Definition and Nature of Personal Data

We may ask you to provide personal data, which identifies an individual directly or indirectly, in two situations:

• If you are interested in (i) subscribing to our real estate credit products (mortgage, loan insurance, or credit refinancing) and wish to be assisted in negotiating and obtaining your mortgage from Noelse’s partner institutions, and/or (ii) subscribing to products offered by our subsidiaries (hereinafter “Clients”).
• If you apply for a position within our company, by any means (hereinafter “Candidates”).

In this context, we collect the following data:

Data Collection for Clients

For the proper execution of our services, whether during an appointment with one of our advisors in an agency or through our website www.noelse.com and/or the web and mobile application “Noelse” (hereinafter “Platform”), we collect the following data:

• Identification information: name, first name, email address, telephone number, postal address.
• Real estate project information: household income level, family situation, current loans, amount of personal contribution, current real estate situation.
• Any information you choose to provide.

Data Collection for Candidates

When you apply for a position, we collect the following data:

• Identification information: name, first name, photograph, gender, nationality, date and place of birth, email address, postal address, telephone number.
• Education and career information: diplomas and training certificates, languages spoken, resume, cover letter.
• Recruitment process information: interview reports, recommendation letters, evaluations.
• Any information you choose to provide, including marital status, driver’s license, disability status.

Automatic Collection of Connection Data

If you use the Platform, we may collect personal data automatically through the tools and services offered on the Platform:

• Usage information: interactions with the Platform, pages viewed, links clicked.
• Connection information: IP address, connection dates and times, equipment and software data, unique identifiers, crash data.

Purpose of this Charter

This charter informs you about how we collect and process your personal data, in strict compliance with your rights. We comply with the GDPR.

Data Controller

For real estate credit, loan insurance, or credit refinancing, the data controller is Noelse. For professional loans or mortgages for non-residents, data is processed jointly by our subsidiaries.

Collection and Processing of Personal Data

Data is collected and processed for the following purposes:

• Manage access to the Platform and services.
• Manage client relationships.
• Create a file of registered members, users, clients, and prospects.
• Send newsletters and informative messages.
• Send advertisements.
• Develop usage statistics.
• Manage user reviews.
• Manage disputes.
• Comply with legal obligations.
• Manage job applications.

Recipients of Collected Data

Your data may be accessed by our staff, auditors, subcontractors, and partner subsidiaries. Public bodies may also receive data to comply with legal obligations.

Transfer of Personal Data

Your data will not be sold or rented to third parties. We may share anonymized, aggregated data.

Data Retention Period

Data is retained as long as necessary for our relationship, or as required by law (e.g., 5 years for contract data). Job application data is deleted after the process, unless you authorize retention.

Security

We take appropriate measures to protect your data from unauthorized access, alteration, or destruction.

Hosting

Your data is stored on OVH SAS servers in France. No data is transferred outside the EU.

Cookies

We use technical, social media, and advertising cookies. You can manage your cookie preferences in your browser settings. We also use Google Analytics.

Legal Basis for Data Processing

Data collection is necessary for the execution of our services and compliance with legal obligations. We obtain your consent for newsletters and advertising.

Access to Your Personal Data

You have the right to access, rectify, and delete your data.

Data Portability

You have the right to data portability for data you have actively provided.

Complaints

You can lodge a complaint with a supervisory authority like the CNIL in France.

Data Breach Notification

We will notify you of any data breaches that pose a high risk to your rights.

Changes

We may modify this policy at any time. Your continued use of our services constitutes acceptance of the changes.

Effective Date

This policy is effective as of July 2, 2020.