification of your lessee profile
		When you fill in the real estate property valuation request form, you provide us with the following information so that we can carry out an automated assessment of your property using our subsidiary Falguière Conseil: • civil status, • email address, telephone number, • characteristics of the property to be assessed, • vendor profile. In addition, unless you object, we can use this data to contact you by phone, SMS or email in order to offer you support services regarding your real estate project.
		When you fill in the Buyer Contact form (“Need the help of a pro to help you define your project?”), you provide us with the following information in order to send us your contact request to a selection of real estate professionals as part of your project to purchase a real estate property: • civil status, • email address, telephone number, • postcode.
		When you fill in the Mandate Opportunity form (“Request to be called back by a SeLoger agent”), you provide us with the following information so that we can send your contact request to a selection of real estate professionals as part of your project to sell a real estate property: • civil status, • type and location of the property, • email address, telephone number.
		When you fill in a loan insurance form in connection with our dedicated partner, you provide us with the following information in order to obtain an automated loan insurance quote from our partner and, if you consent, to be contacted by email by our partner to fine-tune your loan insurance rate: • civil status, • email address, telephone number, • characteristics of the real estate project, • age, occupational status, “smoker” status, • characteristics of the contemplated loan.
		When you fill in the relocation form in conjunction with our dedicated partner, you provide us with the following information in order to obtain an automated relocation quote from our dedicated partner: • civil status, • telephone number, • characteristics of the move.
		When completing the advertisement report form, you provide us with the following information in order to take into account your reporting of an advertisement and inform you of the follow-up: • name, • email address, • reason for the report, • optional clarifications. • In addition, we collect your IP address in order to verify and detect any attempted malicious report.
	bellesdemeures.com	When you fill in the request form for the assessment and sale of a real estate property (“You intend to sell a luxury real estate property?”), you provide us with the following information in order to be contacted by telephone to fine-tune the assessment of your property and help you sell your prestige property quickly through our network of partner agencies, subject to your consent: • civil status, • email address, telephone number, • characteristics of the real estate property (type, surface area, location and optionally, address and description), • information on your proposed sale.
	bureaux-commerces.seloger.com	When you check the “Entrust my request to other agencies” box in an Agency’s contact form, • your contact details • and search criteria are sent to real estate professionals, which are DCF clients, which may contact you to offer you properties similar to your search.
		When you fill in the Lessee Contact Form (“Entrust Your Search”), you provide us with the following information so that we can forward your contact request to a selection of real estate professionals as part of your property search project: • type of transaction (rental, lease assignment, sale or sale of business assets). • type of property sought, surface area for the sale, rental and transfer of leases. • contemplated activity, effective for the sale, lease and transfer of leases. • business sector of the business assets sought. • location. • proposed moving-in date. • optional comments. • civil status. • email address, telephone number. • company name.
		When you fill in the Mandate Opportunity form (“Broadcast your advertisement”), you provide us with the following information so that we can send your contact request to a selection of real estate professionals as part of your project to sell a real estate property: • type of transaction (rental, lease assignment, sale or sale of business assets). • type of property sought, surface area for the sale, rental and transfer of leases. • contemplated activity, effective for the sale, lease and transfer of leases. • business sector of the business assets sought. • price or rent of the property. • location. • Description of the property. • civil status. • email address, telephone number.
	selogerneuf.com	When you fill in the investment form (“Your tailored real estate investment project”), you provide us with the following information in order to send us your contact request to our specialised partners to manage your investment project application: • information about your project (object, type of property, location, proximity criteria), • information about your profile (financial situation, family situation), • choice of partners to contact, • name, • email address, telephone number, • date of birth, • postcode. Unless you object, we may also contact you by phone or email in order to pre-qualify your investment project request and transfer your information to our selected partners subject to your prior consent.
		When you fill in a form on the page of a real estate program or via the Directory (“Receive the brochure”, “Receive the plan” or “Contact the Developer”), you provide us with the following information in order to transfer your request to the property developer: • name, • email address, telephone number, • search criteria, title and reason for the alert. As part of these forms, you can also consent to the sending of offers from SeLoger Neuf real estate developers by SMS and/or Email according to your preferences (“Receive the offers of SeLoger Neuf developers by SMS / Email”).
		When you press the “Call” button online, we generate a technical identifier in order to call the property developer on VoIP.
Management of your browsing and real estate search	seloger.com selogerneuf.com bellesdemeures.com bureaux-commerces seloger.com	When you browse the Website or the Application, we collect the following data in order to manage your browsing, optimise your search time and geographical searches via mapping and offer properties close to your favourite places (“See properties in my area”), optimise your search time and offer recent searches, determine an ideal living area and calculate a perimeter based on your indication of preferred maximum travel time and methods of transport: • geolocation data, • search criteria filled in, • advertisements viewed and date of viewing.
		When you browse the Website or the Application, we collect data on your browsing (number of visits, pages visited, browsing history, actions carried out on the website, origin of access to the website, IP address) and generate an audience measurement identifier, in accordance with the legal basis required by the regulations, in order to generate statistics on its traffic and use.
		When you browse the Website or the Application, subject to your prior consent for the placement of trackers of the associated purpose, we collect your browsing data, in order to present you with advertisements tailored to your interests. In the absence of consent, we collect your IP address in order to distribute contextual advertising to you.
		When you browse the Website or the Application, we collect data about your browsing to ensure the security of our services by detecting/tracking any malicious attempt, computer intrusion or breach of the T&C of Use.
	seloger.com selogerneuf.com bellesdemeures.com	When bookmarking (“Saving”) a real estate property, we collect the following data in order to be able to alert you in the event of a change in the price of an advertisement, to allow you to find these advertisements in your bookmarks from the Website or the Application and identify the advertisements previously bookmarked: • characteristics of the saved advertisement, • unique identifier with which the bookmark is associated.
	seloger.com	When you browse the Website or the Application, subject to your prior consent for the placement of trackers of the associated purpose, we collect data about your browsing (number of contact requests associated with your email address and pages visited) and generate a unique identifier in order to activate the Advertisement Recommendation and recommend any properties that may be of interest to you by notification.
Publication of your advertisement	seloger.com	When you place an advertisement to rent a real estate property as an individual owner, you provide us with the following information in order to publish the property on the Website and the Application and to be contacted by interested persons: • characteristics of the property (location, description, amount of the property, and optionally, photos and videos), • telephone number (for double-factor verification purposes), • account creation data (email address and password created). • In order to detect any attempted fraud, we and our anti-fraud partner (Navee, as independent data controller) process the data you provide to us, any subsequent proof of identity or domicile and the IP address of the terminal used. This processing provides for manual moderation of potentially fraudulent advertisements and therefore does not constitute automated decision-making within the meaning of Article 22 of the GDPR. Subsequently, you may send us a video of your face in order to check that your face matches the photo of your identity document via facial recognition. In this context, we ask you to expressly accept the use of facial recognition on your face in order to certify your identity document. In addition, in this context, we can also contact you by email or by telephone in the context of satisfaction surveys, studies and polls.
Publication of your advertisement	seloger.com	When you place an advertisement as a professional for a real estate property via the dedicated forms, you provide us with the following information in order to publish the property on the Website and Application and to be contacted by interested persons: • characteristics of the property (location, description, amount of the property, and optionally, photos and videos), • civil status, • telephone number, • professional account creation data (email address and password created), • SIRET, company name, billing address, for publication invoicing purposes.
Management of the display of the properties sold	seloger.com	When you have given a mandate to a real estate professional which has subscribed to an offer to publish advertisements to DCF, the latter may send us the following information to display the properties sold on the Website or the Application: • characteristics of the property (type of property, number of rooms, Carrez law surface), • location of the property, • price and date of the sale, • real estate professional representative. This information enables us to inform our Users about the state of the real estate market in their sector and to use the characteristics of the properties sold in our calculation of an online assessment of the price of a real estate property.
Management of the display of the properties sold	seloger.com	Furthermore, when a real estate property is transferred in France, the tax authorities make available to the public free of charge the data relating to these transfers for the last five years under Decree No. 2018-1350 of 28 December 2018, adopted pursuant to Law No. 2018-727 of 10 August 2018. This data is derived from computerised processing relating to land registration and the literal documentation of the land registry (“Request for Real Estate Values (DVF)”). We collect and re-use, in accordance with the Terms and Conditions of Use of the DVF, the following information relating to sales only and from this database in order to inform our Users about the state of the real estate market in their sector: • characteristics of the property (type of property, number of rooms, Carrez law surface), • location of the property, • price and date of the sale. • With regard to DVF’s data, the provision of prior information on the processing to the data subjects concerned by such sales is impossible or requiring disproportionate effort, DCF is not required to individually inform these persons and these mentions allow the information of individuals.

3. For what purposes do we process your data and on what grounds?

We process your data for the following purposes and according to the legal bases specified below:

Legal Basis	Website or Application	Purposes of processing
Performance of the contract (Terms and Conditions of Use of the Website or the Application)	SeLoger Belles Demeures SeLoger Neuf SeLoger Bureaux et Commerce SeLoger Construire	Forward your contact or information requests to real estate professionals or developers, Be able to alert you in the event of a price change of a bookmarked advertisement, allow you to find these advertisements in your bookmarks from the Website and identify the advertisements previously bookmarked.
	SeLoger	Publish the property you wish to broadcast on our Website and Application and be contacted by interested persons, Create your account and allow you to identify yourself, Creation of an advertisement under “bookmarks”. Send you service emails associated with the performance of your contract (e.g. account created, password modification), Respond to a rental advertisement and send the information to be declared by an applicant for a rental allowing the lessor to assess his/her financial situation, Secure your account via a double-factor verification system, Invoice Professional Users for the publication of single advertisements, Send your contact requests to individuals renting a property, Send the desired visit time of a property to a real estate professional, which is a Client of DCF, Respond to your request for an automated assessment of the price of your real estate property and send you the result by email.
	SeLoger Neuf	Call the property developer in VoIP, Send your contact request to our specialised partners to manage your investment project request,
	Belles Demeures	Respond to your support request and contact you by telephone to fine-tune the real estate assessment of your property.
	SeLoger Bureaux et Commerce	Create your business account and allow you to identify yourself
Consent	SeLoger Belles Demeures SeLoger Neuf SeLoger Bureaux et Commerce SeLoger Construire	Automatically assess the degree of interest of your search and communicate this indication to the real estate professional that you contact to help him/her improve his/her management of contact requests, allow him/her to better understand your real estate purchase project and indicate to him/her the advertisements that may be of interest to you (data collected via the placement of dedicated cookies subject to consent, Enable the real estate professional to better understand your real estate project, Indicate to the real estate professional any advertisements that may be of interest to you, Subscribe to the newsletter following your request, Recommend and offer you real estate properties that may be of interest to you by notification and email alerts, Present you with advertisements and advertising content tailored to your interests through the placement of cookies,
	SeLoger	Certify a lessor’s profile via a documentary check and the implementation of facial recognition (combating fraud), Send your contact requests to a selection of real estate professionals as part of a project to purchase a real estate property, Forward your contact requests to a selection of real estate professionals as part of a proposed sale of a real estate property, Send your request to obtain a Pinel simulation to our specialist investment partner, Obtain, following your request, an automated loan insurance quotation from our dedicated partner, Allow our dedicated partner to contact you by email to fine-tune your loan insurance rate, Obtain, following your request, an automated relocation quote from our dedicated partner,
	SeLogerNeuf	send you email alerts for similar properties corresponding to your search criteria, by email or notification, following your activation of the “Save search” alert, receive offers from SeLoger neuf developers by SMS/Email according to your preferences.
	SeLoger Bureaux et Commerce	Entrust your request to other agencies, real estate professionals, which are DCF clients, who may contact you to offer you properties similar to your search. Entrust your search as part of the Lessee Contact form so that we can transfer your contact request to a selection of real estate professionals as part of your property search project. Support you in the Mandate Opportunity form so that we can send your contact request to a selection of real estate professionals as part of your plan to sell a real estate property.
Legitimate Interest	SeLoger SeLoger Neuf Belles Demeures SeLoger Bureaux et Commerce SeLoger Construire	Answer your questions to customer service (improvement of the user experience), Offer you Services Similar to your initial request unless you object, i.e. send you alerts for properties similar to your search criteria, by email or notification, following the filling in of the contact form with a real estate professional (prospecting for similar properties by the Website or the Application with the right to object), Offer you support services regarding your real estate project unless you object (prospecting for similar services with the right to object), Measure the audience of the website: generate statistics on the traffic and use of our services (proper administration of the website and user knowledge), Personalise your experience on the Website and the Application (improvement of user experience), Optimise your search time and provide recent searches and advertisements viewed (improved user experience), Contact you by email or telephone in the context of satisfaction surveys, studies and polls on the quality of the service provided and collect your feedback on this occasion (user knowledge), List the advertisements you have seen previously (improvement of user experience), Improve the performance of the service (improvement of the service), Present you with contextual advertising (improvement of advertisement relevance), Improve the service and training of our call centre agents (improvement of service and training), Ensure the security of our services by detecting/tracking any malicious attempt, computer intrusion or breach of the T&C of Use (IT security), Check and detect any attempted abusive report (protection against malicious actions), Check and detect any attempted fraud (anti-fraud), Take into account your report of a fraudulent advertisement and inform you of the follow-up given (prevention of fraud), Keep the data for evidence purposes (legal security). Achieve economies of scale, identify new opportunities, improve existing products and services and optimise business processes (synergies within the Aviv Group)
Legitimate Interest	SeLoger	Contact you by email, SMS or telephone, unless you object, in order to receive support proposals regarding your real estate project when you have made an assessment request (prospecting for similar services), Management of the display of the Properties Sold (transparency of the real estate market) Use the characteristics of the Properties Sold in our online assessment calculation (improvement in the accuracy of assessments).
Statutory Obligations	SeLoger SeLoger Neuf Belles Demeures SeLoger Bureaux et Commerce SeLoger Construire	Comply with our statutory tax and accounting obligations.

4. Who are the recipients of your data?

When your data is processed by DCF staff, we aim to ensure that only those persons whose duties are necessary to fulfill our purposes can access it.

In addition, the DCF Group offers various services accessible on various sites (and associated applications) for which it is the data controller. You can find a complete list of the group's sites available via this link: https://www.groupeseloger.com

Your data is intended for DCF in particular in order to provide you with personalised services and to facilitate your browsing.

As part of the automated assessment of the price of a real estate property, we share your data with our subsidiary Falguière Conseil SAS, joint controller for this processing, in order to obtain the assessment of the price of your property on the basis of our common data and in order to offer you support services regarding your real estate project.

As part of the fight against fraud on individuals’ rental advertisements, we share data relating to fraudulent advertisements with our anti-fraud partner, Navee, as data controller, in order to detect subsequent fraud.

Finally, your data may be communicated, when necessary for the purposes specified in point 3, to the following recipients:

• to Aviv Group GmbH, parent company of Digital Classifieds France, and all companies owned by it for analysis and growth purposes - with a view to achieving economies of scale, identifying new opportunities, improving existing products and services and optimising business processes,
• publishers who are partners of media not published by Digital Classifieds France for the purposes of fulfilling our Terms and Conditions of Sale,
• to real estate partners, which are DCF clients, acting as data controller, whom you expressly and specifically wish to contact in order to respond to your requests (information on a property, an agency, assessment request, etc.),
• to DCF service providers acting as data processors:

- service providers specialising in the verification and security of documents,
- service providers responsible in particular for providing a service and advertising adapted to Users and measuring the traffic of the Website and/or the Application,
- commercial prospecting service providers,
- contest organisation service providers,
- hosting, maintenance and cloud application service providers,
- call centre service providers,
- service providers responsible for conducting satisfaction studies.

• DCF’s business partners, acting as data controller, where users have expressly agreed to receive promotional offers from them.
• advertising service providers referred to in our cookie management platform referenced in the list “See our partners”. You can control the placement of cookies by them via our cookie management platform.
• authorised administrative or judicial authorities in order to meet our statutory obligations or a legal request from these authorities.

5. Data transfers outside the EU

Data processed by some of our data processors may be transferred outside the European Union. When data is transferred outside the EU, we ensure that destination countries provide an adequate level of data protection, following an adequacy decision of the European Commission or put in place appropriate contractual, technical and organisational safeguards, in accordance with the GDPR, in order to ensure that the level of protection of your data is equivalent to that from which they would benefit within the EU.

6. How long will your data be stored?

We store your data for varying periods depending on the type of data and the purposes for which it is processed under the following conditions:

Type of data	Website or Application	Retention period
Data collected by a form (unless it is an assessment) or activation of an alert, bookmarks or from an account Browsing data relating to your real estate project / content personalisation / audience measurement / fraud prevention	SeLoger SeLoger Neuf Belles Demeures SeLoger Bureaux et Commerce SeLoger Construire	3 years in an active database from your last activity or contact (modification of his/her account, browsing, entering a form on one of the websites and/or on one of the applications, etc.) on one of the following websites (and associated applications) “Residential” of the SeLoger Group: • seloger.com • selogerneuf.com • seloger-construire.com • bellesdemeures.com • lacoteimmo.com • logic-immo.com • neuf.logic-immo.com • construire.logic-immo.com • lux-residence.com 2 additional years in a pseudonymised archive database with restricted access for evidence purposes.
Recording of Telephone Conversations	SeLoger SeLoger Neuf Belles Demeures SeLoger Bureaux et Commerce SeLoger Construire	6 months maximum
Accounting documents and exhibits	SeLoger SeLoger Neuf Belles Demeures SeLoger Bureaux et Commerce SeLoger Construire	10 years, as accounting evidence
Geolocation	SeLoger SeLoger Neuf SeLoger Construire	Real-time use and immediate deletion
Data relating to a published advertisement	SeLoger	3 years in an active database from the expiry of the contract An additional 2 years in a pseudonymised archive database with restricted access for evidence purposes.
Anti-fraud data on advertisements published by private owners	SeLoger	30 days in an active database from the publication of the advertisement An additional 5 years in a pseudonymised archive database with restricted access for evidence purposes.
Proprietary profile certification data	SeLoger	Immediate removal of biometric models 3 months in an active database from the provision of data 5 years in a restricted access archive database for evidence purposes.
Properties Sold (postal address and characteristics of the property sold)	SeLoger	20 years from collection for statistical and information purposes on the real estate market

7. What are your rights and how to exercise them?

In accordance with the GDPR and under the conditions provided for in this text, you have the following rights:

•Right of access: you can obtain confirmation that your data is being processed, and if so, to access your data and information on the circumstances of the processing.
•Right to rectification: you can obtain from DCF rectification of your data when it is inaccurate or incomplete, as soon as possible.
•Right to erasure: you can, under certain conditions, obtain the erasure of your data from DCF as soon as possible.
•Right to restriction: you can obtain the restriction of processing when you dispute the accuracy of the data, the lawfulness of its processing, or you object to the processing or you wish to store it for the purposes of proof.
•Right to portability: you may receive your data that we process in an automated manner and which you have provided on the basis of a contract or your consent in a structured, commonly used and machine-readable format or obtain the transmission of such data to another data controller.
•Right to object: you can object at any time to the processing of your data by DCF, unless DCF has legitimate and compelling grounds for the processing of your data. In the event of commercial prospecting, you may object this without cause.
• Right not to be the subject of a decision based on automated processing: you have the right not to be subject to a decision based solely on automated processing and producing legal effects concerning you or likewise significantly affecting you, except where such processing is necessary for the conclusion or performance of a contract or is authorised by law.
•Right to lodge a complaint: you have the right to lodge a complaint with a supervisory authority, in particular the CNIL.
•Directives in the event of death: you have the right to issue guidelines regarding the fate of your data in the event of death.

To exercise your rights, simply contact us via the “Contact Us” section (names, first names, email address), available via this link.

You can also send a simple letter to DCF at the following postal address:

DIGITAL CLASSIFIEDS FRANCE
- For the attention of the Data Protection Officer –
65, rue Ordener 75018 Paris.

If you benefit from a User account on the Website or the Application, you can also manage your subscriptions, alerts and newsletters within the Alert and Newsletters area.

8. Security of your data

DCF collects and processes Data with the utmost confidentiality and security, and in compliance with the laws applicable to DCF.

DCF undertakes to take all reasonable measures necessary for the security and protection of the Data of Users of the Website and/or the Application and Services, collected and processed by it (particularly firewalls, physical access controls to data centre, authorisations, etc.).

9. How to contact the Data Protection Officer (DPO)?

DCF has appointed a Data Protection Officer. For any question about the collection and processing of your data by DCF, you can contact the DPO by clicking here.

10. Information notice specific to the recording of incoming and outgoing telephone calls by the company DCF

DCF uses a selective recording system for incoming and outgoing calls initiated by call agents for the purposes specified in this Information Notice.

a) Who is the data controller?

DCF (SeLoger Group), publisher of real estate portals, registered with the Paris Trade and Companies Register under number 789 177 391, whose registered office is located at 65, rue Ordener 75018 PARIS is the data processor of your personal data.

b) For what purposes do we process your data and on what grounds?

The selective recording of incoming and outgoing telephone calls allows the company DCF to pursue the following purposes:

• employee training;
• employee assessment;
• improving the quality of the service.

This processing is carried out on the basis of DCF’s legitimate interests:

• improve its commercial techniques,
• verify compliance with the contractual commitments of the service providers.

c) What are the recipients of your data?

Within the limits of their respective powers, the following persons are the recipients of recorded calls:

• authorised employees of the service provider (call centre), a subcontractor, under a contract with DCF,
• authorised employees of the company DCF.

d) What is the retention period for your data?

Recorded calls are kept for a maximum period of 6 months.

e) What are your rights and how to exercise them?

In accordance with the GDPR and under the conditions provided for in this text, you have the following rights:

• Right of access: you can obtain confirmation that your data is being processed, and if so, to access your data and information on the circumstances of the processing;
• Right to rectification: you can obtain from DCF the rectification of your data when it is inaccurate or incomplete, as soon as possible;
• Right to erasure: you can, under certain conditions, obtain the erasure of your data from DCF as soon as possible;
• Right to restriction: you can obtain the restriction of processing when you dispute the accuracy of the data, the lawfulness of its processing, or you object to the processing or you wish to store it for the purposes of proof;
• Right to portability: you may receive your data that we process in an automated manner and which you have provided on the basis of a contract or your consent in a structured, commonly used and machine-readable format or obtain the transmission of such data to another data controller;
• Right to object: you can object at any time to the processing of your data by DCF, unless DCF has legitimate and compelling grounds for the processing of your data. In the event of commercial prospecting, you may object this without cause;
• Right not to be subject to a decision based on automated processing: you have the right not to be subject to a decision based solely on automated processing and producing legal effects concerning you or likewise affecting you significantly, except where such processing is necessary for the conclusion or performance of a contract or is authorised by law;
• Right to lodge a complaint: you have the right to lodge a complaint with a supervisory authority, in particular the CNIL.
• Guidelines in the event of death: you have the right to issue guidelines regarding the fate of your data in the event of death.

To exercise your rights, simply contact us by explicitly specifying that your request relates to telephone recordings, via the “Contact Us” section (specify your surnames, first names, email address), available via this link.

You can also send a simple letter to DCF at the following postal address:

DIGITAL CLASSIFIEDS FRANCE
- For the attention of the Data Protection Officer -
65, rue Ordener 75018 Paris.

COOKIE POLICY
SELOGER GROUP WEBSITE AND APPLICATIONS

When visiting the Website and/or the Application, information may be stored in “cookies” files installed on the User’s computer, tablet or mobile phone. This page allows to understand what a cookie is, the purpose it serves and how we can set it.

1. What is a cookie ?

A cookie is a text file that may be saved, subject to the User’s choice, in a dedicated space on the hard drive of your terminal, when viewing an online service using the User’s browsing software.

A cookie file allows its issuer to identify the terminal on which it is saved, for the duration of validity of the cookie.

2. What is the purpose of the cookies used on the Website and/or the Application?

The cookies and trackers placed on our Website and/or our Application are of different kinds:

a) Functional cookies

These cookies that we set allow:

• to identify you when you log in to our Website or Application,
• adapt the presentation of the Website and the Application to the display preferences of your terminal (language used, display resolution, operating system used, etc.),
• memorising information relating to a form that the User has completed on the Website and/or the Application (registration or access to your account) or products, services or information that the User has chosen from the Website and/or the Application (service subscribed, content viewed, etc.)

Website / Application	Partners	More information
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	XAMARIN	allows to create applications using the C# language. This tracker is strictly necessary for the proper functioning of the Website or the Application. https://docs.microsoft.com/fr-fr/xamarin/get-started/what-is-xamarin
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	DATADOME	allows to ensure the security of our services by detecting/tracking malicious attempts or computer intrusions This tracker is strictly necessary for the proper functioning of the Website or the Application. https://datadome.co/fr/bot-protection/
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	Usercentrics	allows you to save your tracker preferences. This tracker is strictly necessary for the proper functioning of the Website or the Application. https://usercentrics.com/
seloger.com seloger-construire.com	MAPBOX	allows the display of an online map. This tracker is strictly necessary for the proper functioning of the Website or the Application. https://www.mapbox.com/legal/privacy/
seloger.com	LAUNCHDARKLY	enables AB/TESTS to be produced on different versions of the Website or the Application. This tracker is strictly necessary for the proper functioning of the Website or the Application. https://launchdarkly.com/policies/privacy

b) Tailored advertisement recommendations cookies

These cookies that we store allow you to send you advertisement recommendations in connection with your browsing on the Website or the Application.

Website / Application	Partners	More information
seloger.com selogerneuf.com	SNOWPLOW	allows you to send the necessary information for the advertisement recommendation on the Application. https://snowplowanalytics.com/privacy-policy/

c) Cookies for audience measurement

These cookies that we set allow:

• to establish anonymous statistics on the Website and Application traffic unless you object,
• measure the audience of the website,
• conduct market research and improve our website.

Website / Application	Partners	More information / Opposition
seloger.com edito.seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	AT INTERNET	allows to analyse and measure the behaviour of Users. http://www.xiti.com/fr/optout.aspx
seloger.com bellesdemeures.com	REALYTICS	allows audience and statistical measurement, it is therefore exempt from consent according to the CNIL https://www.cnil.fr/fr/solutions-pour-les-cookies-de-mesure-daudience, used to measure the performance of advertisers’ TV campaigns on digital media. In addition to measuring, Realytics offers advanced audience optimisation or measurement solutions that may require free, explicit and unequivocal consent from the User. Realytics then becomes a data provider for the advertiser’s partners, which must ensure the compliance of the operating partner. In both cases, the Realytics cookie undertakes to respect the data collected and not to collect any personal or sensitive data and can be disabled from the Realytics opt-out page by clicking here: https://www.realytics.io/optout/.
bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	MÉDIAMÉTRIE	allows to measure the audience of the Website. https://www.mediametrie.fr/fr/gestion-des-cookies

d) Cookies for tracking and personalising your browsing

These cookies that we set allow:

• simplify your searches by retaining your saved advertisements and sections visited,
• test different versions of the Website/Application and measure the audience of these versions,
• automatically assess the degree of interest of your search and communicate this indication to the real estate professional that you contact to help him/her improve his/her management of contact requests, allow him/her to better understand your real estate project and indicate to him/her the advertisements that may be of interest to you,
• to show you advertisements corresponding to your previous searches.
• improve your user experience.

Website / Application	Partners	More information / Opposition
seloger.com edito.seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	GOOGLE ANALYTICS	allows to manage advertising and analyse the behaviour of Users of the Website and the Application. https://policies.google.com/privacy?hl=fr&gl=fr https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=fr https://policies.google.com/technologies/cookies?hl=fr&gl=fr
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	HARVEST	(placed by DCF) to understand and analyse your browsing. To opt-out of these cookies, disable the Tracking and Personalisation functionality of your browsing within our cookie management platform.
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	FIREBASE	enables the monitoring and analysis of the uses of the Application. https://www.firebase.com/terms/privacy-policy.html
seloger.com bellesdemeures.com seloger-construire.com selogerneuf.com bureaux-commerces.seloger.com	SNOWPLOW	allows to understand and analyse the performance results of the Application. https://snowplowanalytics.com/privacy-policy/
bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	KAMELEOON	allows to manage the A/B tests to improve the user experience on the Website. https://www.kameleoon.com/fr/politique-confidentialite.

e) Targeted advertising cookies

These cookies allow:

• the display of relevant and targeted promotional offers and advertisements for you in advertising locations reserved for advertising on third-party websites.
• to measure the effectiveness of an advertising campaign on the website or the Application,
• limit the display of advertising on the Website or the Application.

They may be placed, subject to your consent:

• either by DCF,
• or by its advertising partners listed in the list “See our partners” of our cookie management platform.

The issuance and use of cookies by third parties are subject to the privacy policies of these third parties. As such, we invite you to peruse the privacy policy of these partners related to these cookies, some of which are available below.

Website / Application	Partners	More information / Opposition
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	ACCENGAGE	allows for the management and analysis of notification routing and in-app advertising banner broadcasting campaigns. https://www.accengage.com/privacy-policy/
seloger.com edito.seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	DOUBLECLICK FOR PUBLISHERS GOOGLE ADS GOOGLE ADSENSE GOOGLE TAG MANAGER	allows to manage advertising and analyse the behaviour of Users of the Website and the Application. https://support.google.com/dfp_premium/answer/2839090?hl=fr https://policies.google.com/privacy?hl=fr&gl=fr https://adssettings.google.com/authenticated?hl=fr https://policies.google.com/technologies/cookies?hl=fr&gl=fr https://support.google.com/tagmanager/answer/6102821?hl=fr
bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	REMAILME (CLOUDMEDIA)	allows to offer personalised advertising displaying products or services based on the recent behaviour of Internet users on Remailme’s websites, newsletters and applications. Remailme recognises internet users using cookies. https://remailme.fr/opt-out/ https://www.cloudmedia.fr/vie-privee
seloger.com	WEBORAMA	so that advertisements appearing on the Website and/or the application, or other websites, are as relevant as possible, Weborama collects, reconciles and analyses pseudonymous information from your browsing on the Website or the Application, using a code line inserted in the pages you visit (Tag Weborama). The Tag Weborama also allows to limit the number of times you see an advertisement on our Website and to measure the effectiveness of an advertising campaign. The Tag Weborama and other identifiers placed in the cookies used by Weborama are associated with each device you use to log on. This data is cross-checked with browsing data and pseudonymised before any use by Weborama, for the purpose of developing your User profile and connecting interests to it on the basis of which advertisements will be presented on behalf of partnering advertisers. These collections and associations are carried out under conditions to ensure your pseudonymity, with no data allowing Weborama to identify you directly. Pseudonymous data collected via Tag Weborama is stored by Weborama for a maximum of 13 months from the date of collection. You can opt out of receiving personalised advertisements on this link https://weborama.com/fr/opt-out-2/
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	MEDIARITHMICS	allows to track the interactions of Mobile Users in order to improve the knowledge of the User, build user audience segments according to observed behaviours, improve the user experience on the website, personalise relational marketing plans and personalise advertising targeting https://www.mediarithmics.com/fr-fr/content/charte-de-protection-des-donnees-personnelles
seloger.com edito.seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	ADOBE EXPERIENCE	allows us to measure our audience and provide Users with more relevant experiences and marketing messages based on your potential interests https://www.adobe.com/fr/privacy/opt-out.html#end-users.
seloger.com edito.seloger.com	YOUTUBE	allows videos to be read on the Website or the Application https://policies.google.com/technologies/cookies?hl=fr
bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	CRASHLYTICS	allows to collect data about the use of the Application, particularly with regard to system failures and bugs. Information about the device used or version of the Application installed, as well as other information will be used to help correct bugs, primarily with respect to the User’s software and hardware. https://policies.google.com/privacy
bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	TUNE	allows to understand and analyse the performance results of the Application. https://www.tune.com/resources/data-and-privacy/privacy-policies.
seloger.com edito.seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	CRITEO	allows you to retarget advertising to Users and optimise advertising campaigns https://www.criteo.com/fr/privacy/
seloger.com	APPSFLYER	Enables the analysis and proper functioning of paid advertising campaigns on the SeLoger application https://www.appsflyer.com/services-privacy-policy/
seloger.com	NEXITY / TABOOLA	allows for the collection of data on visitors to the NEXITY space to retarget advertising on other websites https://www.nexity.fr/charte-de-protection-des-donnees/https://www.taboola.com/fr/policies/privacy-policy-fr/
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	TABOOLA	allows the collection of visitor data on a specific page to retarget advertising on other websites https://www.taboola.com/fr/policies/privacy-policy-fr/
bellesdemeures.com seloger-construire.com	HOTJAR	in order to measure and analyse the behaviour of Users https://www.hotjar.com/privacy/do-not-track/.
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	OUTBRAIN	in order to generate a profile of interests and display targeted advertising https://my.outbrain.com/recommendations-settings/home
seloger.com bellesdemeures.com selogerneuf.com seloger-construire.com bureaux-commerces.seloger.com	SMART AD SERVER	allows to host and manage the display of targeted advertising to Users https://smartadserver.fr/politique-confidentialite-client-final/
seloger-construire.com bureaux-commerces.seloger.com	APPNEXUS	allows to connect sellers and buyers of advertising space via an automated platform https://www.appnexus.com/platform-privacy-policy-fr-072016

f) Login via social media

DCF may include computer applications on the Website from third parties that allow the User to share content on the Website with other persons or to inform these other persons of their viewing or opinion on any content on the Website. This is particularly the case for the “Share” and “Like” buttons from social media such as “Facebook”, “Twitter”, “LinkedIn”, etc.

The social media providing such an application button is likely to identify the User through this button, even if he/she has not used this button when visiting the Website. Indeed, this type of application button may allow the social media concerned to track the User’s browsing on the Website, solely because his/her account on the social media concerned was activated on his/her terminal (open session) during his/her browsing on the Website.

If the User does not want the social media to publish his/her actions from plug-ins in his/her social media accounts, the User must log out of his/her social media before browsing the Website.

3. How do I set my cookies?

Several options are available to manage cookies.

At any time, when you wish, you have the option to control your wishes in terms of cookies by configuring the cookie module the link of which is accessible at the bottom of the Website page or in the menus of the Application.

1) by configuring the cookie module the link of which is accessible at the bottom of the Website.

2) by configuring your browser:

The User can configure his/her browsing software so that cookies are saved on their terminal or, on the contrary, rejected, either systematically or depending on their issuer. The User may also configure his/her browsing software so that the acceptance or refusal of cookies is offered to him/her from time to time, before a cookie is likely to be saved on his/her terminal. For the management of cookies and the User’s choices, the configuration of each browser is different. It is described in the help menu of the User’s browser, which will allow him/her to know how to change his/her cookie preferences. For more information:
http://www.cnil.fr/vos-droits/vos-traces/les-cookies/conseils-aux-internautes/

For example:

- For Internet Explorer : http://windows.microsoft.com/fr-FR/-vista/Block-or-allow-cookies
- For Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- For Safari : https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
- For Google Chrome : https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
- For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html,
- Etc.
- Cookies « Flash »© and « Adobe Flash Player »™

« Adobe Flash Player »™ is a computer application that enables the rapid development of dynamic content using “Flash” computer language. Flash (and applications of the same type) memories the settings, preferences and use of this content using technology similar to cookies. However, “Adobe Flash Player”™ manages this information and your choices through an interface different from that provided by your browser software. Insofar as the User’s terminal is likely to view content developed using Flash language, the User is invited to access his/her Flash cookie management tools, directly from https://www.adobe.com/fr/privacy/cookies.html.

3) by refusing advertising cookies via youronlinechoices.com

The User can manage the use and operation of cookies by visiting the advertising cookie management platform offered by advertising professionals at http://www.youronlinechoices.com/fr/controler-ses-cookies/ and following the instructions given. The User may thus know the companies listed on this platform, which offer them the possibility of refusing or accepting the cookies used by them to adapt to their browsing information, the advertisements likely to be displayed.

4) by refusing a cookie issued by a social media: If the User does not want the Website and/or the Application to save cookies issued by a social media, the User may click on the following information links in order to disable cookies issued by a social media. Disabling these cookies will therefore prevent any interaction with the social media concerned:

FACEBOOK : https://fr-fr.facebook.com/policies/cookies/
TWITTER : https://support.twitter.com/articles/20171379-twitter-prend-en-charge-la-desactivation-du-suivi-dnt#
GOOGLE + : https://support.google.com/accounts/answer/3118621?hl=fr
LINKEDIN : http://www.linkedin.com/legal/cookie-policy
YAHOO : https://info.yahoo.com/privacy/us/yahoo/cookies/
YOUTUBE : https://support.google.com/accounts/answer/3118621?hl=fr
Learn more about cookies https://www.cnil.fr/fr/cookies-et-traceurs-que-dit-la-loi

In the event of refusal of certain trackers, the functionalities associated with the refused trackers will not be accessible (for example: the recommendation or customisation of the service).

Where applicable, DCF declines all liability for the consequences related to the degraded operation of its services resulting from the choices expressed by the user.

In any event, the functionalities strictly necessary or requested by the user will remain accessible (for example: verification of an account and bookmarking).

4. Retention period of your choices

Your choices regarding cookies are kept for a maximum period of 6 (six) months.