Privacy Policy
Dernière modification: 15th October 2024
Introduction
At Trackstone, protecting your personal data is a priority and one of our core values.
The purpose of this privacy policy is to inform you about how we process your personal data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").
1. Who are we?
Trackstone is a simplified joint-stock company (société par actions simplifiée) with share capital of €1,116.65, registered office at 19 Quai de rive neuve, 13007 Marseille, registered in the Bobigny Trade and Companies Register under number 893 431 585, represented by Mr. Florent Vaudelin in his capacity as Chairman ("Trackstone").
Trackstone has developed a platform (the "Platform"), accessible at https://www.trackstone.fr/ (the "Site"), enabling its users to search for, buy, and sell tenanted real estate properties for rental investment.
You can contact Trackstone by email at: contact@trackstone.fr.
2. What is personal data?
When you use the Trackstone website (the "Site"), we may ask you to provide personal data about yourself in order to use our services.
Personal data means any information relating to an identified or identifiable natural person — for example, your name, postal or email address, or indirectly, a user identifier, IP address, browsing data, etc.
3. Who is the data controller?
The data controller is Trackstone, a simplified joint-stock company registered in the Paris Trade and Companies Register under number 893 431 585, with its registered office at 19 Quai de rive neuve, 13007 Marseille (hereinafter "we" or "us").
4. What data do we collect and under what circumstances?
As part of our business, we collect certain information about you. This information falls into the following categories:
- Identification data (including your name, email address, postal address, and phone number)
- Connection data (e.g. IP address, logs)
- Data relating to your prospecting requests (including your name, email address, and sale address)
- Data relating to your investments
This data may be collected when you log in to our Site and when you use our Services.
For clarity, mandatory fields are clearly indicated when you provide your data.
5. Use of your personal data
On what legal basis is your data collected and used?
Contract:
This processing is necessary to perform the contract entered into when you use our Services on our Platform.
Legitimate interest:
When you voluntarily provide personal data, we collect it to better respond to your information requests on our Site.
Legal obligation:
When processing your data is necessary to comply with a legal obligation to which we are subject.
Summary table of the purposes for which Trackstone collects and processes your personal data, along with the corresponding legal basis:
| Purpose | Legal Basis |
|---|---|
| Creating your user account on the Platform | Performance of the contract binding you to Trackstone (i.e. the Platform's terms of use) |
| Sending the newsletter | Your consent |
| Responding to your information requests | Trackstone's legitimate interest in maintaining its service |
| Handling requests to exercise your rights | Legal obligation |
| Handling account deletion requests | Performance of the contract binding you to Trackstone (i.e. the Platform's terms of use) |
| Platform maintenance | Trackstone's legitimate interest in maintaining the Platform |
6. Who receives your data?
The following parties will have access to your personal data:
(i) Our team,
(ii) Our sub-processors: hosting provider, audience measurement and analytics provider, newsletter provider, CRM tool, and customer support tool provider,
(iii) Public and private bodies, solely to meet our legal obligations.
This also includes legal auxiliaries (bailiffs, notaries, etc.), ministerial officers, and debt-collection agencies.
Your personal data will never be sold, rented, or exchanged with third parties.
7. For what purposes is your data collected and used?
- To provide the services available on our Site
- To maintain a database of users, subscribers, and prospects
- To manage the customer relationship and respond to information requests
- To send newsletters, solicitations, and promotional messages
- To personalize responses to your information requests
- To comply with the legal obligations applicable to our business
- To handle requests to exercise your rights
8. How long do we keep your personal data?
Data collected to provide our services on the Site
Your data is kept for the duration of your account plus a further 3 years from the date your account is deleted.
Data collected to manage the customer relationship, conduct prospecting, and develop and promote our business
Data is kept for the duration of the commercial relationship and deleted 3 years after that relationship ends.
Data collected for prospecting purposes
Data is kept for 3 years from your last contact with us.
Data needed for legal and evidentiary purposes
Data is archived for evidentiary purposes for 5 years. Invoices and mandates are archived for 10 years.
When you exercise your rights
If we ask you for proof of identity: we keep it only for as long as is necessary to verify your identity. If you exercise your right to object to prospecting: we keep that information for 3 years.
9. Cookie and tracker policy
What is a cookie or tracker?
A cookie is a small text file that is downloaded to your computer when you visit certain websites. It allows a website to recognize a user's computer. Cookies help users navigate websites more efficiently, enable certain features, and provide information to website owners.
Cookies are the most widely used tracking technology, but other technologies also exist for analyzing a user's connections. These are collectively called "trackers" (local storage, local shared objects, etc.).
Which cookies and trackers are used on the Site?
The list below sets out the cookies and trackers used on the Site, together with their purpose and retention period:
| Cookie / Tracker | Purpose / Data Collected | Retention Period | Legal Basis |
|---|---|---|---|
| Sentry | Error tracking, performance monitoring, and crash detection for the Platform. Data collected: error traces, browser information, anonymized IP address, pseudonymous session identifier. Sub-processor: Functional Software Inc. (United States), covered by Standard Contractual Clauses. | 90 days | Trackstone's legitimate interest in ensuring the security and proper operation of the Platform (Article 6(1)(f) GDPR, Recital 49) |
| Axeptio | Stores your cookie preferences and consent choices. | 12 months | Trackstone's legitimate interest in recording your cookie choices |
| trackstoneutk | Tracks visitor identity on Trackstone. Contains an opaque identifier representing the current visitor. | 6 months | Trackstone's legitimate interest |
| Intercom | Live chat widget and customer messaging. | 9 months | Your consent |
| Customer.io | Audience measurement and personalized in-app messaging. | 12 months | Your consent |
| Google Analytics | Audience measurement and website analytics. | 13 months | Your consent |
| Google conversion Linker | Links Google Ads conversions and audiences across browsing sessions. | 90 days | Your consent |
| Google Ads | Tracks Google Ads conversions and builds remarketing audiences. | 90 days | Your consent |
| Facebook Pixel | Tracks Facebook Ads conversions and builds remarketing audiences. | 3 months | Your consent |
| HubSpot | Customer relationship management and conversion tracking. | 13 months | Your consent |
| Clarity | Audience measurement and user behavior analysis (heatmaps, session recordings). | 12 months | Your consent |
The retention period for data collected through cookies varies but does not exceed 13 months. Data collected is not sold to third parties or used for any other purpose. Personal data collected via cookies may be retained for a maximum of 25 months, after which it will be deleted.
How do I block or delete cookies?
Your web browser may allow you to block or delete cookies placed by the Site. The Help function of your browser should explain how to do this. Alternatively, you can visit www.allaboutcookies.org, which provides general information about cookies and how to manage them on your computer.
Please note that if you delete a cookie or object to cookies being placed on your device, you may not be able to access certain services on the Site and the Platform.
10. Security and Hosting
We (and our sub-processors) have taken all necessary precautions and appropriate organizational and technical measures to protect the security, integrity, and confidentiality of your personal data.
Your data is stored and retained for the duration of its processing on Google Cloud Platform servers located within the European Union.
11. European Union
In connection with the tools we use (see the section "Who receives your data?" regarding our sub-processors), your data may be transferred outside the European Union. Such transfers are secured by the following means:
- Either the data is transferred to a country that the European Commission has determined provides an adequate level of protection, or
- We have entered into a specific contract with our sub-processors governing transfers of your data outside the European Union, based on the standard contractual clauses between a data controller and a data processor approved by the European Commission.
12. What are your rights over your data?
Right to information
This is precisely why we have written this policy.
Right of access
You have the right to access all of your personal data at any time.
Right to rectification
You have the right to correct any personal data that is inaccurate, incomplete, or out of date at any time.
Right to restriction
You have the right to obtain restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
Right to data portability
You have the right to receive your personal data in a readable format and to request its transfer to a recipient of your choice.
Right to erasure
You have the right to request that your personal data be deleted and to object to any future collection.
Right to lodge a complaint
With a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of applicable law.
Right to object
You have the right to object to the processing of your personal data. Please note, however, that we may continue processing it despite your objection, for legitimate reasons or for the establishment, exercise, or defense of legal claims.
Regarding prospecting, you may object at any time via the unsubscribe link at the bottom of each of our prospecting emails.
Right to set out instructions for after your death
Relating to the retention, deletion, and disclosure of your personal data, and designating a person responsible for their execution where applicable.
General instructions may be transmitted to a digital trusted third party certified by the CNIL; specific instructions may be sent to the contact details below.
You may modify or revoke your instructions at any time.
You may exercise the above rights by writing to us at privacy@trackstone.fr
Or by post at: Trackstone - 19 Quai de rive neuve, 13007 Marseille
You must provide proof of identity by any appropriate means. If we have doubts about your identity, we may ask for additional information, including, where necessary, a signed copy of an identity document.
13. Amendments
We reserve the right, at our sole discretion, to amend this policy at any time, in whole or in part.
You will be informed of any such update by a notice displayed the next time you use our Site.
Amendments take effect from the date the new privacy policy is published. Your continued use of the Site after the amendments take effect constitutes your acknowledgment and acceptance of the new policy. If the new policy is not acceptable to you, you must stop using the Site.