LEGAL INFORMATION

The content on the Website www.yrsa-progedim.fr is edited by:

YRSA Communications

Simplified joint-stock company (SAS) governed by French law

With a capital of 10,000 euros

With registration number RCS PARIS 843 572 892

This site is owned by:

PROGEDIM A

Single-member Limited Liability Company (SARL unipersonnelle) governed by French law

With a capital of 7,622.45 euros

8 Rue Tournus – 75015 PARIS

With registration number RCS PARIS 333 435 360

With professional card number CPI 7501 2016 000 012 996

Insured with Professional Liability Insurance by SERENIS Assurances (Policy number: VD 7.000.001/5279)

Holding of funds: applicable only when there is insurance in effect

Intracommunity VAT number: FR 91 333 435 360

The Website is hosted by:

1&1 IONOS SARL

Single-member Limited Liability Company (SARL unipersonnelle) governed by French law

7 Place de la Gare

BP 70109 – 57200 SARREGUEMINES C

France

With registration number RCS PARIS 431 303 775

DISCLAIMER AND WARNING

1.   Information

YRSA Communications undertakes to abide by all laws regulating the creation and running of a website.

PROGEDIM A shall use its best efforts to ensure that all information made available to visitors at www.yrsa-progedim.fr is accurate, but makes no representations or warranties as to its accuracy. Internet Users are thus advised to use this information with discernment and good judgement.

If any information on the Website is found to be incomplete, or to contain legal and/or technical inaccuracies or typographical errors, corrections shall be made as expeditiously as possible by PROGEDIM A.

2.   Conditions of Access and Use

The Website is in French and provides information addressed both to customers and non-customers of PROGEDIM A, hereinafter referred to as “Internet Users.”

Internet Users acknowledge having read this charter and agree to abide by it.

Internet Users are reminded that secrecy of correspondence is not guaranteed on the Internet network and that it is the responsibility of each Internet User to take all appropriate measures to protect their own data and/or software.

3.   Hypertext Links and Off-Site Information

The Website may contain off-site information provided by external companies or hypertext links to other websites that have not been developed by PROGEDIM A and for which it is not responsible.

Links from PROGEDIM A’s Website on the World Wide Web to other websites do not constitute an endorsement of their content. It is the sole responsibility of Internet Users to use this information with discernment and good judgement. The editor shall not be held liable for any opinions, advice, or other information expressed or made available by third parties.

It is the sole responsibility of Internet Users to use the information provided on third-party websites with discernment and good judgement. PROGEDIM A shall not be held responsible for the content of any off-site pages that reference, or that are referenced by, the Website, nor does it make any warranties or representations as to their technical availability and their proper functioning. Hence, it shall not be held liable for any malfunction of third-party websites, nor for lack of access to them.

Any linking to PROGEDIM A’s Website without the editor’s prior written consent is prohibited.

Please contact us to request permission to link to the Website: contact@yrsa-progedim.fr

Due to the number of sources from which the content is obtained, and the inherent hazards of electronic distribution, there may be delays, omissions, or inaccuracies in some content.

4.   Fees

Access to the Website is free, with the exception of the costs of internet access (internet service and telephone communication) billed directly to Internet Users by their operators.

For any clarification, please contact the Website’s webmaster via the following email address: contact@yrsa-progedim.fr

5.   Liability and Site Management

To ensure the Website’s proper management, PROGEDIM A may:

• suspend, interrupt, or limit access to all or part of the Website;
• delete any information that may disrupt the operation of the Website, or that contravenes national or international law;
• suspend the Website’s operations to allow for the installation of updates.

PROGEDIM A cannot be held liable for failure, interruption, difficulty, or dysfunction preventing site access or disrupting one or more functions.

The device(s) you use to connect to the Website is/are your sole responsibility.
You must take all appropriate measures to protect your device(s) and your data against viral Internet attacks and other dangers.

LEGAL NOTICE

1.   IP Addresses

The IP addresses of Internet Users who visit the Website may be collected for statistical purposes and in case of any misuse, as required by competent authorities.

2.   Applicable Law

The content of the Website is subject to French law. PROGEDIM A reserves the right to modify or discontinue all or part of the Website at any time. Any dispute as to its content and use, as well as the remedies arising therefrom, shall fall within the exclusive jurisdiction of the French courts.

In the event of a dispute with a real estate agent, you can refer the matter to the Médiateur du Commerce Coopératif et Associé (Mediator of Cooperative and Associated Trade). The Trade Mediator is competent for any dispute regarding the execution of contracts entered into with a real estate agent and can be contacted by mail at

MEDIMMO CONSO 1 Allée du Parc de Mesemena – Bât A – CS 25222 – 44505 LA BAULE CEDEX

or via the website www.mcca-mediation.fr, which contains the Charter for Mediators of Cooperative and Associated Trade and the list of supporting documents to be provided.

3.   Copyright

All content of the Website is the property of PROGEDIM A, within the meaning of Articles L. 111.1 et seq. of the French Intellectual Property Code.

The photographs, texts, slogans, drawings, images, animated sequences (both with and without soundtrack), and any other copyrightable material that is contained on the Website are the property of PROGEDIM A or a third party who has duly authorized the use of such material.

The Website must be considered as an indivisible whole.

The information contained therein is reserved for personal use only and shall not be reproduced or circulated in whole or in part.

All data (text, sounds or images) displayed on the Website’s pages are the sole property of PROGEDIM A or its partners.

The reproduction, whether on paper or by electronic means, of this Website is authorized provided that it is strictly limited to personal use (excluding any use for advertising and/or commercial purposes) and/or informational purposes only, and/or that it is in compliance with the provisions of Article L. 122-5 of the French Intellectual Property Code.

With the exception of the above provisions, any reproduction, representation or distribution, for purposes other than personal use, by any process and in any format whatsoever, of all or part of the Website is strictly prohibited.

Failure to comply with this prohibition may constitute a breach of copyright and result in civil and/or criminal legal action against any offender. It is strictly forbidden to use or reproduce the name of “PROGEDIM A” and/or its logo, for whatever reason (in particular, for advertising purposes), without the prior written consent of PROGEDIM A.

No act of downloading or otherwise copying from PROGEDIM A’s Website will transfer ownership rights to any software, data, or material to you.

You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into, or use for any public or commercial purpose the Website without the prior written permission of PROGEDIM A. All data contained on PROGEDIM A’s Website are the sole property of their respective owners.

Hence, Internet Users undertake:

• not to misuse the services provided by PROGEDIM A or the personal data to which they may have had access;
• not to offer products or services provided by PROGEDIM A and its branches via the Website to receive any direct or indirect remuneration;
• not to limit the access to and use of the Website owned by PROGEDIM A and its branches;
• not to modify any notice or element on the Website owned by PROGEDIM A and its branches;
• not to send mass spam emails or mailing messages of any other kind whatsoever to other Internet Users.

GENERAL POLICY FOR PERSONAL DATA PROTECTION

The purpose of this privacy policy is to inform all Internet Users in a clear manner about the data processing measures adopted by PROGEDIM A and the rights to which they are entitled as visitors of the website www.yrsa-progedim.fr.

Identity of the Data Controller

YRSA COMMUNICATIONS, a company incorporated with the Paris Trade and Companies Registry under number 843572892, with registered office at 119/121 avenue Emile Zola, and represented by Mr. Yves Romestan,

is responsible for processing personal data collected on the website www.yrsa-progedim.fr, within the meaning of the Regulation (EU) 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 referred to as “GDPR”).

The way in which data are collected and used is explained in detail below.

1.   Definition of Personal Data

Any information that relates to an identified or identifiable natural person either directly (e.g., a surname, first name, mailing or e-mail address) or indirectly (e.g., a username, an IP address, browsing data, etc.).

2.   Circumstances under which Personal Data are Collected

PROGEDIM A collects personal data directly from Internet Users. Personal data are collected and processed when you visit our Website (www.yrsa-progedim.fr) and fill out our data collection form with your information.

The type of personal data collected through the Website may vary depending on how our services are used. The personal data collected or stored are directly provided by Internet Users themselves or third parties, or are generated from their activity on the website and their use of our services.

Account Management

When creating your account, you must provide data relevant to your account’s creation (email address and new password). We will then generate a unique username that will allow you to authenticate yourself securely, personalize your experience and send yourself service emails (account creation, password change request, etc.).

In your personal space, you can add and view favorites, see your saved searches, and manage posted ads. In addition, the browsing data generated when you visit real estate pages are collected automatically in order to list the ads you have seen previously.

Alert Management and Newsletter Subscription

When you activate a “similar listings” alert, you agree to receive alerts by email or notifications for similar properties matching your search criteria and shall thus provide us with the following data:

• marital status;
• email address and phone number;
• search criteria, alert title, and reason (optional).

When you subscribe to the newsletter, you agree to provide us with your email address in order to receive our newsletter.

Request Management and Communication with Real Estate Professionals via the Online Form

(1) When you fill out the contact form to forward your request to and communicate with a real estate professional, you will provide us with the following information:

• marital status;
• email address;
• search criteria, alert title, and reason.

Unless you object, you will also receive by email or notification similar properties corresponding to your search criteria, as well as our service proposals relevant to your real estate project (which we refer to as “Analogous Services”).

In addition, subject to your consent, we collect certain browsing data (number of contact requests associated with your email address and pages visited) in order to allow the real estate professional to better understand your property purchasing plans and to automatically estimate the level of interest in your search. This information is communicated to the real estate professional to help him/her better manage requests for contact as well as to indicate to the real estate professional the listings that may interest you.

(2) When you fill out the real estate appraisal request form, you give us permission to forward your contact request to a real estate professional. In doing so, you provide us with the following information:

• marital status;
• email address.

(2) When you fill out the Owners “Sell a Property” form, you give us permission to forward your contact request to a range of real estate professionals as part of your plans to sell a property. In doing so, you will provide us with the following information:

• marital status;
• type and location of the property;
• email address and phone number.

(3) When you fill out the “Contact Us” contact form to request assistance, you provide our customer service with the following information:

• name;
• email address.

Management of your Internet Browsing and Property Searches

(1) When you visit the Website, we collect your browsing data (number of visits, pages visited, browser history, actions taken on the Site, source of Site traffic, IP address) and generate an audience measurement identifier, in accordance with the lawful basis required by regulations to generate statistics regarding the Site’s traffic and use.

(2) When you visit the Website, we collect your browsing data in order to ensure security from our services by detecting or retracing all attempts at malicious acts, hacking, or violations of Terms of Use.

Mandatory Nature of Data Collection

When filling out the electronic personal data collection form, Internet Users are notified whether or not it is mandatory to answer via an asterisk next to the relevant field(s) or via the disclaimer “voluntary.” In the absence of such a specification, the requested information will not be mandatory.

3.   Purpose of Personal Data Processing

The processing of personal data takes place for the following purposes and in accordance with the lawful bases specified below:

4.   Recipients of Personal Data

Data are processed by PROGEDIM A personnel. Data may also be transferred to the company’s partners, who, when acting as recipients, may process the data on their own behalf, or who, when acting as data processors, may only process the data on behalf of and according to the instructions of PROGEDIM A.

Recipients of the data are:

• Julien Cotel
• Rachel Pétremant
• Sophie Gleizes

PROGEDIM A uses data processors for the following operations:

• Data storage and website hosting;
• Development and technical maintenance operations for the Website;
• Sending emails.

5.   Transfer of Data Outside the EU

Internet Users are hereby informed that their personal data may be transmitted to companies based outside of the European Union for the purposes listed above.

In the case of data transfer outside of the European Union, PROGEDIM A shall make certain that the country or countries receiving the data ensure adequate data protection.

• Either the country of the recipient(s) shall offer a level of data protection deemed adequate by the European Commission;
• or the recipients shall be adherents to “Privacy Shield” principles;
• or the transfer shall be carried out in compliance with the requirements of the Regulation (EU) 2016/679 of 27 April 2016 (clauses on protection practices adopted by the European Commission or the CNIL [French National Commission for Computing and Freedom], binding corporate rules approved by the CNIL, code of conduct approved by the CNIL, or certification issued by an accredited body).

6.   Retention Period of Personal Data

Personal data are retained for the purposes detailed herein.

As such, data pertaining to messaging forms are retained for a period of five years. Data pertaining to the contractual relationship are retained as long as the concerned party maintains a contractual relationship.

7.   User Rights

In accordance with the amended Data Protection Act of 6 January 1978 and the Regulation (EU) 2016/679 of 27 April 2016 (applicable starting 25 May 2018), and under the conditions provided for in this text, Internet Users have the following rights:

• Access rights: Any Internet User holds the right to obtain confirmation that his/her data have been processed and, in such an event, to access the data as well as information regarding the processing of said data;
• Right to rectification: Any Internet User holds the right to the rectification of his/her data by PROGEDIM A, without undue delay, when said data is found to be inexact or incomplete.
• Right to erasure: Any Internet User holds the right, under certain conditions, to the erasure of his/her data by PROGEDIM A, without undue delay.
• Right to restriction: Any Internet User holds the right to restrict data processing if he/she disputes the accuracy of the data or the legality of the processing of his/her data, or if he/she objects to the processing of his/her data or wishes for the data to be retained for evidentiary purposes.
• Right to portability: Any Internet User holds the right to receive the data, which we process automatically and which he/she provided via a contract or another structured formal consent agreement commonly used and readable by machine. the User also holds the right to have his/her data transferred to another data controller.
• Right to object: Any Internet User holds the right to object at any time to the processing of his/her data by PROGEDIM A, unless PROGEDIM A has legitimate and imperative grounds for processing said data. In the event of commercial communications, the User may object to the processing of his/her data without reason;
• The right not to be subjected to a decision based on automated processing: Any Internet User holds the right not to be subjected to a decision based exclusively on automated processing that may have an impact on him/her legally or in another significant manner, except when the processing is necessary for the completion or execution of a contract or is authorized by law.
• Right to file a complaint: Any Internet User holds the right to file a complaint vis-a-vis a supervisory authority such as the CNIL.
• Instructions in case of death: Any Internet User holds the right to specify instructions regarding the fate of his/her data in the case of death.

To exercise these rights, the User must contact the company via the “Contact-Us” field (mentioning his/her first and last names and email address).

You may also send an ordinary letter to PROGEDIM A at the following postal address:

PROGEDIM A

Personal data

8 Rue Tournus – 75015 PARIS

Any request to exercise rights of access, rectification, erasure, or restriction of processing, must be submitted alongside a copy of the requesting User’s ID document.

For additional information or to file a complaint, you may contact the French National Commission for Computing and Freedom (Commission Nationale de l’Informatique et des Libertés). More information available here: www.cnil.fr

On the Website, users can use their account to manage their subscriptions, and newsletters via the Alert and Newsletters space.

8.   Status of this Privacy Policy

This Privacy Policy was last updated on 1 February 2021.

We reserve the right to modify the present policy at any time in order to provide updated information on our methods of data collection and processing.

COOKIES POLICY

The company PROGEDIM A operates this Website, which is accessible to the public at the following address: www.yrsa-progedim.fr. The purpose of the Website is to make available to all Internet users, as well as all visitors and users of the Site, information about the services offered by PROGEDIM A, their most recent news, and, for information purposes, details regarding real estate assets.

When the User visits the Website, information may be stored in “cookie” files installed on his/her computer or another computer medium belonging to the him/her.

Our Cookie Policy therefore allows the User to select cookies and customize his/her browsing rights.

Definition of the Term “cookies”

A cookie is a file, usually consisting of alphanumeric characters, for storing and retrieving information. It is deposited by a web server on the computer or electronic device of the user of a website to send status information to a given browser and to obtain such information in return from said browser.

In general, cookies make it possible to obtain certain information on the browsing habits of an internet user, his/her computer or his/her device, specifically in order to improve the content and services offered by the website in question, to understand the traffic of said site, and to provide internet users with personalized services.

Cookies used on the PROGEDIM A Website

1. Functionality cookies

We do not use cookies for functional purposes.

1. Cookies for advertising purposes

We do not use cookies for advertising purposes.

1. Analytics and personalization cookies

These cookies allow for:

• the establishment of anonymous statistics regarding the Website’s traffic.

Example: Cookies associated with Google

Cookies associated with Google Analytics

Cookie Settings

1. On the YRSA-PROGEDIM.FR Website

With respect to the cookies mentioned above used by the company PROGEDIM A, every User has the ability to control his/her cookies preferences as per the following:

Google Analytics

1. On an Internet Browser

With regard to cookies, the User has the ability to configure his/her browser software such that cookies are either saved on his/her computer or not, whether invariably or depending on the issuer of cookies.

The User can also configure his/her Internet browser such that the choice is offered to him/her on every occasion that a cookie is subject to be saved on his/her computer.

Every Internet browser, as part of its cookie management policy, uses different methods to present the choice to the User. As such, it is advisable to refer to the help menu of the chosen Internet browser to learn how to modify cookie preferences.

Model Letter for Objection to the Use of Personal Data

“Surname, First Name(s),”

“Number and Street,”

“Postal Code” “City”

“Name of Entity”

“Number and Street,”

“Postal Code” “City”

“Date,”

Subject: Objection to the Use of My Personal Data

To whom it may concern,

I hereby object to all use of my personal data, in accordance with Article 21 of the General Data Protection Regulation:

[Specify which data]

I therefore request a total erasure of this data for the following reasons:

[Indicate the reasons pertaining to the specific situation of the concerned person]

Please send me your response in a timely manner and, in any event, no later than one month from the receipt of my request, as per Article 12 of the General Data Protection Regulation.

Yours faithfully,

“Surname, First Name of Signatory”

Model Letter for the Erasure of Personal Data:

“Surname, First Name(s),”

“Number and Street,”

“Postal Code” “City”

“Name of Entity”

“Number and Street,”

“Postal Code” “City”

“Date,”

Subject: Request for Erasure of My Personal Data

To whom it may concern,

Information about me is currently available on your website on the following pages:

[List each relevant URL]

Thus, pursuant to Articles 21.1 and 17.1 of the General Data Protection Regulation (GDPR), I kindly request that you delete the following personal data concerning me:

[Indicate information to be deleted]

I wish for this information to be deleted because [Specify the reasons for deletion].

I also request that you take the necessary steps to ensure that these pages are no longer referenced by search engines, in accordance with Article 17.2 of the General Data Protection Regulation.

Please send me your response as soon as possible and, in any event, no later than one month from the receipt of my request, as per Article 12.3 of the General Data Protection Regulation.

Yours faithfully,

“Surname, First Name of Signatory”