Privacy Policy

Introduction

At Lifull Connect we understand the importance of personal data for our users and customers. We are committed to your privacy and data protection rights.

This Privacy Policy describes the processing of personal information provided or collected on the websites and applications (“the Platform”) in which this Privacy Policy is published or redirected to. This Privacy Policy is in accordance with the legislation in force in the places where we operate. In some cases, we may include additional data privacy notices specific to certain regions.

This policy explains the purposes for which your personal data may be processed by the Platform. Please read this carefully. By using the Platform or any service derived from it, you agree you have been informed about the use we do of personal data collected.

This policy is not applicable to other groups of data subjects not included on it.

Who is the data controller?

Lifull Connect is formed by different companies and brands. This privacy policy is issued on behalf of the group of companies which forms part of Lifull Connect, so when we mention “Lifull Connect”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company of Lifull Connect responsible for processing your data. The Data Controller will vary depending on the country and brand providing the services or collecting the data. You can find the corresponding Data Controller in our portals Legal Notice or our aggregators Legal Notice.

Our brands are listed here: here.

If you have any questions regarding this privacy policy, you can contact our Data Protection Officer (DPO) here.

Personal data collected

Lifull Connect will access to the following personal data:

a) Personal data provided voluntarily by users:

Name
Telephone number
Preferences
Email address
Type of alerts to receive
Favourite properties
Geolocation, only if the user activates this option on his/her device.
Any personal data sent directly to Lifull Connect

b) Personal data provided voluntarily by agents developers or professionals:

Full Name
Full address/business registered address
Phone number
Email address
Billing information
Other contact details (Whatsapp id, Line id, Skype id, Messenger id, Wechat id and/or website url).
Geolocation, only if the agent activates this option on his/her device.
Any personal data sent directly to Lifull Connect

c) Personal data provided voluntarily by owners:

Name
Telephone number
Email address
Property details (when publishing an Ad): total or partial address, pictures/videos, description and characteristics, contact details (Whatsapp id, Line id, Skype id, Messenger id, Wechat id) and/or website url.

d) Personal data automatically collected by Lifull Connect:

As you interact with our website, we may automatically collect Technical Data about your equipment (IP address, device details) , browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies:

Device data: operating system, version or unique ids. In example, the name of the movil network used by the device.
Geolocation data: Only in case you authorize its use. Geolocation can be determined by IP address, GPS, Wi-Fi access points and movil services towers. In any case, it will be used to enable some features which are needed to provide the services and in some cases to provide ads related to your location.
Navigation data: information about your activity in our websites, whcih may include websites from where you access our websites, searches done, date and hour of the visits, interaction with ads, alerts created and visit duration. This information will allow us to suggest ads or products similar to those you were looking for and customized ads shown to you.

In case you used a social network profile to (like Facebook or Google) to create an account in our websites:

This is totally volunteer and will imply that additionally to your user name into the corresponding social network we will be able to access other personal data under your profile, like your address, name, identifier, gender, picture, contacts, groups, preferences and hobbies and other data, always according to your privacy settings on that network. In any case we will only access to those data you have authorized those entities to share with us and only for the same purposes as if you register directly with us. Information about this will be provided to you before registering through this option, but we recommend you to read carefully Terms and Conditions of those platforms before giving authorization to us. Without minimum information we cannot create a user account.

Register into our services is totally voluntary but for a), b) and c) some fields are mandatory and should be provided in order to provide our services. If not provided we will not be able to provide the services. Those fields usually be marked with an asterisk or a warning will inform about this.

Purposes

Your personal data will be processed for the purposes described in this policy This policy is based on the applicable law, choices and controls that are applicable to you. We may use the information collected from you, or from devices associated with you, to:

register you as a user and create your account.
provide our services, according to the Legal Notice and applicable Terms & Conditions or those that may be established in the future with each of the users.
respond to consultations or information requests made by the users/agents/owners.
upload ads from agents/owners and publish them on our websites.
keep you informed about our services, activities, projects, updates and new website(s) or application(s) features by means of notices/newsletters sent by email and/or other electronic means.
personalize content and experiences. The information you provide will allow us to generate user profiles in order to offer you ads, products or services from Lifull Connect or our partners in a personalised manner.
operate, understand, optimize, develop, or improve our websites, products, services and operations.
detect, investigate, and prevent activities that may violate our policies or are considered illegal.
manage your participation in a contest or prize.
publish your comments (where applicable) if you are a registered user.

Legal basis

Lifull Connect may process your personal data on any of the following legal grounds:

If it is necessary in connection with contractual obligations: managing the accounts and provide our services. We will understand you consent has been given.
To comply with a legal obligation applicable to Lifull Connect.
Based on your given consent to keep you informed about Lifull Connect products and services and to send communications of your interest using the contact details provided.

Sharing your information with other entities

Lifull Connect will only share your personal data with other entities in the following cases:

Owners, advertisers and agents
Portals or platforms that publish ads
When you request a service and/or more information through the contact form made available for this purpose.
If you post an add on our platforms your contact details (provided to us) as well as information about the property or product included on the add will be published and all our visitors and users will have access to it.
For the rest of purposes your personal data will not be shared, sold or disclosed. Nevertheless, your personal data might be communicated to Regulatory authorities or other third parties as per the applicable law.
In addition, and where applicable if you request the portability of your data, we will communicate them to the recipient that you indicate

Besides, depending on the purpose of collection your personal data may be accessed by:

Third-party service providers that may process personal data as per the instructions of Lifull Connect, upon applying the appropriate security measures necessary to ensure that we may share personal data under the enforceable privacy law. We rely, among others and by way of example, on third parties providers for hosting data, sending electronic communications or for general support and development.
Other companies of the Lifull Connect group, according to our legitimate interest, for internal management issues, subject to the applicable privacy law.

Use of your personal data by Google

Google may process your personal information, provided that you give your consent to do so through our web pages. For more information https://policies.google.com/technologies/partner-sites

To whom do we give access to your personal information?

Depending on the purpose of collection your personal data may be accessed by:

Staff authorized by Lifull Connect or its representatives acting on behalf of Lifull Connect, subject to the applicable privacy law.
Third-party service providers that may process personal data as per the instructions of Lifull Connect, upon applying the appropriate security measures necessary to ensure that we may share personal data under the enforceable privacy law. We rely, among others and by way of example, on third parties providers for hosting data, sending electronic communications or for general support and development.

Your rights

You may exercise the following rights, always according to the applicable data protection law:

The right to request access to your personal data: you can enquire Lifull Connect about the processing of your personal data and access those
The right to rectify your personal data in case they are inaccurate or incompleted
The right to withdraw your consent
Filing a complaint with the corresponding Data Protection Authority of your Country and/or region
The right to request a restriction of the processing of your personal data
The right to object the processing of your personal data
The right not to be subject to a decision based solely on the automated processing of your personal data

In any event, all personal data linked to the user’s account, as well as any information and/or content included in the corresponding profile will be removed at the same time the user exercises the right of erasure. Furthermore, should the user exercise the right of erasure in connection with personal data necessary to provide the services on the Platform, Lifull Connect will be forced to terminate its relationship with the user and shall therefore unsubscribe the user, who will not be entitled to file any claim whatsoever in this respect. Erasure will be executed without prejudice to the obligation of the blocking set out in some Data Protection regulation(s) applicable.

Users may exercise their rights by sending a written communication to the owner of the website indicated in our Legal Notice of Aggregators or Legal Notice of Portals or through the contact information we have at the bottom of each of our websites.

Important: Please note that some rights included above may not be applicable to you due to applicable data protection legislation. In that case, if you excercise a right which is not applicable we will not be able to proceed with it. Check your applicable rights beforehand in order to avoid any inconvenience.

How do we protect your personal data?

Lifull Connect has security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, or inappropriately altered or disclosed. In addition, we limit access to your personal information to those third parties that need to process that information for business reasons only. In these cases we make sure that your personal information are processed following our instructions, and protected by the duty of confidentiality.
To protect you we have put in place procedures to detect any security breach and we will notify you and any applicable privacy regulator about any breach as appropriate and in accordance with our legal applicable obligations. However, despite the diligent implementation of such measures, the user must know that Internet security measures are not impregnable.

How long will we keep your personal data?

You may exercise the following rights, always according to the applicable data protection law:

The right to request access to your personal data: you can enquire Lifull Connect about the processing of your personal data and access those
The right to erasure your personal data
The right to rectify your personal data in case they are inaccurate or incompleted
The right to withdraw your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal
Filing a complaint with the corresponding Data Protection Authority of your Country and/or region
The right of portability of the personal data: if you wish to have your personal data processed by a different data controller, Lifull Connect will enable the transfer of your personal data to the new data controller indicated
The right to request a restriction of the processing of your personal data
The right to object the processing of your personal data
The right not to be subject to a decision based solely on the automated processing of your personal data

Users may exercise their rights by sending a written communication to Lifull Connect’s corporate address indicated on our portals Legal Notice or our aggregators Legal Notice or using this form, including upon request a photocopy of the ID card or equivalent identification document.

Confidenciality

Professionals working with Lifull Connect who may intervene in any way in the services provided to the user undertake not to disclose or use the information they may gain access to. In any event, any information provided by the user will be considered confidential and may not be used for purposes other than the management of the user’s account and/or the services engaged with Lifull Connect (if any). In this regard, we undertake not to disclose information regarding the user unless it is legally required.

International transfers

Lifull Connect operates globally, therefore, in some cases it will be necessary to transfer your personal data to third countries for operational purposes. We may transfer your personal data to:

Lifull Connect group entities you can find in our Legal Notice
Service providers we need to provide your data with (Europe)

In any case, we will only transfer the minimum required data in order to comply with the purposes indicated in this privacy policy.

If your data is transfered outside Canada we will ensure that adequate guarantees are provided in order to protect your personal data such as standard contractual clauses, Binding Corporate Rules (BCR), codes of conduct or similar legal mechanisms which allow us to transfer your personal data with an adequate level of protection. You can request additional information about the mechanisms used to our Data Protection Officer, even a copy of the contractual clauses used.

Special categories of data or sensitive data

We will neither collect nor process any personal data which may be especially sensitive or included in the special category of user personal data, unless said data have been provided explicitly. Special personal data categories include information related to race/ethnicity, political opinions, religious, philosophical or similar beliefs, membership in trade unions, genetic data, biometric data used for exclusive purposes of identification of an individual, health data, sexual life or sexual orientation.

Policy regarding the use of the Platform by children

The Platform is not designed for or addressed to children under the legal age established in your country, users under the legal age established cannot use it without the authorization of their parents or legal guardians. In this regard, we do not collect information from persons under said age deliberately. In any event, if any parents or legal guardians believe that their children have provided us with personal data without their consent, they should let us know by writing us through our DPO Contact form: https://www.lifullconnect.com/dpo-contact-form/

Direct marketing

We undertake not to use your personal data for direct marketing purposes without your express prior consent as applicable in your country of residence.

lf, at any time, you wish to stop receiving commercial or promotionaI information from Lifull Connect or third parties, you can unsubscribe directly from marketing campaigns free of charge, by contacting us on here. or by pressing the opt-out button in your preference panel, within the user’s account. You may also use the opt-out procedure provided in any promotional message received from Lifull Connect.

Please note that, even if you decide not to subscribe or if you decide to unsubscribe from receiving promotional emails or newsletters, we may need to continue contacting you in connection with important information of a non-commercial nature, such as problem solving, inactivity or lack of use, detection and prevention of errors or, in general, compliance with the Legal Notice and operational procedures of the Platform.

Social Media

Lifull Connect Group informs you that, when you request to follow us on our profiles or social media pages, we will process your personal data (always in accordance with your privacy settings on the corresponding social network and its privacy policy) in order to include you as one of our followers and interact with you.

Our connection, based on your settings, may be posted on your profile and wall so that your friends can receive notifications about it. We, by default, will only be able to see your name and your profile picture. That is, we will not have access to additional personal details or your social network activity unless you have given access to “everyone” or your profile is completely public.

We will inform you through social media about our activities, events, news, products or services offered by Lifull Connect Group or our partners. If you no longer wish to receive this information, just click on “unfollow”. If you have additional questions, please do not hesitate to contact us.

We inform you that it is possible that your comments are published outside the platform of the social network or using other tools than TWITTER API or FACEBOOK API. To do so we will have your prior consent, without modifying, translating or deleting any part of the content of the message. In addition, we will always refer to your full username. Once that content of the social network has been deleted, or modified, we will make every effort to remove or modify it within 24 hours provided that we have been notified.

Lifull Connect Group will use third parties (Google Ads, Facebook Ads, etc.) to show you information or advertising related to its services or products, remarket and / or create similar audiences to those users who register to obtain additional information about Lifull Connect Group products on social media. These providers will only process the data on behalf of Lifull Connect Group and in an encrypted manner. You will be able to disable and control the use of cookies and similar tools as indicated in their privacy policies.

Lifull Connect Group will not be able to access, modify or cancel your personal data from social media, only the corresponding social network can do this. If you need to know more about how social media process your data, you can visit their privacy policy here:

Lifull Connect Group allows all users to comment freely, but in order to maintain proper social media functionality and preserve a pleasant atmosphere, some basic rules of participation must be followed. In this regard, we reserve the right to remove your comments, images and any other content from this page if:

Inappropriate language is used, such as vulgarities, insults, profanity, incitement to hatred or anything else that is considered offensive.

Any person, brand, organization or social group is harassed or threatened.

Fundamental rights or freedom are threatened

The right to honour, personal and family privacy or the right to one’s own image is infringed.

Your comment contains personal data of third parties or is protected by any industrial or intellectual property right.

Your comment contains viruses or any component that may damage or impede the normal functioning of the networks, systems or computer devices of Lifull Connect Group or third parties.

It is used for commercial or promotional purposes, is not related to the publication or activities of Lifull Connect Group and is published repeatedly (spam).

It is used for purposes related to illegal activities.

In this regard, we can block users who violate the above rules, so you will no longer be able to comment. Lifull Connect Group reserves the right to inform the competent authorities, including related data to find the author of any comment that violates current legislation.

Social Media offer various functionalities that allow users to interact with other users, such as making comments or giving opinions about the comments of others. You must understand that all these interactions will be public depending on your settings and may be seen by third parties who are registered in Social Networks and we cannot control the use made by other users of Social Networks of this information. For example, sending unsolicited messages. Therefore, we are not responsible for such use by third parties.

Facebook Fanpage

At Lifull Connect Group, we use Facebook pages for which we are jointly responsible together with Facebook Ireland Limited or any of its subsequent business names (hereinafter FB):

As joint controllers, we only analyse the use made of our FB website. FB provides you with the information related to such treatment through its privacy policy that you can find here:

https://www.facebook.com/privacy/explanation

FB also provides the essential part of our agreement as co-controllers and which you can currently find under this link:

https://www.facebook.com/legal/terms/page_controller_addendum

As part of the FB statistics service, we only receive anonymized statistical data and do not have access to personal data processed by FB for this service. The legal basis for the processing of anonymised statistical data is the legitimate interest we have in obtaining further information about the interests of visitors to our FB pages.

Contests and sweepstakes

When you participate in sweepstakes or contests organized on our profiles or social media pages, they will be regulated by the legal bases or general conditions of the contest or sweepstakes.

In these cases, the personal data you provide will be processed in order to manage your participation in the corresponding contest or draw. In order to participate, we need you to provide at least your contact details. These data will be mandatory if you want to participate and will be indicated in the form or the conditions of the contest or draw.

We will not share your data with third parties except:

By legal obligation

In the case of the winners, their data (name and surname) will be made public in accordance with their consent or with the legitimate interests of Lifull Connect Group, in guaranteeing the transparency of the contest or draw, all depending on the applicable legislation in each specific country.

In those cases where the promoter of the prize or gift is a third party and it is necessary that the prize be sent directly by the promoter, your data will be communicated to the promoter. In this case we will inform you in advance of such communication.

The data will be kept for the duration of the contest or draw and subsequently according to the legally established deadlines. As an example, in some countries we may keep it for 4 years for tax reasons.

Links to other websites, applications or platforms

The Platform includes links to other types of websites, applications or platforms which we consider may be potentially informational and useful to you. However, keep in mind that we neither support nor recommend the content and/or services provided therein and that we are not liable for their privacy policies or terms of use. In this respect, we recommend that you read the privacy policies of any websites you may visit. Remember that the provisions herein are only applicable to personal data collected and/or processed by Lifull Connect.

Amendments to Privacy policy

We will only use your personal data as set forth in the Privacy Policy which is applicable at the time of collection of your personal data. Lifull Connect reserves the right to amend this Privacy Policy at any time by publishing said amendments on our Platform. Therefore, we recommend that you check the Privacy Policy every time you enter the Platform. You may determine if such revision has taken place by referring to the date on which this policy was last updated. The use of the Platform after the changes implies the acceptance of them.

If we decide at any time to use personal data for purposes other than as stated at the time of collection, we will communicate said decision to you by email, provided that we have your email address. In case your consent is needed you will have the chance to authorize or not those new purposes.

Should any of the clauses in this Privacy Policy be eliminated or considered null and void, this will not affect the rest of the terms and conditions, which shall remain fully valid and effective under regulations in force from time to time.

Last Update Date

27 September 2023