PRIVACY POLICY

ARTICLE 1: PREAMBLE

This privacy policy applies to the Moderlab application. The purpose of this privacy policy is to inform users of the application about how their personal data is collected and processed. Personal data refers to any data that could identify a user, including first and last name, age, postal address, email address, location, IP address, device and browser.

What rights users have regarding their data;
Who is responsible for the collection and processing of personal data;
To whom this data is transmitted;
Where applicable, the application's policy regarding "cookies".
This privacy policy supplements the Legal Notice and Terms of Use that users may consult at the following address: https://moderapp.com/confidentiality

ARTICLE 2: GENERAL PRINCIPLES REGARDING DATA COLLECTION AND PROCESSING

In accordance with Article 5 of European Regulation 2016/679, the collection and processing of user data complies with the following principles:
Lawfulness, fairness and transparency: data may only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that their data is being collected and for what purpose;
Purpose limitation: data collection and processing are carried out to meet one or more specific objectives defined in these terms of use;
Data minimisation: only data necessary for the proper fulfilment of the objectives pursued by the site is collected;
Storage limitation: data is kept for a limited period, of which the user is informed. Where this information cannot be provided, the user is informed of the criteria used to determine the retention period; Integrity and confidentiality: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.
In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only take place if at least one of the following conditions is met:
- The user has given explicit consent to the processing;
- The processing is necessary for the performance of a contract;
- The processing meets a legal obligation;
- The processing is necessary to protect the vital interests of the person concerned or of another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
- The processing and collection of personal data is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF NAVIGATION IN THE BACK OFFICE AND THE APPLICATION

A. DATA COLLECTED, PROCESSED AND METHOD OF COLLECTION

The personal data collected on the Moderlab application is as follows:
    - last name
    - first name
    - residential address
    - email address
    - phone number

The commercial data collected on the Moderlab application is as follows:
- purchase reporting (apartment / product information);
- connection information (IP address, location, connection duration, device, operating system, browser, network);
- activity on the application;

This data is collected when the user performs one of the following operations:
- when the user registers on the site;
- when the user visits a sales office and provides personal information;
- when the user visits a unit;
- when the user saves their configurations;
- when the user validates a cart or makes a purchase (unit, developer-included and optional services, product);

Furthermore, when a payment is made on the site or application, proof of the transaction including the order form and invoice will be retained in the publisher's computer systems.
The data controller will retain all collected data in the back office and application computer systems under reasonable security conditions for an indefinite period.
The collection and processing of data serves the following purposes:
- improving the use of the application;
- purchasing real estate;
- configuring an apartment (choosing included and optional services, purchasing furniture);

Personal Space
moderapp_settings — cookie preferences — 1 year — moderlife.com
i18n_redirected — display language management — SESSION — moderlife.com
_secure__ls__metadata — LocalStorage encryption — SESSION — moderlife.com
internal_origin — redirect status — 10 minutes — moderlife.com
temp-usr, temp-usr-rl, temp_vx — tokens — SESSION — moderlife.com

Streaming
auth.strategy — cookie storage type — SESSION — streaming{instance}.moderlife.com
i18n_redirected — display language management — SESSION — streaming{instance}.moderlife.com
moderapp_favorites — favourite units — SESSION — streaming{instance}.moderlife.com

Professional Space
_ga — traffic analysis — SESSION — analytics.google.com
_ga_R372T6FSZS — session persistence — SESSION — analytics.google.com
tarteaucitron — cookie preferences — 1 year — moderapp.com
moderlab_solutions_pour_linnovation_immobiliere_session — token — SESSION — moderapp.com
XSRF-TOKEN — token — SESSION — moderapp.com

B. TRANSMISSION OF DATA TO THIRD PARTIES

The personal data collected may be transmitted to the property developer or furniture distributor who will be your point of contact; it will be processed by them and Moderlab for the reasons defined in the previous section.

C. DATA HOSTING

The Moderlab site is hosted by: OVH, whose registered office is located at: 2 Rue Kellermann, 59100 Roubaix. The host can be contacted at the following phone number: 09 72 10 10 07. The data collected and processed by the site is exclusively hosted and processed in France.

ARTICLE 4: DATA CONTROLLER AND DATA PROTECTION OFFICER

A. THE DATA CONTROLLER

The person responsible for processing personal data is: Elsa MAJI. She can be contacted as follows: contact@moderlab.com. The data controller is responsible for determining the purposes and means of personal data processing.

B. OBLIGATIONS OF THE DATA CONTROLLER

The data controller undertakes to protect the personal data collected, not to transmit it to third parties without the user being informed, and to respect the purposes for which this data was collected.
Furthermore, the data controller undertakes to notify the user in the event of rectification or deletion of data, unless this entails disproportionate formalities, costs and steps for them.
In the event that the integrity, confidentiality or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means available.

C. THE DATA PROTECTION OFFICER

The user is informed that the following person has been appointed Data Protection Officer: Elsa MAJI.
The role of the Data Protection Officer is to ensure the proper implementation of national and supranational provisions relating to the collection and processing of personal data. They are sometimes referred to as a DPO (Data Protection Officer).
The Data Protection Officer can be reached as follows: contact@moderlab.com

ARTICLE 5: USER RIGHTS

In accordance with regulations on the processing of personal data, the user has the following rights.
In order for the data controller to act on their request, the user must provide: their first and last name as well as their email address, and where relevant, their account, personal space or subscriber number. The data controller is required to respond to the user within a maximum of 30 (thirty) days.

A. OVERVIEW OF USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING

a. Right of access, rectification and right to erasure

The user may view, update, modify or request the deletion of data relating to them, by following the procedure set out below:
Simply log in to your Moderapp personal space at https://moderapp.com/users — MY INFORMATION / MY DETAILS.
If you logged in via a property developer's client portal, simply make the request directly to the property developer.
If they have one, the user has the right to request the deletion of their personal space by following this procedure:
    Simply submit a request by email to contact@moderlab.com

If you logged in via a property developer's client portal, simply make the request directly to the property developer.

b. Right to data portability

The user has the right to request the portability of their personal data held by the application to another site or application, by following the procedure below: Simply submit a request by email to contact@moderlab.com. If you logged in via a property developer's client portal, simply make the request directly to the property developer.

c. Right to restriction and right to object to data processing

The user has the right to request the restriction of or to object to the processing of their data by the site, without the site being able to refuse, unless it can demonstrate the existence of legitimate and compelling grounds that may override the interests, rights and freedoms of the user. To request the restriction of data processing or to object to data processing, the user must follow the procedure below:
- Simply submit a request by email to contact@moderlab.com
- If you logged in via a property developer's client portal, simply make the request directly to the property developer.

d. Right not to be subject to a decision based solely on automated processing

In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based solely on automated processing if the decision produces legal effects concerning them or significantly affects them in a similar manner.

e. Right to determine what happens to data after death

The user is reminded that they may determine what should happen to their data collected and processed in the event of their death, in accordance with Law No. 2016-1321 of 7 October 2016.

f. Right to lodge a complaint with the competent supervisory authority

In the event that the data controller decides not to respond to the user's request and the user wishes to challenge this decision, or if they believe that one of the rights listed above has been infringed, they are entitled to contact the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent court.

B. PERSONAL DATA OF MINORS

In accordance with Article 8 of European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data. If the user is a minor under the age of 15, the consent of a legal representative will be required before any personal data can be collected and processed.

The site publisher reserves the right to verify by any means that the user is over 15 years of age, or that they have obtained the consent of a legal representative before browsing the site.

ARTICLE 6: USE OF "COOKIES"

The site may use "cookie" technology.

A "cookie" is a small file (less than 4 KB), stored by the site on the user's hard drive, containing information relating to the user's browsing habits.
These files enable the processing of statistics and traffic information, facilitate navigation and improve the service for the user's comfort.
For the use of "cookies" involving the storage and analysis of personal data, the user's consent is required.
The user's consent is considered valid for a maximum period of 13 (thirteen) months. At the end of this period, the site will again request the user's authorisation to store "cookies" on their hard drive.

a. User's right to object to the use of "cookies" by the site

The user is informed that they may object to the storage of these "cookies" by configuring their browser. For information, the user can find the steps to configure their browser to object to the storage of "cookies" at the following addresses:
Chrome: https://support.google.com/accounts/answer/61416?hl=fr
Firefox: https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences
Safari: http://www.apple.com/legal/privacy/fr-ww/
Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
Opera: http://www.opera.com/help/tutorials/security/cookies/

If the user decides to disable "cookies", they may continue to browse the site. However, any malfunction of the site caused by this action cannot be considered the responsibility of the site publisher.

b. Description of "cookies" used by the site

The site publisher draws the user's attention to the fact that the following cookies are used during browsing.
When browsing the site, the user is informed that third-party "cookies" may be stored.
These third parties are in particular:
In addition, the site incorporates social network buttons, allowing the user to share their activity on the site. "Cookies" from these social networks may therefore be stored on the user's computer when they use these features.
The user's attention is drawn to the fact that these sites have their own privacy policies and terms of use, which may differ from those of the site. The site publisher invites users to consult the privacy policies and terms of use of these sites.

ARTICLE 7: CONDITIONS FOR AMENDING THE PRIVACY POLICY

This privacy policy can be consulted at any time at the following address: https://moderapp.com/confidentiality
The site publisher reserves the right to modify it in order to ensure its compliance with applicable law.
Consequently, the user is invited to regularly consult this privacy policy in order to stay informed of the latest changes made to it.
The user is informed that this privacy policy was last updated on: 07/09/2020.

ARTICLE 8: USER ACCEPTANCE OF THE PRIVACY POLICY