Residences

Data protection policy

1. Personal data protection policy

 

KLEY undertakes to respect the confidentiality of your data and has updated its policy in this respect in accordance with regulation no. 2016/679 of the 27 April 2016, called the general data protection regulation (GDPR).


This personal data protection policy sets out in detail the way that KLEY processes and protects your personal data and informs you of your rights. All data shall be processed and protected in accordance with the existing laws on data protection, this including the GDPR, data protection act no. 78-17 of the 6 January 1978, the guiding principles relating to the application of article 82 of the law of the 6 January 1978 on “cookies and other plotters”, as well as all guiding principles, recommendations and systems of reference published by the CNIL and the CEPD.


We may modify this data protection policy from time to time to comply with the new laws and regulations or the evolution of interpretations. We invite you to regularly consult this page to keep informed of the updates that we are likely to make.

 

2. KLEY, processing manager of your data

 

The processing manager is the one that defines for what use and how your personal data are used.
The personal data collected on the KLEY website and mobile application are processed by:

• KLEY, a simplified joint stock company, registered with the Trade and companies register of Nanterre under the number 803 724 699, domiciled 38 rue Jacques Ibert, 92300 in LEVALLOIS-PERRET

Our data protection representative is Maître Pierre-Louis ROUYER, domiciled at 38 avenue Hoche in Paris (75008) and whose email address is the following [email protected].

To find out more about the data protection representative’s missions on the CNIL website.

 

3. Types of data collected and processed

 

KLEY collects personal data concerning users of the kley.fr website and the KLEY application (Android and IPhone), below the “Platform”


These data are necessary for concluding and correctly managing your rental agreement. Providing your personal data thus determines the supply of services proposed by KLEY among others.

 

3.1. Data concerning Platform users

 

• Data concerning the tenants
- surname and first names;
- Marital status;
- nationality;
- date of birth;
- place of birth;
- language of preference;
- login names;
- IP address;
- email address;
- postal address;
- URL referrer;
- the type of accommodation desired and chosen;
- telephone number;
- the start date desired;
- the length of stay desired;
- the training undertaken and the current year of study;
- if the tenant has a grant;
- if the tenant is an employee;
- if the tenant has a guarantor and how much does he/she have.

 

• Data concerning the guarantors
- surname and first names;
- Marital status;
- nationality;
- date of birth;
- telephone number;
- login names;
- IP address;
- email address;
- postal address;
- URL referrer;
- the professional situation (social-professional category);
- Name of the guarantor organisation.

 

3.2. Data concerning the end users

 

Data concerning the end users, namely the users having made a reservation request, are collected on the basis of their consent.
In addition to data collected for Platform users, the subscription of a rental agreement imposes the collection of additional data, necessary for studying reservation requests:


• Data concerning the tenants;
- Bank data;
- Identification data;
- Data concerning the university education.


• Data concerning the guarantors;
- Identification data;
- Data relating to the professional situation and remuneration;
- Data relating to the land situation.

 

4. Purposes of the processing

 

We use the information collected to give users an online experience best adapted to their student accommodation wishes and searches.


The exact purposes (or objectives for processing your data) for which we use your information are the following:
- to manage the website;
- to supply third parties with statistical information on our users (but this information will not be used to identify individual users);
- to process requests and complaints made by or about yourself in connection with the website.

 

- administrer le site ;
- fournir à des tiers des informations statistiques sur nos utilisateurs (mais ces informations ne seront pas utilisées pour identifier des utilisateurs individuels) ;
- traiter les demandes et les plaintes faites par ou sur vous-même en lien avec le site.

 

 

Processing activit

 

 

Purposes

 

 

Legal basis of the processin

 

 

 

Prospection: to offer you a rental offer

 

 

 


 

 


(1) Analysis of the type of accommodation sought after by a future tenant for the transmission of an offer;
(2) Sending offers similar to the property for which the prospect presents an interest.

 

 

 

 

 

 

 

(1) Consent
(2) Legitimate interest (subject to compliance with your right to object)

 

 

 

 

Conclusion of the lease agreement

 

 

 

 

 


(1) Analysing the candidate’s solvency
(2) Conclusion of the lease agreement and its annexes

 

 

 

 

 


Execution of pre-contractual measures

 

 

 

 

 

 

Management of the contractual relationship

 

 


 

 

(1) Monitoring the payment of rents, charges and security deposits
(2) Management of the accommodation occupancy
(3) Management of insurance
(4) Aggregation of the data to pass on the statistics to the local rent watchdog

 

 

(1), (2), (3), Performance of the agreement
(4) Legal obligation

 

 

 

 

Proposal of additional services to the lease agreement

 

 

 

 

 

 


(1) Subscription to additional services (housework, laundry room, parking, etc.)
(2) Invoicing and monitoring of the payment of additional services

 

 

 

 

 

 

Execution of pre-contractual measures and performance of the agreement

 

 

 

Information and advertising

 

 

 

(1) Transmission of general commercial communications (non-advertising)
(2) Transmission of notifications expressly requested by email
(3) Transmission of advertising communications linked to our activities that you think have an interest for you by mail or in the event you have expressly accepted it, by email or by a similar technology

 

 

 

 

Consent

 

 

 

 

Management of the website and client space

 

 

 

 

(1) Improvement of the browsing experience by personalising the website
(2) Use of services available on the website and on the client space
(3) Managing complaints and claims

 

 

 

 

 

(1) legitimate interest
(2), (3) performance of the agreement

 

 


 

 

Management of the termination of the lease agreement

 


 

 

Termination of the agreement

 

 

 

Performance of the agreement

 

 

 

5. Cookies

 

Internal and third party cookies:

A cookie constitutes a little text file containing alphanumeric characters, created from a computer when a browser wishes to access a website using cookies. These files are used to help the browser to browse the website and fully exploit its functionalities, with common functionalities like notably login names, preferences, linguistic settings and even themes.
On no account does KLEY undertake to authorise access to information contained on the computer’s hard drive or identify it by a name.


“Internal cookies” are cookies that belong only to KLEY, while “third party cookies” are cookies that a third party places on a device via our website. Internal cookies, like third party cookies, may be analytical, functional or even advertising cookies. Social networks cookies are generally parameterised by a third party.


Third parties that parameterise cookies via our website supply us with a service or ensure a function of the website. KLEY has put in place tools allowing you to parameterise your choices concerning the acceptance or refusal of the archiving of cookies on your terminal, online, with different operators.

 

5.1 The types of cookies

 

The types of cookies used on most website generally belong to one of the following categories: necessary, analytical, functional, advertising and social network cookies.
KLEY uses cookies from its different categories in order to provide users with the best browsing experience possible.
To consult all of our cookies, you can access them here.

 

 

The table below sets out in detail the cookies from each category that KLEY uses.

 

 

Type of cookie

 

 

 

 

 

Description

 

 

 

 

Strictly necessary cookies

 

 

 

 

These cookies are essential for performing our services. Without these cookies, it is impossible for us to provide the services that can be used. Analytical cookies: These cookies collect information on the way Internet users use our website, for example the most visited pages, the way Internet users go from one link to another and if they get error messages on certain pages.

 

 

 

 

 

Functional cookies

 

 

 

 

 

These cookies allow us to remind us of the choices and adapt our website so as to improve the functions and content proposed. For example, these cookies can be used to recall the username, the language chosen or the preferences already stated. They can also be used to memorise changes concerning the size of the text, the font and other parts of customisable pages.

 

 

 

Advertising cookies

 

 

 

 

 

These cookies are used to offer our adverts. They are used to limit the number of times users see an advert and to measure the effectiveness of the advertising campaign. They are a reminder that users have consulted a website and this information may be passed on to other companies, like advertisers. They also allow us to offer more relevant adverts, which more suit your interests.
We use a plate.

 

 

 

Social network

 

 

 

In order to improve the online experience and facilitate the sharing of content, some pages from our website or some of our adverts contain tools or applications linked to service providers of external social networks, like Facebook, Twitter or Google+. These service providers can parameterise their own cookies on the device via these tools or applications.
We use several sharing buttons on our website.
• To manage your data on Facebook here
• To manage your data on Twitter
here
• To manage your data on LinkedIn
here
Disabling these cookies therefore prevents any interaction with social networks.

Disabling these cookies therefore prevents any interaction with social networks.

Referral cookies

 

These cookies are placed on the device when users use one of our special referral pages to create a link allowing their friends to be referred to our services.

5.2 Your rights regarding the acceptance and management of cookies

 

The saving of cookies used by KLEY on your browsing terminal is subject to your wishes: you can modify your choices involving the acceptance or refusal or the archiving of cookies on your terminal at any time, either on your browser or online with the different operators.
KLEY has put a tool in place so you can parameterise your choices depending on the pursued purposes.

Click here to modify your preferences regarding cookies.
Cliquez-ici pour modifier vos préférences en matière de cookies.

 

For more information relating to the management of cookies, we invite you to consult the page dedicated to this purpose.

6. Data retention

 

 

 

1. Retention period

 

KLEY retains your personal data collected in the framework of carrying out the processing relating to the rental management. The retention period established differs according to the pursued purpose and the stage of the contractual relationship.
• Data processed for the purposes of prospecting are retained for three years from the last contact with KLEY.
• Data collected in the framework of the assessment of your solvency are retained for three months in an active database.
• KLEY also retains your personal data in an active database throughout the duration of the contractual relationship, and five years in the intermediary archives from the closing of your accounts.
• Data collective in the framework of the termination of the agreement are also likely to be consulted by us if needs be (reduction of the notice, solidarity).

2. Security

Your personal data are retained in accordance with the strictest security and encryption standards. In accordance with the GDPR, KLEY undertakes to retain the data collected from users only for the time needed to accomplish the purposes of the processing. At the end of the processing, the data collected will be destroyed or archived.

7. Data transfer

 

The processing carried out by KLEY is not intended to be the subject of a personal data transfer outside of the European Union.
However, if such was the case, KLEY undertakes to respect all of its obligations in the matter, including notably:
- ensuring that the transfer is carried out towards a third country subject to an adequacy decision;
- ensuring that the transfer is carried out by means of appropriate guarantees (including notably via data protection type clauses adopted by the Commission or by a supervisory authority approved by the Commission).

8. Sensitive data

 

No sensitive data, namely any data revealing the racial or ethnic origin, political opinions, religious and philosophical beliefs, the belonging to a trade union, genetic, biometric data, concerning the health or sex life or sexual orientation of a natural person is processed by KLEY in the framework of the reservation request.

 

9. Rights of the persons concerned

 

The beneficiaries of the rights conferred by the GDPR are the persons concerned by the processing of their personal data.
 
KLEY informs you that you have the following rights:
- Right to information: this involves the right, for the person concerned by the processing of his/her personal data, to be informed of all of the rights he/she has in virtue of the GDPR.
- Right to access: the persons concerned by the processing of their personal data must be able to access them.
- Right to rectification: this involves the right to have the processed data that proves to be inexact or inaccurate completed or rectified.
- Right to deletion: the person concerned by the processing is entitled to request the deletion of personal data concerning him/her.
- Right to limitation of the processing: this involves the possibility for the person concerned to request the locking of his/her personal data, this entailing that KLEY settles for storing them.
 
- Right to data portability: this involves the possibility of retrieving certain data in a structured format, commonly used and legible by machine, allowing that person who requests it to store them or pass them on easily to another information system.
- Right to object: this involves the right for the person concerned to object to processing relating to his/her personal data being carried out.
- Right not to be the subject of an automated individual decision: this involves the hypothesis where an algorithm identifies correlations and reciprocal connections between personal data collected in view of assessing the personal aspects of the person concerned or to predict his/her behaviour.
The users of the Platform who wish to exercise their rights can contact us at the following address: [email protected]
 
If you consider some of your rights not to be respected by KLEY, you have the possibility of making a claim to the CNIL in its capacity as regulator.

The filing of an online complaint is accessible here.

10. Nos principaux partenaires de traitement des données

 

 

KLEY works with two subcontractors:

Salesforce et Ad Presence.

Questions? Don't keep them to yourself!
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