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General remarks

This privacy policy describes the policies and procedures ("Privacy Policy") applicable by PropTech Partners Ltd, Rue du Grand-Pré 2A, 1007 Lausanne, Switzerland, to the processing of personal data collecting from you ("user", "you", "your") when using our websites, platforms, portals, or mobile applications ("Neho"), such as, but not limited to www.neho.ch.

Unless otherwise defined or the context otherwise requires, capitalised terms shall have the meaning set forth in this Privacy Policy.

We propose innovative solutions consisting of services or products to improve the overall process of purchasing and selling real estate and support the stakeholders involved in this process with pragmatic, efficient and cost-effective solutions ("Offer") and have made Neho available to you to access services related to our Offer.

Use of Neho is governed by this Privacy Policy, our Cookie Policy available here: https://neho.ch/en/cookie-policy ("Cookie Policy") and our Terms of Use available here: https://neho.ch/en/terms-of-use ("Terms of Use"). By accessing and using Neho, you acknowledge that you have read and accepted this Privacy Policy, the Cookie Policy and the Terms of Use.

As we value your privacy, any personal data processing is made strictly in accordance with applicable data protection laws, including the Swiss Data Protection Act of 1 September 2023 ("DPA") and, to the extent relevant, the EU General Data Protection Regulation ("GDPR") of 25 May 2018 .

Data collected

We collect any data you provide to us when using Neho, such as, but not limited to, via our online forms, applications, other digital channels and in any other way in the course of our business. Your data is collected and processed when you:

register online, access or use your Neho account, place an order and or/a request for any of our products or services;
request to evaluate your property;
contact us via customer service, a contact form, by email or telephone;
meet our agents;
visit a property;
consent to sending us or allow us to take digital images and videos of the property to be sold;
voluntarily complete a customer or user survey or provide feedback on any of our message boards or via email;
subscribe to our newsletters;
consent to receiving advertisement from our part;
participate in a promotion, activity, or any other similar event launched by Neho;
use or view of Neho, with or without your browser’s cookies.

Some data is collected in an automated way, including by means of tools and other active elements, through the use of cookies or similar technologies. You can set certain permissions and parameters in connection with the automated collection of your data. We take appropriate measures to protect your data and to assign it to the purpose of collection, as defined below, at section 3.

We collect the following data necessary for enabling our Offer to you:

identification data: name, email address, phone number, postal address (complete address, including place, postal code, city, country);
personal characteristics: your date of birth, gender, nationality, marital status, ID documents information, i.e. passport, identification card (number, expiry date, place of issuance);
personal financial data: tax and pension fund statements, insurance policies, information regarding your debts and liabilities, personal income statements and/or income information;
user profile/login data: username and password, language preferences;
user shopping history: information about your current and past purchases and contracts, i.e. products, services, payment amount;
data regarding your property to be sold: complete address, including place, postal code, city, country, digital images and videos of the property to be sold, insurance policies, plans, and any other information or documents provided by you in relation with your property;
payment information: bank details (e.g. IBAN), invoicing address;
technical data: Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access this website (for more information please read our Cookie Policy);
other data: social media profile information, information about newsletters to which you subscribed or other advertisement, your activity or preferences when using Neho, content of a meeting or a conference call with our agent in response to your request.

You provide us directly and with your express consent the data we collect. We will not check the accuracy of your data and you are responsible for ensuring that such data is accurate.

To the extent permitted by law, we also obtain certain data from third parties, i.e. companies related to us, contractual partners, authorities, advisors, services providers or from public accessible resources, such as for example, Homegate, Immostreet Immoscout24, Justimmo, as well as from any other business partners who may introduce you to Neho. The categories of personal data that we receive from third parties about you include in particular information about or relating to your property, contact details, information from our business partners about the use or provision of services by and for you.

Purposes for use of your personal data

We use the personal data we collect to enable you to use Neho, our services or products and to fulfill our contractual or statutory obligations as well as in the context of our legitimate interests in accordance with the applicable law or for the purpose expressly stated at the time of collection. More specifically, we collect your data to satisfy the following purposes:

Evaluate your property;
Handling specific requests (providing to potential buyers information about a property, visit of a property, evaluating the financial capacity to contract a loan, etc.)
Register and manage your account;
Process an order or request from your part;
Develop and maintain our relation with you;
Inform you of any updates, changes to our offers, events or changes to our terms and conditions; privacy statements or requirements relating to announcements on our website;
Organise and perform promotional events or contests, in case of voluntary participation;
Improve your user experience;
Design and improve offers and products;
Manage our marketing and that of third parties, propose special offers, products and services we think you could be interested in (by email, via your personal account, newsletter, telephone, SMS, etc.);
Prevent fraud and abuse;
Evaluate user behaviour - we will keep a record of the articles on our website that you have clicked on and use that information to target advertising on this website relevant to your interests or make our website more intuitive;
Internal business purposes, i.e. training, improvement, audits, new products or services development;
Ensure maintenance of our security.

Your registration and creation of a personal account is required to use our services and products, take advantage of personalised offers and access a secured virtual space. You will need to provide us with certain personal data which is mandatory for registration purposes or use of our services and products. Data not marked as such is not mandatory and you may choose to not communicate it to us. Some data provided to us is used for statistical reasons, to ensure good functioning of Neho, analyse and optimise our Offer. Statistic data is published by us on an anonymous basis and can be consulted by other Neho users.

Recording and processing of telephone calls

By using Neho services and providing your telephone number, you agree to be contacted by telephone by Neho (PropTech Partners SA, acting under various commercial brands). When you contact Neho or are contacted by Neho , certain personal data may be processed, such as the telephone number, the date and time of the call, its duration, as well as the content of the conversation (audio recording) and the information communicated by the user during the call.

Incoming and outgoing calls between Neho and the telephone number(s) provided by you may be recorded, without prior audio notification. You are informed of this practice through the Terms of Use of the website, the Service Agreement and this Privacy Policy. Such data is processed for the purposes of client file management and follow-up, relationship management and support, training, quality assurance, as well as the improvement and development of services and technologies, in particular in the field of artificial intelligence. The processing is based on the performance of pre-contractual or contractual measures, on Neho legitimate interest in ensuring the quality of its services and, where applicable, on the user’s consent.

The recordings are accessible only to authorised persons and are retained for a limited period of time proportionate to the purposes pursued, and are then deleted or anonymised, unless otherwise required by law. The user has the rights provided for by applicable legislation, in accordance with the terms described in this Privacy Policy.

Marketing

If you use Neho and have consented to receive advertising from us or other partner companies, we are entitled to provide you with personalised offers and services on Neho and to contact you by email, telephone, mail, messages, etc. To design such personalised offering or contact you, we will use your personal data including, but not limited to, the way you use Neho. Profiling is carried out as part of product development and optimisation of our offering. This is done as part of our legitimate interest in improving the effectiveness of direct marketing, unless your express consent is required. We usually use AppNexus, GoogleAds, and other tracking & ads tools. To refuse to have your online behaviour tracked for publicity purposes, email us at: [email protected]. If you have agreed to receive marketing communications, you may always opt out at a later date. When you no longer wish to receive our communications, you can unsubscribe from our newsletter at any time by clicking on the link at the end of the email containing the respective newsletter or communication, or by emailing us at: [email protected].

Transfer of your data to third parties

Any transmission, transfer or sale of your data to a third party, who processes it for us or uses it for their own purposes, will be limited and conducted (i) for the purposes set out at section 3, in accordance with the applicable law and/or in the course of our business activities, (ii) if there is a legal obligation to do so, (iii) if it is necessary to enforce our rights, in particular those arising from the contractual relationship, which is of overriding interest to us, or (iv) if you have expressly consented to it.
We transmit the required data within these above mentioned limits, as it follows:

Transfer to potential buyers and/or owners of a property;
Transfer to our partner service providers (banks, IT providers, insurance companies, etc.), that will use your data exclusively for the processing of an order or for their own purposes;
Transfer to subcontractors and other business partners to process and/or store data in accordance with this Privacy Policy;
If you click on integrated offers from our third party partners or use integrated contact forms from them, we can transmit your data in accordance with that offer or contact form, to which you will give your consent. In addition, we transmit your data to third parties if they wish to display personalised advertisements or announcements in connection with our offers. In addition, your data may be transmitted to third parties in case of a joint offer with them;
Transfer to third parties in the course of a transaction or reorganisation, in the event of a sale, merger or other reorganisation of all or part of the assets of our company. In these specific cases your data will be transferred, sold or otherwise shared with such third parties as part of that specific event.

We collaborate with other third parties to process and/or store data in accordance with this Privacy Policy. These may be companies related to PropTech Partners Ltd, (including its subsidiaries or branches), subcontractors, or other third parties. These third parties will only obtain access to your personal data to the extent necessary to perform the tasks we have assigned to them or to achieve the purposes described in this Privacy Policy. We will only engage third parties providing sufficient guarantees, in particular in terms of expertise, reliability and resources, for the implementation of adequate technical and organisational measures, including security of processing. When we share data, to protect the data and to comply with our data protection confidentiality and security standards, we put in place (i) contractual arrangements defining the whole framework (e.g. purpose, nature and duration of the processing, the type of data to be transmitted, processed and stored, the category of individuals concerned, etc.) as well as (ii) security mechanisms.

In addition, in accordance with the applicable data protection legislation, we disclose your data to third parties if this is necessary for the performance of a contract you have concluded with us. For this purpose, if necessary, we disclose data notably to banks, hardware and software suppliers and/or other service providers. These third parties will use your data exclusively for the processing of the contract, but not for any other purpose, unless you have expressly consented to it. You may withdraw your consent at any time

For the avoidance of doubt, you agree that the data you provide on Neho for the purpose of benefiting from services or offers proposed or provided by other users or business partners on Neho may be communicated to them. In particular, if you are a potential buyer, you expressly consent to the communication of your full name, email address and telephone number to the owners of the property you are interested in. As owner of a property, you agree that your personal data and information and documents relating to your property and communicated to us by you may be shared with potential buyers, which are other users of Neho.

If you have been referred to Neho by one of our business partners, you expressly consent to us informing our business partner of your intention to use one of our services or to enter into a transaction offered on or promoted by Neho.

Transfer abroad

We will not transfer any personal data to non-EEA countries without your consent. The servers used by us are located within the European Union. In cases where personal data is transferred to countries that do not offer the same level of protection as within the European Union and you have not expressly agreed to the transfer of your data to those countries by way of your consent, we will ensure that certain contractual obligations under applicable data protection law (including the execution of standard contractual clauses approved by the European Union) are agreed with each service provider, unless we can invoke other legal grounds for the transfer of personal data.

Links and third-party services

If Neho contains services offered by third parties as well as links to other websites operated by third parties, such as Trustpilot, it has no influence whatsoever on such websites and services. Use of these services is subject to the privacy policies of those providers that you are expected to take knowledge of.

Please note third parties (including, for example, Homegate, Immostreet and Immoscout24, other business partners, providers of financial products and services, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. For further information about the cookies used by third parties, please refer to the cookies policies on their website.

We sometimes use third parties' materials and associated services to generate usage statistics, used to display third-party advertising or enable direct access to social networks and other third-party offerings. These third parties are in particular Facebook, Twitter, LinkedIn, etc.

Security

We implement security safeguards as well as appropriate administrative, organisational, and technical measures to protect your data which is under our control against unauthorised access, acquisition, disclosure, destruction, alteration, falsification or accidental loss, misuse, or damage. We continuously review, monitor, and update these security and protection measures in line with technological developments.

Retention of your personal data

We reserve the right to retain your personal data for as long as it is necessary to fulfill our contractual and statutory obligations in accordance with the purposes of processing, or within the scope of processing activities for which we have obtained your consent. Subject to applicable legal minimum retention periods, your personal data will not be retained for longer than necessary with regard to the purposes and compliance obligations contemplated in this Privacy Policy. If we store data based on a contractual relationship with you, this data will remain stored for at least as long as the contractual relationship exists and at the latest for as long as any limitation periods for possible claims by us or any statutory or contractual retention obligations exist.

Your data protection rights

Within the context of the data protection regulations applicable to you and insofar as these regulations contain corresponding provisions, you are entitled to the following rights:

Right to be informed and access: you have the right to be informed whether or not personal data concerning yourself are being processed, and, where that is the case, access your personal data. You have the right to request access and copies of your personal data held by us;
Right to rectification: you have the right to request to rectify inaccurate personal data and to complete incomplete data;
Right to erasure: you have the right to request that we erase your personal data and that your data are no longer processed, if (i) they are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (ii) you withdraw your consent on which the processing is based and where there is no other legal ground for the processing, (iii) you object to the processing on grounds relating to your particular situation, including profiling and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing, (iv) your data have been unlawfully processed, (v) your data have to be erased for compliance with a legal obligation to which the controller is subject. We will erase your personal data, provided we have no other relevant obligation or overriding interest in continuing to retain or process your personal data for a certain period of time. In this case, we store your data exclusively for these purposes and will not process it otherwise;
Right to restrict processing: you have the right to restrict the processing of your data at any time, insofar as we are not under any other obligation to retain and process your data for a certain period of time;
Right to object to processing: you have the right to object to the processing of your personal data, for instance so that it is not used for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing or to decisions based solely on automated processing, including profiling;
Right to data portability: you have the right to request that we transmit the personal data you provided to us in a structured, commonly used and machine-readable format to a third party, where the processing was (i) based on your consent or (ii) carried out by automated means;
Right to withdraw consent: you have the right to withdraw your consent given to process your data at any time;
Right to raise a claim before data protection authorities: you have the right to lodge a complaint with the competent data protection supervisory authority of your place of residence, place of work or place where the violation is alleged to have occurred. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner. You can also enforce your rights in court.

Any request to exercise your rights mentioned above will be processed no later than one month. We reserve the right to apply any applicable legal restrictions, e.g., if we need to retain or process certain data, if we have an overriding interest in the data or if we need the data to enforce our rights. You will be informed in advance if a fee would need to be paid to exercise your rights.

To exercise any of these rights at any time, you can write to us, with proof of your identity, at:

PropTech Partners Ltd,

Data Protection Officer

Rue du Grand-Pré 2A, 1007 Lausanne, Switzerland

You can also communicate your request to us by email at: [email protected], by using, for identification purposes, the email address you registered with us.

How to contact us

For any additional information about our Privacy Policy or requests, you can contact us directly at any time at [email protected].

The contact details of our data protection officer are:

PropTech Partners Ltd,

Data Protection Officer

Rue du Grand-Pré 2A, 1007 Lausanne, Switzerland

Amendment of this Privacy Policy

We reserve the right to modify this Privacy Policy, as needed, at any time. Registered users will be informed of any material changes to the data protection declaration by e-mail to the e-mail address given at registration or by means of a corresponding notice placed appropriately after logging into their user account. Changes to this Privacy Policy are effective when they are posted on Neho. You are advised to review this Privacy Policy periodically to be informed about the latest developments concerning your personal data and how you can exercise your rights.

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