Million Real Estate INC Privacy Policy

Summary

the hereby document and taking effect on March 1st, 2019, we present the Privacy Policy summary for our mobile app Million. The platform has been designed for the strict use of our team, which means no direct interaction with clients will be done through it. Million Real Estate INC is committed to the protection of our customer's personal information and therefore no material or data will be sold to a third party for advertising or any other commercial use. On the following summary, we explain what information we collect, our purpose with it and who has access to it.

What information we gather

When a user requests additional information or asks for customer support from any of our websites, we collect the basic details provided, including their name, location and contact information which will log into the app.

How we use our client's information

We use this information to communicate with our clients and supply all services requested by them on our websites. We also analyze the data provided to improve our services through an understanding of our customer's needs. The app will include the option to communicate with our clients via text message. Which means, it will redirect our agents and employees to their phone’s text messaging platform in order to send the requested information to each client. However, this service will and cannot be used to receive any type of information in return, it will only allow our users to send it. In order to collect and process our client's information from our websites and into the app, we are required to have a legal basis. Before we receive any of their personal data, we either require their consent or need the information in order to provide the service requested. Our client's personal information will not be shared with employees or contractors unless they have a legitimate need for it. In case it is necessary to provide our customer's information with third parties it is mandatory they have appropriate security measures and again, a legitimate need to use this information, otherwise, it is not provided. Once the services needed from our clients have been supplied we will no longer be in possession of their personal information. We keep it for as long as it is required for the purposes stated in this Privacy Policy.

Information we process on behalf of our agents

As our team of agents handles their client's information through our app, they are entrusting us to give adequate use to it. Therefore, we protect and limit access to it following their instructions. The information will be stored in their accounts for as long as they choose to.

General

If necessary and in order to comply with legal obligations, user safety and preventing fraud, we will disclose our client's personal information. Customers will be able to get in touch with us regarding inquiries about our Privacy Policy, to alert us if they believe we have gathered information from a minor or even ask to have their personal data deleted from our records.

Privacy Policy

Effective as of March 1st, 2019, we Million Real Estate INC introduce the Privacy Policy for our mobile application Million.

Million's privacy statement

Being a private app, designed for the strict use of our team, we do not have any direct interaction with clients through the platform. Which means we do not request any piece of personal information as client's do not have access to this app, but we do handle the data we receive from our websites. Now, any piece of our client's information within the app must be legally treated. We only gather and control the necessary information required to provide our services, including names, location, and contact information.

Our Privacy Policy Scope

This document states the Privacy Policy that applies to our mobile app called Million, but it doesn't regard any of our websites, products or services that have a separate privacy policy. Our intention with this policy is to put into evidence the way we process client's information within the app, what information we collect, who has access to it, our purpose with it and how we handle this data.

1. The information we collect

We only collect information about our clients after they have requested our services from any of our websites. Once the information fields for name, contact, and location have been submitted, we receive the data in our app for any of our agents to assist a said client with the request they've made. This is the information customers provide to us. Being an app that has no interaction with the public, we do not have the capacity to demand any sort of information through this platform. We do not receive additional information from a third party and no financial data is ever requested.

2. Our purpose with this information

As previously mentioned, we use the information provided by our clients to provide a requested service. However, we may also use it for some of the following: - To contact our customers (through email or by phone). Our agents will be ready to communicate with our clients in regard to their requests or services they demand. - To inform them about new products, offers, or information that may be of their interest. - To provide customer support and analyze their interaction with the company agents. - To prevent fraudulent transactions and activities. Report spam and protect their interests. - To analyze our market, enhance marketing campaigns, administer our websites and visitor navigations as well as the improvement of our services.

Legal bases applicable to Million mobile app

For clients that belong to the European Economic Area (EEA) our legal basis for information gathering and use depends on which is said personal information and the context where it was gathered from. Our information collection process is based on contractual necessity, one or more legitimate interests of Million Real Estate INC, and customer's consent. In some cases, we may need to collect clients' information in order to protect their vital interests or those of another person. Withdrawal of consent: Clients have the right to withdraw their consent at any time where we rely on it as the legal basis to collect their information. Legitimate interests notice: We will explain to our clients our legitimate interests to gather their information at any moment they request where we rely on legitimate interest as the legal basis.

3. Whom we share client's information with

The entities listed below will have access to our client's personal information which was covered earlier in the first section of this document. We share the gathered information only as it has been described in this Privacy Policy and only with members of the company who adopt appropriate confidentiality and security measures. Agents and employees: to comply with our clients' demands agents and their personal assistants (employees) will have access to our customer's information like names, contact, and location. Only agents will be able to directly contact clients. We require that both agents and employees follow this Privacy Policy for the adequate use of personal information. Admins: Heads of the company whom in order to keep a record and analyze our market and visitor navigation will have access to the clients' information stated above. No direct communication will be made by admins with clients, unless strictly necessary.

4. Clients' rights regarding their information held by our team

Regardless of where our client is located, if he/she is in the European Economic Area (EEA) we respect the following rights: - Right to rectification: In any case necessary, clients have the right to make an update or modification of the personal information provided to us. According to the service needed, they are able to instruct us to add supplemental information about themselves in our database. - Right to erasure: Clients have the right to request the removal of their personal data from our records such as when the service requested has already been provided and there is no longer a purpose for us to keep their data. - Right to the restriction of processing: Our clients also have the right to demand a restriction regarding the use we make of their personal information. - Right to object: Clients have the right to object our use of personal data in specific circumstances, such as the use of their information for marketing purposes. - Right to complain: Customers have the right to complain to the relevant authority in case they are against the way we gather, share and use their personal information.

Retention of information

We keep clients' personal data for as long as we need to in order to supply the service or product requested. In some cases, we may hold the information for longer periods as permitted or required by law obligations such as to prevent abuse, to enforce our agreements, for accounting, fax, to maintain suppression lists or if it is required in connection with a legal claim. Once our clients' personal information is no longer useful, we will delete or anonymize it from our records.

5. Information we process on behalf of our agents

As our team of agents handles their client's information through our app, they are entrusting us to give adequate use to it. Therefore, we protect and limit access to it following their instructions. The information will be stored in their accounts for as long as they choose to.

6. General

Information Security

In order to ensure our clients' personal information is protected, we have taken certain measures including appropriate administrative and technical safeguards to prevent unauthorized access or use of the information entrusted to us. In any case of concern regarding the security of the information we hold, clients can contact us at [email protected].

Information transfers

Our client's personal information is shared within the company as it has previously been stated above. By providing said information in our websites, clients are granting permission for us to use, store, and transfer that information within our team located in the United States of America and Colombia where Million Real Estate INC operates.

Children's information

Our products and services are not directed at minors. In any case we may gather or receive personal information of an individual under 16 years of age, we will address the situation to delete said data. If any of our customers believe we may have been provided with a minor's personal information, they can notify us through [email protected] with the details and we will take the necessary actions.

Data processing addendum

We are ready to sign a Data Processing Addendum (DPA) based on Standard Contractual Clauses in order to enable our clients to be compliant with the data protection obligation under the General Data Protection Regulation. In case any of our clients are interested in requesting a DPA, they can contact us at [email protected].

Disclosures within legal obligations

Following the law, we may be required to preserve or divulge our clients' personal information to comply with legal processes or governmental requests.

Enforcement of our rights

In order to prevent fraud, protect our users and team, investigate illegal activities or enforce our policies we may disclose any piece of personal information entrusted to us if necessary.

Business Transfers

Even though we have no intention to sell our business or merge with other companies, in the remote case we do, we will make sure that the acquiring entity is legally bound to honor our commitment to our customers. A pertinent notification will be made through our websites and by email to inform our clients about any change in ownership or in the uses of their personal information.

Notification of updates

In case we modify or update our Privacy Policy, clients' will be notified by email 30 days in advance. If we make major changes that may affect their rights, clients will count with a 30-day window notice and an additional 30-day term to instruct us to remove their personal information from our records if desired. No contact with us after the date of the update in our Privacy Policy will mean clients are comfortable with any modification applied.

Compliance with our Privacy Policy

Our team is committed to the adequate use and processing of any information entrusted to us in accordance with this Privacy Policy. In any case a client is concerned about the way we handle their information or our adherence to this Privacy Policy, they will be able to contact us through [email protected]. We will address the situation and, if required, contact the appropriate regulatory authorities to approach the matter.