PRIVACY POLICY FOR TENANTS

At Garantme, the protection of your personal data is a priority. 

When you use the site https://console.garantme.fr (hereinafter the "Site"), we collect personal data about you.

The purpose of this policy is to inform you about how we process this data in accordance with the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

1. Who is responsible for processing?

The data controller is the company GARANTME, a simplified joint-stock company, registered with the RCS of Paris under number 832 523 344 and whose registered office is located at 9 rue des colonnes, 75002, Paris, France (hereinafter "We").

2. What data do we collect? 

Personal data is data that directly or indirectly identifies an individual.  

We collect data that falls into the following categories:

• Identification data (including your name, first name, pseudonym, photograph, email and postal address, telephone number, date of birth, nationality);
• Supporting documents (including proof of identity, proof of address, proof of professional situation, proof of schooling, proof of income, Eligibility Certificate®). The list of supporting documents that may be collected is detailed in the Annex to this policy;
• Data relating to your housing search (including surface area, rent);
• Data relating to scheduled housing visits;
• Data relating to your personal life (including city of move-in, desired date, family situation);
• Data relating to your professional life (including your professional status);
• Economic and financial information (including your net monthly income, your savings, your maximum budget); 
• Connection data (for example: login logs, encrypted passwords);
• Browsing data (for example: IP address, pages viewed, date and time of connection, browser used, operating system, user ID, IFA);

The mandatory data is indicated when you provide us with your data. They are marked with an asterisk and are necessary to provide you with our services.

3. On what legal bases, for what purposes and for how long do we keep your personal data?

Objectives	Legal basis	Data retention periods
Registering on our Website and creating an account	Performance of pre-contractual measures taken at your request	Your data is kept for the entire duration of your account. If your account is inactive for 1 year, your personal data will be deleted in the absence of a response from you to our reminder email. Connection data is kept for 6 months from collection. In addition, your data may be archived for probative purposes for a period of 5 years.
Providing you with our services (sharing your documents securely with real estate agencies or your landlord)	Performance of the contract you have entered into with Us	Your data is kept for 12 months. In addition, your data may be archived for probative purposes for a period of 5 years.
Carrying out operations related to the management of our clients concerning contracts, transactions, invoices, and follow-up of the contractual relationship with our clients	Performance of the contract you have entered into with Us	Personal data is kept for the entire duration of the contractual relationship. In addition, your data (except for your bank details) is archived for probative purposes for a period of 5 years.
Establishing a file of customers and prospects	Our legitimate interest in developing and promoting our business	For customers: the data is kept for the entire duration of the contractual relationship. For prospects: the data is kept for a period of 3 years from your last contact, for prospecting purposes.
Sending newsletters, solicitations and promotional messages	For customers: our legitimate interest in retaining and informing our customers of our latest news. For prospects: your consent	The data is kept for 3 years from your last contact with Us or until you withdraw your consent.
Developing commercial statistics and tracking the use of our services	Our legitimate interest in analyzing the composition of our clientele and improving our services	The data is kept for 3 years.
Managing the opinions of people about our services and content.	Our legitimate interest in knowing the opinions of our customers and improving our services	The data is kept for 2 years.
Personalizing our responses to your information requests	Our legitimate interest in responding to your requests	The data is kept for the time necessary to process your information request and deleted once the information request has been processed.
Comply with the legal obligations applicable to our business	Comply with our legal and regulatory obligations	For invoices: invoices are archived for a period of 10 years.
Manage unpaid bills and possible disputes regarding the use of our services	Our legitimate interest in managing unpaid bills and possible disputes with our customers	The data is kept for a period of 5 years from the date of collection.
Manage requests to exercise rights	Our legitimate interest in responding to your requests and keeping a record of them	If we ask you for proof of identity: we only keep it for the time necessary to verify your identity. Once verification is done, the proof is deleted. If you exercise your right to object to receiving prospecting: we keep this information for 5 years.

4. Who are the recipients of your data?

The following will have access to your personal data:

1. Our company staff, control services (including auditors);
2. Our subcontractors: hosting provider, newsletter sending provider, review management provider, audience measurement tool, our visualization tool, CRM provider;
3. Real estate agencies for the purpose of studying your rental application in accordance with your request;
4. Landlords for the purpose of studying your rental application in accordance with your request;
5. Insurers or insurance brokers for the purpose of insuring contracts taken out by the tenant(s);
6. If applicable: public and private organizations exclusively to comply with our legal obligations.

5. Is it possible that your data may be transferred outside the European Union?

Your data is stored and kept for the entire duration of processing on servers belonging to Amazon Web Services, located within the European Union.

In the context of the tools we use (see article on recipients regarding our subcontractors), your data may be subject to transfers outside the European Union. The transfer of your data in this context is secured through the following tools:

• Either the data is transferred to a country that has received a decision of adequacy from the European Commission, in accordance with Article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR;

• Or the data is transferred to a country whose level of data protection has not been recognized as adequate under the GDPR: in this case, these transfers are based on appropriate safeguards indicated in Article 46 of the GDPR, adapted to each provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules, or under an approved certification mechanism.
• Or the data is transferred on the basis of one of the appropriate safeguards described in Chapter V of the GDPR.

6. What are your rights regarding your data?

You have the following rights regarding your personal data:

• Right to information: this is precisely the reason why we have written this policy. This right is provided for in Articles 13 and 14 of the GDPR.

• Right of access: you have the right to access all your personal data at any time, in accordance with Article 15 of the GDPR.

• Right to rectification: you have the right to rectify inaccurate, incomplete or outdated personal data at any time in accordance with Article 16 of the GDPR.

• Right to restriction of processing: you have the right to obtain the restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR.

• Right to erasure: you have the right to require that your personal data be erased, and to prohibit any future collection for the reasons stated in Article 17 of the GDPR.

• 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 violation of applicable laws. (Article 77 of the GDPR)

• Right to define directives regarding the retention, erasure, and communication of your personal data after your death, in accordance with Article 40-1 of the French Data Protection Act.

• Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR states that you may withdraw your consent at any time. This withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

• Right to data portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller.

• Right to object: pursuant to Article 21 of the GDPR, you have the right to object to the processing of your personal data. However, please note that we may continue to process your personal data despite this objection, for compelling legitimate reasons or for the exercise or defense of legal claims.

You may exercise these rights by writing to us at the contact information below. We may ask you on this occasion to provide additional information or documentation to verify your identity.

7. What cookies do we use?

To learn more about how we manage cookies, please refer to our Cookie Policy.

8. Contact Point for Personal Data

Contact Email: dpo@garantme.fr

Contact Address: 9 rue des colonnes, 75002, Paris, France

9. Changes

We may modify this policy at any time, particularly to comply with all regulatory, jurisprudential, editorial or technical developments. These changes will apply from the effective date of the modified version. You are therefore invited to regularly consult the latest version of this policy. However, we will inform you of any significant changes to this privacy policy.

Effective date: April 19, 2023

Annex: List of Supporting Documents that may be Collected

Proof of identity

• French or foreign identity card (with photo)
• French or foreign passport (with photo)
• French or foreign driving license (with photo)
• Temporary residence permit
• Residence permit
• Card of a national of a member state of the EU or EEA

Proof of income

• Last 3 payslips
• Certificate of payment of internship allowances
• Last balance sheet or attestation of resources for the current year issued by an accountant
• Proof of payment of allowances, pensions, social and family benefits, and allowances received in the last 3 months or proof of the establishment of rights by the paying organization
• Proof of rental income, life annuities or income from securities and movable property
• Grant award notice (student grant recipient)
• Proof of rental income, life annuities, or income from securities and movable property
• Simulation certificate for housing assistance issued by the Caf or by the MSA or by the tenant
• Last or second-to-last tax notice or non-tax notice

Proof of professional situation

• Employment or internship contract, or if necessary, employer's certificate specifying the job and proposed remuneration, the planned date of entry into function, and if necessary, the duration of the trial period
• Student card or certificate of enrollment for the current year
• Copy of professional card (liberal profession)
• Copy of the INSEE identification certificate including identification numbers (self-employed)
• Original D1 extract from the register of trades less than 3 months old (artisan)
• Original K or K bis extract from the trade and companies register less than 3 months old (commercial enterprises)
• Any recent document attesting to the professional activity (other cases)

Proof of address

• Last 3 rent receipts or, failing that, a certificate from the previous landlord
• Statement of honor from the host
• Last 3 rent receipts or, failing that, a certificate from the previous landlord
• Title deed of real estate or last property tax bill

Proof of enrollment

• Student card
• Certificate of enrollment for the current year
• Letter of admission