PERSONAL DATA PROTECTION POLICY

This policy for the protection of personal data describes what type of personal data is collected, the purposes as well as the time frame for which it is kept.

ZENITY 1 is committed to ensuring that the collection and processing of your data, on the site www.pureness-properties.com is carried out in compliance with the General Data Protection Regulation (GDPR) and French Law No. 78-17 “Information Technology and Liberties” of January 6, 1978.

This policy may be modified, completed or updated specifically to be in compliance with any legislative, regulatory, jurisprudential or technical developments. Before using the site, you should refer to the latest version of the policy. For any information regarding the protection of personal data, you may also access the website for the French Commission on Information Technology and Liberties (Commission Informatique et Liberté) www.cnil.fr

1. WHO COLLECTS PERSONAL DATA (IDENTITY OF THE DATA PROCESSOR)?

Your personal data is collected by ZENITY 1, the registered office of which is located at: 3 Place du Molard 1204 GENEVE

2. USE OF PERSONAL DATA

"Personal data" means any information concerning an identified natural person or who may be directly or indirectly identified by reference to an identification number or any other information specific to said person. When ZENITY 1 collects your personal data, this collection is carried out in an honest and transparent manner through information notices or by sending you this Policy. Personal data is the information pertaining to you that allows us to identify you, such as your first name, last name, email address, telephone number, postal address, login name, password of your account and any other personal data useful for the purposes defined below. Personal data is collected through our different forms (contact form, downloading white papers, landing page, etc.). These forms limit the collection of personal data to what is strictly necessary (minimization of data) and specifically indicates:

• The objectives for collecting data (purposes)
• If this data is required or optional for handling your request
• Who may be made aware of it (only ZENITY 1 Group companies in principle, unless otherwise specified on the form that a transfer to a third party is necessary for its purposes);
• Your rights relative to information technology and liberties and means of exercising them with ZENITY 1.

3. PURPOSES FOR PROCESSING PERSONAL DATA

ZENITY 1 is committed to only collecting personal data that is appropriate, pertinent and not excessive in terms of the purposes for which it is collected, namely :

• Handling your requests for contact, requests for information,
• Sending you a brochure for a property development or a white paper (e.g. Heritage Guide)
• Subject to your agreement, sending you personalized ZENITY 1 offers (new real estate developments, commercial promotions/offers, etc.)

4. RECIPIENTS AND SUBCONTRACTING OF PERSONAL DATA

In principle, the ZENITY 1 Group is the only recipient of the data collected. ZENITY 1 sends your personal data to a third party when you have given your prior agreement to share this information (e.g. for a special promotional event).

5. TIME FRAME FOR KEEPING PERSONAL DATA

ZENITY 1 manages and keeps personal data in a secured environment for the time necessary to carry out the purposes for which it has been collected. Your electronic identification data and cookies are kept for a time frame of 12 months from the time they are collected.

6. CONDITIONS FOR EXERCISING YOUR RIGHTS RELATING TO YOUR PERSONAL DATA UNDER REGULATIONS

You are informed that you have the right to access, transfer, rectify, and erase your data. For additional information or to exercise your information technology and liberties rights regarding personal data managed by ZENITY 1, you may contact the data protection officer.

• By email at the following address: info@purenessproperties.com.
• or by letter at the following postal address : ZENITY 1 SARL, ATTN: Data Protection Officer, 3 Place du Molard 1204 GENEVE

Requests must include a copy of a valid identity document.

7. POLICY FOR PERSONAL DATA REGARDING MINORS

The site is not intended for minors. However, access to the site is not reserved to adults because it does not contain content prohibited to minors younger than 18 years old. The forms on the site do not gather information from minors. If a minor’s information is gathered by the site, their legal representative has the possibility of contacting the data protection officer to rectify, modify or erase this information (see Paragraph 6 - Conditions for Exercising Your Rights Relating to Your Personal Data).

8. SECURITY AND CONFIDENTIALITY

ZENITY 1 takes all necessary measures to ensure the confidentiality and security of users’ personal data and to prevent this data being damaged, erased or unauthorized third parties having access to it. The ZENITY 1 information technology systems have a software protection device. Data collected on the site is backed up. Access to personal data is strictly limited to authorized individuals based on their capacities and who are bound by an obligation of confidentiality.

9. COOKIES

A cookie is a small text file that may be placed on your device when you visit a website. A cookie allows its issuer to identify the device on which it is registered, during the validity or registration period for this cookie. There are several categories of cookies:

• Authentication cookies
• Preference cookies
• Statistical and site usage measurement cookies

The www.pureness-properties.com site uses authentication and statistical and site usage measurement cookies.

Authentication cookies

This cookie is installed once you connect to your profile (client, partner, ambassador). The next time you visit the Site, the cookie will identify you as an existing user, which will enable you to connect without entering your login identification. We use these cookies to recognize you and to show you the correct information and to personalize your use. If you prefer not to allow cookies, you may erase them by changing your web browser configuration. We draw your attention to the fact that limiting the Site’s use of cookies may lead to a reduced usage of the Site. At any time, you may deactivate these cookies. You may accept or refuse them on a case-by-case basis or systematically refuse them once and for all.

Statistical and site usage measurement cookies

These are cookies that allow us to know the use and performance of the site regarding account activity, to establish statistics, the traffic volume and the use of various elements of our site (content visited, navigation pathway) allowing us to improve the relevance and usability of our services (the pages and sections that are most frequently viewed, the articles that are read the most, etc.). Cookies also allow us to count the number of visitors to a page. These cookies are from Google Analytics.