PRIVACY POLICY AND COOKIES

REALDIR SAS

Welcome to the REALDIR platform accessible via the following URL: hereinafter the "Platform".

This privacy and cookies policy (hereinafter the "Policy") aims to inform you of the rights and freedoms you may exercise with regard to our use of your personal data, and describes the measures put in place to protect it.

REALDIR is the "data controller" for the personal data processed in connection with the management of the Platform.

1. Purpose of processing

The purpose of processing is to manage the Platform.

The processing carried out via the Platform notably enables:

• Identification and authentication: we use your personal data when you want to access your Account, use the Services linked to the Platform or offer the Services;
• Managing the operation and security of the Platform: we use your personal data to operate our services and ensure security;
• Assistance: we collect your personal data to respond to your requests for assistance or service;
• Improving our services: we use your personal data to understand how you use our services on the Platform and to improve them;
• Technical administration in connection with service providers: we may use your data for purely technical purposes in connection with hosting or third-party application maintenance;
• Compliance with legal obligations: we use your personal data where we are required to do so in accordance with applicable regulations.

When using the Platform, you are required to provide us with a certain amount of personal data, such as name, first name, email, telephone number, bank details in the event of a subscription, etc., in order to create an account and access the various services and functionalities of the Platform. We may also collect your IP address for security purposes.

2. Legal basis for processing the data collected

The information collected for the purposes described above is necessary on the basis of the following legal grounds:

• Performance of a contract (identification and authentication, management of the Platform in accordance with the performance of the GTU);
• Consent (use and processing of the personal data of minors under 15 years of age, subject to the consent of the holder(s) of parental authority);
• Legitimate interest (ensuring security, improving our services and responding to your requests);
• Compliance with a legal obligation (retention, exercise of rights).

3. Retention period

Your data is only kept for as long as is strictly necessary for the purpose for which it was collected, and for no longer than 3 years from the date of account inactivity.

• Account creation (identification, authentication): 3 years from account inactivity.
• Bank details: for the duration of the transaction. This data is processed by our trusted service provider Stripe.

Your personal data will not be further processed in a manner incompatible with the purposes described in this Policy or under the collection forms.

4. Data recipients

As part of the processing operations described in this Policy, your personal data is shared with the following recipients:

• Authorized personnel within the Platform Publisher in charge of managing the Platform;
• Technical (IT) service providers;
• Hosting service providers;
• Provider in charge of payment processing;
• Service provider in charge of sending emails.

5. Transfers of personal data

Any transfer of data to a third country outside the European Economic Area (EEA) is carried out in compliance with applicable regulations and in such a way as to ensure adequate protection of personal data.

As part of the Services provided on the Platform, your data may be transferred to recipients located outside the European Union. In this case, safeguards are put in place to ensure adequate protection of personal data.

The table below details the data transfers carried out as part of the Platform's services.

6. Data security measures

The data controller implements appropriate measures to preserve the security and confidentiality of your personal data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties.

7. Cookies and trackers

A cookie is a file that enables us to record information relating to your browsing and to make it easier for you to use the Platform. All cookies are listed below:

8. Exercising your rights

The data controller makes every effort to be transparent and to allow you to control and manage your data. You may exercise the following rights at any time:

• the right of access: you may request confirmation as to whether or not data concerning you is being processed and, if so, request access to your data;
• the right of rectification: you may ask Realdir to rectify incorrect data concerning you. This means you can also ask Realdir to update or complete your data;
• the right to erasure (right to be forgotten): in certain cases provided for in Article 17 of the GDPR, you may ask Realdir to delete your data;
• the right to object: where processing is carried out on the basis of a legitimate interest of Realdir, and subject to the absence of legitimate and compelling grounds on our part, you may object to Realdir processing your data;
• the right to restriction of processing: in certain cases provided for in Article 18 of the GDPR, you may ask Realdir to restrict the processing of your data to certain purposes and under several conditions;
• the right to data portability: where the data is necessary for the performance of a contract with you or is processed on the basis of your consent, you may ask Realdir to provide you with your data in a structured, commonly used and machine-readable format, and/or to transmit it to another data controller;
• the right not to be subject to an automated decision: data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
• Withdrawal of your consent: where your data is processed on the basis of your consent, you may withdraw that consent at any time;
• The right to define post-mortem directives: under the conditions set out in articles 84 to 86 of the French Data Protection Act, you may define directives relating to the fate of your data after your death.

You can exercise your rights or ask any questions by emailing the following address: .

If, after contacting us, you feel that your rights have not been respected, you have the right to lodge a complaint with a supervisory authority, in particular the French Data Protection Authority (CNIL).

The Policy may be updated regularly to reflect technical, legal and organizational developments.

The hypertext links included in the digital version of the Policy are provided solely for your information. Realdir cannot be held responsible for the content of these links or in the event that these links no longer function.

Date of last modification: January 2024