Privacy Policy.

The purpose of this privacy policy is to inform the Users of the Platform developed by VISUS TECHNOLOGY of the ways in which their personal data is collected, processed and used, and of their rights regarding the protection of personal data under the applicable provisions, in particular French Law 78-17 of January 6, 1978 on data processing, files and freedoms, known as the "Informatique et libertés" law, and the European regulation on the protection of personal data 2016/679, known as the "GDPR".

This privacy policy governs all processing carried out by VISUS TECHNOLOGY, a simplified joint-stock company (Société par Actions Simplifiée) with a share capital of €3,790.00, registered with the Marseille Trade and Companies Register under number 913 932 653, whose registered office is located at 132 boulevard Michelet - 13008 MARSEILLE (hereinafter "LYCAON DATA"), acting as data controller within the meaning of the GDPR.

LYCAON DATA's personal data processing policy can be consulted directly through the Platform published online by LYCAON DATA. Validation of the Account by the User constitutes acknowledgment that they have been informed of the conditions under which their personal data is processed as set out herein, and that they accept them without reservation.

Article 1 - Definitions

The terms below have the following definitions:

• "Subscription": means the commitment entered into by the client when creating their account, which may be monthly or annual.
• "Client": means the natural or legal person who has created an account on the platform created and published online by LYCAON DATA.
• "Account": means the account created by the Client and/or their users upon first access to the platform.
• "Terms of Use" or "ToU": means this document establishing the rights and obligations of each Party in connection with the use of an account.
• "Data": means the data that may be processed in connection with the use of the Platform.
• "Credentials": means the usernames and passwords allowing Users to access the platform.
• "Party": means either LYCAON DATA or the User, without distinction.
• "Platform": means the website published online by LYCAON DATA for subscribing to plans and ordering services provided by LYCAON DATA.
• "Provider": means LYCAON DATA.
• "Service(s)": means the services marketed by LYCAON DATA through the Platform.
• "User": means any natural or legal person holding an account allowing them to use the services offered by LYCAON DATA through the platform.

Article 2 - Data processed by Lycaon Data

In connection with the use of the Platform, LYCAON DATA collects and processes personal data relating to Clients and Users.

LYCAON DATA acts as data controller within the meaning of the GDPR for the personal data referred to in this privacy policy, relating to the creation of the Account and the use of the Platform by Users and the Client.

2.1 Categories of data processed

The categories of data processed, in order to offer Users the best possible service, are the following:

• The contact details of Clients and Users as listed in the ToU when creating the Account, namely: last name, first name, company name, position within the company, telephone number and e-mail address.
• The Client's professional information, namely: the name of their organization and their role within that organization.
• Geolocation data, namely: the data used to determine the location covered by the study report ordered by the Client through the Platform.
• Payment-related data, excluding bank details, namely: the amount invoiced, payment histories and invoices.
• Data relating to records of communications and correspondence, in particular when placing orders: this data consists of the dates, times and contents of the reports ordered through the LYCAON DATA Platform or in the event of an exchange with any member of the support team set up by LYCAON DATA at the e-mail address tech@lycaon-data.com.
• Identification data of the device used to access the Platform, in particular the IP address on which the Platform was installed.

2.2 Legal basis for data processing

The collection and processing of the data referred to in 2.1 are justified by and based on:

• The legitimate interest of LYCAON DATA, which includes in particular LYCAON DATA's commercial interests and notably the provision of a service consistent with its commercial policy.
• The performance of the contract with respect to the collection of data relating to the creation of the various Accounts, Data relating to orders for study reports and real estate analysis, including the location data of the studies and analysis, as well as data relating to financial information and data, excluding the Client's bank details, which are not processed by LYCAON DATA.
• The explicit consent of Users and/or the Client for the processing of data relating to their identity, status and professional data, as well as for the sending of notifications, newsletters and promotional and marketing communications.

Should a User or a Client refuse to provide personal data governed by this privacy policy, this could prevent LYCAON DATA from providing the services it intends to provide through the Platform and impair the operation of the Account created by the Client and/or the User on the Platform.

2.3 Data collection

Data relating to Users is collected by LYCAON DATA directly from the User when their account connects to the Platform.

2.4 Purpose of processing User Data

User Data is processed to enable use of the Platform, such as, in particular, the identification and location of a real estate market in order to provide a detailed analysis to the Client in accordance with the Subscription taken out as part of the use of the Platform developed and published online by LYCAON DATA.

This data is also processed for archiving for evidentiary purposes, for compiling audience and traffic statistics, for distributing commercial and marketing content, and for carrying out commercial prospecting operations.

In summary, personal data is processed for one of the following purposes:

• Managing the Client's and/or User's Account created on the Platform;
• Optimizing the Platform in order to adapt it as closely as possible to the needs of Clients and Users;
• Providing support in searching for information and producing reports on a given real estate market at the request of the Client or a User;
• Regularly informing Clients and Users about the services and any developments in the features of the Platform developed by LYCAON DATA.

2.5 Retention period of User and/or Client Data

In connection with the publication and use of the Application, Client and User data will be retained for different periods, namely:

• Client and User Data such as their contact details, information about their organization and their status within that organization will be kept in an active database for the entire period of validity of the Account providing access to the Application, and then for a period of three (3) years after the end of that period, for evidentiary purposes, unless a different legal retention obligation applies.
• Financial and accounting data, which, as a reminder, does not include the bank details of clients and users, which are not processed by LYCAON DATA, will be retained for a period of ten years in accordance with the applicable French regulations in this area.

Article 3 - Cookies

LYCAON DATA may collect and process data relating to the device on which the User accesses the Platform. This data is not personally identifiable.

In this context, LYCAON DATA may use cookies, or similar technologies, for the following purposes:

• Authenticating Users;
• Remembering the User's preferences and settings;
• Designing advertising campaigns and evaluating the effectiveness of such advertising campaigns;
• Analyzing trends on the Platform and understanding the behavior and interests of Users in connection with the purchase of the services marketed through the Platform.

Statistical cookies, provided they comply with the CNIL guidelines and recommendations of September 17, 2020, may be used without being subject to the collection of the user's consent.

Cookies and trackers installed while browsing the Platform expire after a period of twelve (12) months from the last visit to the Platform.

Article 4 - Data circulation

LYCAON DATA uses the aforementioned data only for the purposes set out in this privacy policy.

The data is not used for any other purpose, is not transmitted to third parties, and is confidential.

LYCAON DATA may nevertheless use technical service providers for purposes including, but not limited to, hosting the Platform it has developed on shared server infrastructures and routing e-mails or content.

Where applicable, the data may be accessible to the service provider, strictly within the scope of the service provided.

In this respect, LYCAON DATA undertakes to implement all necessary measures to protect the personal data of Users and Clients in connection with the service provider's access to the personal data referred to herein.

Should LYCAON DATA transfer personal data to a third country, in particular where its servers hosting the data or the operators handling calls are located outside the European Union, LYCAON DATA undertakes to ensure that the contracts entered into with the service providers concerned include the standard contractual clauses established by the European Commission to guarantee the security and confidentiality of the transferred data.

Article 5 - Security

LYCAON DATA processes the collected data only in strict compliance with the legislation in force, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the GDPR.

In this respect, LYCAON DATA undertakes in particular to:

• Not use the data for purposes other than those specified herein or in the general terms and conditions appearing on the Platform published online by LYCAON DATA;
• Not disclose the data to third parties, whether private or public persons, natural or legal, other than the aforementioned technical service providers;
• Inform Clients and users of any breach or security flaw having direct or indirect consequences for the data and/or likely to accidentally result in the disclosure of, or unauthorized access to, Data;
• Ensure that members of its staff who access Client and User Data are bound by a confidentiality obligation;
• Ensure that the servers on which Client and User Data is hosted are located within the territory of the European Union;
• Ensure that any subcontractors that LYCAON DATA uses or may use in the course of its business comply with all the provisions of the GDPR and are subject to obligations identical to those incumbent on it under this document with regard to data confidentiality and security;
• Assist Clients and Users, upon request, in handling requests to exercise the rights of data subjects concerned by the data processing;
• Delete or return to the Client, at the Client's choice, all the Data detailed in this privacy policy at the end of the contractual relationship, without retaining a copy.

Article 6 - Rights of data subjects

In accordance with the French "informatique et libertés" law of January 6, 1978 and Regulation (EU) 2016/679 of April 27, 2016, known as the "GDPR", the persons concerned by the processing of personal data referred to in this privacy policy have an individual right of access, rectification, erasure, restriction, objection and portability of the data concerning them.

The rights to object to or restrict processing may only be exercised subject to the conditions provided for by the regulations in force, in particular Articles 17 and 21 of the GDPR, with respect to data processing justified by a legitimate interest or by the necessity of performing a contract.

For the data referred to in Article 2 hereof, requests to exercise the aforementioned rights must be addressed to LYCAON DATA, in its capacity as data controller.

The person making the request must specify their last name, first name, postal address and e-mail address, under the following conditions:

• Either by post to the following address: 132 Boulevard Michelet - 13008 MARSEILLE, LYCAON DATA.
• Or by e-mail, to the following e-mail address: tech@lycaon-data.com.

The persons concerned by the processing provided for herein also have the right to lodge complaints with the competent supervisory authority regarding the exercise of the aforementioned rights.

Article 7 - Marketing and promotional communications

As stated in its ToU, LYCAON DATA reserves the right to send marketing and promotional communications to the e-mail address and/or telephone number provided by the Client and Users where the latter have authorized LYCAON DATA directly or on the basis of tacit consent. Marketing or promotional communications may be personalized on the basis of information collected in connection with the Client's and Users' use of the Platform.

If Users and/or Clients no longer wish to receive such communications, they may unsubscribe via the link at the bottom of any of these communications, in the settings portal on the Platform, or directly at the following e-mail address: tech@lycaon-data.com.

Article 8 - Changes to the privacy policy

LYCAON DATA reserves the right to amend this privacy policy, either to strengthen the protection of privacy and the transparency it wishes to provide to Clients, or in the event of a new or strengthened legal or regulatory obligation.

Article 9 - Dispute resolution

Disputes relating to the processing of personal data are resolved through support at the following e-mail address: tech@lycaon-data.com.

If, after contacting LYCAON DATA, the Client or User considers that their rights are not being respected, the Client or User may submit a complaint to the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr.