PRIVACY POLICY

1. Scope of the Privacy Policy

One of our top priorities is making sure that the information shared with us about you (or your customers) is protected and secure. While we work hard to preserve your privacy and ensure that your preferences are honored, the very nature of our relationship may result in us needing to collect or share certain types of information, but always in safe and legal ways.

We therefore attach the utmost importance to respect for your privacy and processing of your personal data in accordance with the regulations in force applicable to the processing of personal data and, in particular, where relevant, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter « R. EU 2016/679 ») applicable as of 25 May 2018, as well as the Luxembourg Law of 1 August 2018 on the implementation of the said R. EU 2016/679 (hereinafter the « Law »).

This privacy policy explains how we collect and use personal data. Personal data means any data relating to an identified or identifiable natural person, directly or indirectly, by reference to an identifier (such as a name, an identification number, an address or an electronic identifier) or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that person.

This privacy policy is applicable to us (on the Plan-It-All website and platform, including in the use of the Atlentis Application, and at the corporate level), our subsidiaries, our partners, and our subcontractors.

2. Identity of the data controller

The data controller is MnR Services Sàrl with its registered offices at 6, avenue Pasteur – L-2310 Luxembourg.

3. Collection of Information

We Collect Information:

• Which you give to us on applications, surveys, registration forms, etc.
• Which you give to us when you make a purchase or place an order, or when you otherwise provide us with account information such as credit card usage.
• Which others give to us to enable us to make sure that the data you provide is accurate and up-to-date.
• which may include information about you from past or present employers.
• On seminars or other events where there may be an exchange of visit cards or other information.

We Treat this Information:

• To ensure the delivery of the requested services and products.
• To execute a sales contract.
• To organize an event in an optimal way.
• To inform you about news from Plan-It-All, including among other things about the Atlentis app, new technologies and new services.
• To process transactions (including purchase/account data).
• To respond to your inquiries.

We Keep this Information:

• As long as legally required (including among other things accounting data, contracts)
• For the duration of the trade relation.
• Certain contact information for canvassing are held in our databases until you inform us that you do not want to be contacted by us anymore.

4. How We Share Information

We share information within Plan-It-All and the Atlentis application, as appropriate. To respond to your enquiries, it can happen that we share personal information with our partners, our subsidiaries, or other Plan- It-All/Atlentis offices. This is done when they perform services on our behalf.

5. How We Protect Information

We take appropriate technical, physical and organisational measures designed reasonably to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and from any other form of unlawful processing. Access to personal data is restricted to authorised recipients on a need-to- know basis. We operate comprehensive data security measures commensurate with the risks associated with the processing. These are regularly adapted to mitigate operational risks and to ensure the protection of personal data, taking into account accepted industry practices.

6. Data Quality and Access

The accuracy of your individual identifying information is important to us. We are working on ways to make it easier for you to review and correct the information that Plan-It-All and the Atlentis app maintain about you, since you are entitled to review, amend and remove your personal data. By providing us with personal data, you understand and agree to the collection, processing and use of such data as set out in this privacy policy. Should you want to see any information we have about you or to exercise your rights, please contact us directly at support@plan-it-all.com.

Where required by applicable law, we will seek your express consent to some aspects of the processing of your data. In accordance with applicable law, you have the right to object at any time to the use of your personal data or to withdraw any consent previously given for a specific purpose by contacting us at support@plan-it- all.com.

Within the limits of applicable law, you may have the right to request the deletion of your personal data or to restrict the processing of your data, and to object to the processing or transfer of such data. Such request should be made by contacting us at support@plan-it- all.com. In case of difficulties in exercising these rights, you also have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (hereinafter the « CNPD »).

7. Online Specific Statement

Plan-It-All and the Atlentis app are committed to taking reasonable steps to protect the individual identifying information that you provide to us.

8. Collection of data for statistics and reporting

When you connect to the Plan-It-All website or the Atlentis app to view information or to download files, we automatically collect the following data:

•  Type of domain name used to gain access to the Internet (such as .com, .org). The IP address attributed during the connection.
• Date and time of access to the site.
• Duration of site/page visit.
• Browser used.
• The operating system or platform installed on your personal computer, or the access device used.
• Search engine and meta tags used to track the Plan-It-All website and the Atlentis app on the web.
• Type and nature of files or information that has been downloaded.
• These log files are intended to map the number of visitors on various sections of our website and app and to continuously improve the content of the site and the app.

9. Use of Cookies

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited, but the only personal information a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. When accessing information stored in a database format, a basic version of cookies is used to transfer an answer to the user who has initiated a question.

Nowhere on the Plan-It-All website, however, are cookies being used that store specific information on the user or surfer. Cookies on the Plan-It-All site serve a more functional purpose i.e. they are generated by an IIS web server (Internet Information Server), stored in the memory of the browser, meaning they disappear once the browser session has been terminated.

Links to external sites.

The Plan-It-All web site may contain links to external sites. Plan-It-All is not responsible for the content and the privacy practices of other web sites and encourages you to examine each site’s privacy policy and disclaimers in order to make your own decisions regarding the accuracy, reliability and correctness of material and information found there.

Applications, surveys, registration forms

Plan-It-All and the Atlentis app have to collect certain information in order to be able to provide all requested services. Compulsory indications will be expressly highlighted in applications, surveys, registration forms, where they are required.

Use of our website, portal and/or application

Our Plan-it-All website and portal, as well as our Atlentis Application are primarily designed for real estate professionals and/or anyone having an interest in real estate. All other uses are prohibited.

10. Liability

MnR Services, PLAN-IT-ALL and the Atlentis app publish blog posts on plan-it-all.com (and any related websites). However, these publications are not to be considered as legal advice and MnR Services Sàrl and its staff are not liable for them.

MnR Services declines all responsibility for the accuracy, the updating of the data made available to any person consulting the website and/or blog pages accessible to the public, as well as the data made available to Plan-It- All and Atlentis users.

MnR Services points out that the information made available on the publicly accessible Plan-It-All website and Atlentis app are available to anyone, including natural and legal persons who are in a Member State of the European Union subject to the applicable legislation on the protection of personal data, but also in a State outside the European Union which does not necessarily guarantee the same level of protection of personal data.

Even if MnR Services, Plan-It-All and the Atlentis app implement appropriate technical and organizational measures to ensure data protection, including against unauthorized access or inappropriate use by third parties, we cannot be held responsible for the use of data communicated to us by third parties for purposes contrary to those originally intended. Consequently, we invite users not to communicate so-called sensitive data, and more generally any data that is not intended to be made public.

11. Contact Information

If you wish to inform us of any problems related to data confidentiality or if you have any questions, comments or complaints, please contact us at support@plan-it-all.com or by surface at the following address:

MnR Services Sàrl 6,
avenue Pasteur
L-2310 Luxembourg

We are committed to handling complaints in relation to the collection, use and other processing of your personal data with due diligence.

12. Changes to our Privacy Policy

We reserve the right to correct, amend and update this privacy policy at any time. Please check our website or our app regularly to ensure that you have read the most recent privacy policy.

Done in Luxembourg on 9 July 2021.