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CONFIDENTIALITY

1. PERSONAL DATA

a) In charge of treatment
The person in charge of processing User Data processed by the Company is

Subsquare SAS
Simplified Joint Stock Company with a capital of € 10,000
RCS Paris 823 822 812
Registered office: 2, avenue Paul Doumer 75116 Paris
represented by its Director of Publication.

b) Nature of the User's Personal Data Collected by the Company
Among the Data that the Company collects from the User or its terminal may appear:

• his name and surname,
• his mailing address,
• his email address (email),
• his telephone number,
• his unique identifier and his password,
• information relating to its navigation and interactions with the Services, the Application and / or the Website (search history, forms, cookies, etc.),
• its geolocation information only if it chooses it (via the Application),
• where applicable in the context of legal financing forms, information on its income and indebtedness

The Company collects the information provided by the Users including:

• when creating their personal spaces,
• when entering and sending contact forms,
• when browsing the Website and / or the Application (consultation of ads, searches, etc.).

c) Legal basis of treatment
In the context of the acceptance of the TOS, and in application of the article of the General Regulations on Data Protection, the User is informed that the various treatments of his Data mentioned below are necessary (i) to the performance and performance of the Services offered by the Company and the supply of which is governed by the present terms and conditions constituting the contract signed by the User to assist him in the context of his real estate project; (ii) as well as to the legitimate interests pursued by the Company to improve its Services and to understand Users' expectations, in particular to protect the rights and Data of the User.

In accordance with the law n ° 78-17 of January 6th, 1978 relating to data processing, the files and the liberties, the personal information relative to the Customer will be able to be the object of an automated treatment. The personal data collected through the site abrastone.com are subject to a declaration filed with the Commission Nationale Informatique et Libertés under the number 2138666 v 0.

d) Purpose of the treatment
The Data of Users processed by the Company are used for the following purposes:

• to enable them to create an account,
• to provide them with the Services available through the Website and / or the Application,
• to respond to their requests.
• to establish general statistics on the traffic of its Website and / or of its Application and the various sections it contains,
• to send them by e-mail the answers, various information or announcements published on the Website and / or on the Application by the Company or its Real Estate Partners, customers of the Company,
• to send them by e-mail newsletters on the evolution of the Website and / or the Application and the different sections of the said Website and / or the Application,
• to better understand their needs and simplify their navigations and / or to analyze or predict elements concerning them such as their personal preferences, interests, reliability, and their behaviors,
• to conduct surveys and satisfaction surveys

The Data of Users processed by the Company are also used for marketing purposes to respond to requests for information and surveys issued by Users to third parties, subject to the express consent of Users.

e) Recipients of the User's personal data
The Data may be communicated, in accordance with the laws applicable to the Company, for one or more of the purposes described above, to the persons listed below:

• the authorized and authorized personnel of ABRASTONE Group companies that may be required to process the Data,
• Real Estate Partners, customers of the Company, that Users expressly and specifically wish to contact in order to manage their requests

• banking partners as part of the "financing" form
• legal partners in the framework of the "legal" form
• Managing partners in the "Management" forms
• to the Company's IT service providers, in particular to provide a service and advertising appropriate to the Users and to measure the use of the Website and / or the Application in accordance with the provisions of the article "Use of tracking technologies" (Website and / or Application) "hereof,
• the administrative or judicial authorities authorized by French law,
• to the Company's business partners when Users have expressly agreed to receive promotional offers from them.

f) Retention period of the User's personal data
The Data are kept by the Company, in compliance with the laws applicable to the Company, for 3 years from its last contact with the Company (modification of its account, browsing the Website and / or the Application, seizure of a form on the Website and / or the Application, etc.). This information may also be kept for an additional 2 years under limited and exceptional access for the purposes of evidence in compliance with the legal and regulatory obligations of the Company. The documents and accounting documents are kept for 10 years, as accounting evidence.

2. OPPOSITION RIGHT OF ACCESS, CORRECTION AND DELETION OF USER

a) Rights of the User
In accordance with the laws applicable to the Company, the User has the faculty to:

• to oppose, at any time for reasons relating to his personal situation, the processing of his Data as part of the Services provided by the Company,
• to oppose, at any time, the processing of the Data for prospecting purposes,
• to oppose the communication of the Data to third parties, to access all of its Data processed as part of the Services provided by the Company,
• correct, update and delete the Data processed in connection with the Services provided by the Company,
• subject to the proof of their identity with the Company and where technically possible, to request the portability of the only personal data it has provided to the Company. In particular, data included in the data provided to the Company does not include any analysis of these data by the Company.
• provide the Company with direction as to the fate of its Data after its death.

In the event of exercise of the right of opposition by the User, the Company will cease the processing of its Data, except in case of legitimate motive (s) and compelling for the treatment, or to ensure the recognition, the exercising or defending his rights in court, in accordance with the General Regulations on Data Protection. Where applicable, the Company will inform the User of the reasons for which the rights it exercises can not be satisfied in whole or in part.

b) Terms of exercise of rights by the User
In order to exercise his rights, the User simply has to send a simple letter to the Company to the contact details referred to in article 1.2 of the GTU or to contact the Company via the "Contact us" section, making sure to enclose a proof of receipt. identity at his request (mention his name, first name, e-mail address) - in accordance with Chapter III of the General Regulations on Data Protection.

3. SECURITY AND ARCHIVING OF PERSONAL DATA OF THE USER

The Company collects and processes the 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 User Data of its Website and / or the Application and its Services, collected and processed by it (including firewalls, physical access controls to the data center, authorizations, etc.).

4. SETTLEMENT OF DISPUTES CONCERNING THE PROCESSING OF DATA

In the event of a dispute between the Company and the User regarding the processing of the Data, the User may send his complaint to the Company by contacting it at the address given in Article 1.2 of the TOU. The Company will endeavor to find a satisfactory solution for the User, to ensure compliance with applicable regulations.
In the absence of a response from the Company or if the dispute persists despite the proposal of the Company, the User has the possibility, in accordance with the provisions of the General Data Protection Regulation, to lodge a complaint with the National Commission of Computer and Freedoms or the supervisory authority of the Member State of the European Union in which the User usually resides.

5. NEWSLETTER AND ALERTS

In order to keep the User informed about the Company's news and the advantages it could benefit from, the Company may receive commercial information from the Company by electronic communication (email, sms ...). If the User does not wish to receive offers and information from the Company, he may oppose the sending by specifying it, at any time, in his account heading "Subscriptions" and by clicking on the hypertext link of unsubscription which found at the bottom of each electronic communication received.

The Company uses cookies on its Website Cookies are information relating to the browsing of the User's computer of the Company's Websites and which make it possible to determine the pages it has consulted, their date and time of consultation. At no time do these cookies allow the Company to personally identify the User. The shelf life of these cookies in the User's computer does not exceed thirteen (13) months. The User is informed that he has the right to oppose the registration of these cookies and this in particular by configuring his Internet browser to do so, details of which are provided in the "INFORMATION CONCERNING THE USE OF COOKIES" .

INFORMATION REGARDING THE USE OF COOKIES
When consulting our site, information may be stored in "cookie" files installed in your computer, tablet or mobile phone.
This page allows you to understand what a cookie is, what it is used for and how it can be set.

WHAT IS A COOKIE ?
A cookie is a text file that can be saved, subject to your choice, in a dedicated area of the hard drive of your device, during the consultation of an online service with your browser software.

A cookie file allows its issuer to identify the terminal in which it is registered, during the cookie validity period.

WHAT SERVES THE COOKIES ISSUED ON OUR SITE?
The cookies used on our site make it possible to identify the services and sections that the user has visited, and more generally his behavior regarding visits.
This information is useful to better customize the services, content, offers and banners that appear on our site and facilitate your navigation on our site.
Cookies are also necessary for the proper functioning of certain services or to measure their audience.
Cookies are also likely to be included in the advertising space of our site. Some non-identifying information may be sent to third parties to enable them to adapt their content.

All data collected relating to the use of the Services, the Website and / or the Application is processed by the Company and the recipients indicated in Article 10.1 e) located in and outside the European Union, particularly in the purpose of executing and providing the Services, and this in compliance with the rules provided by the Data Protection Act and the General Data Protection Regulation. This data will be processed for the purpose of following up on the Website and the Application, in accordance with the stipulations below.

Access or use of all or part of the Services implies acceptance without restriction or reservation of these different technologies by the User.