Privacy Policy

1. INTRODUCTION
GREM Real Estate Platform ("us", "we" or "company") is committed to respecting the privacy rights of its visitors and users of this web application ("Web Application"). We have developed this Privacy Policy (the "Policy") to give you confidence as you visit and use the web application, and to demonstrate our commitment to fair information and privacy.

This Privacy Policy sets out the collection, use, disclosure and management of personal information. By using the GREM Websites and Web Application, subscribing to our services, or entering into an agreement with us regarding the Web Application, you are deemed to have read and consented to the collection, use, disclosure and processing of your personal information in accordance with this Privacy Policy.

We recognize the importance of protecting personal information. We do not collect sensitive information such as information about race or ethnicity, political opinions or associations, criminal records or medical information, or sexual orientation.

In the collection and processing of personal information, we are bound by the law on the protection of personal data and applicable privacy regulations.

Company encourages you to read these Cookies and Privacy Policy carefully when using our Web Application or services or doing business with us. By using the website, you accept the practices described in this Cookie and Privacy Policy.

If you have any questions about our Privacy Practices, please see the end of this Cookie Policy and Privacy Policy for information on how to contact us.

For certain services and products, GREM may also collect your personal data to verify your identity, including information from your passport, driver's license, and medical and permit documents.

The controller of your personal data is GREM CAPITAL LIMITED. Please send questions about data processing and requests concerning your rights to [email protected].
Company number: 14177574. Address: 54 Kestrel Avenue, London, England, SE24 0EB.

2. INFORMATION COLLECTION STANDARDS
2.1. WHAT PERSONALLY IDENTIFYING INFORMATION DO WE COLLECT?
(a) Categories of personally identifiable information. We collect personal information from you when you create an account or sign in, send a request, subscribe to a newsletter or contact us, including:

Your name,
Your email address,
Your phone number (see section 2.3),
The message you send with requests.

GREM may collect personal information about you, including, but not limited to, your name, address, telephone number, email address, gender, profession, personal interests and any other information provided. For certain services and products, GREM may also collect your personal data to verify your identity, including information from your passport, driver's license, and medical and permit documents. If you access any of our services through a social networking site, such as Facebook, we collect limited information provided to us by the social networking site: username, site ID, and email address. If you are a shareholder of GREM, GREM (or its service providers) may collect information about your shareholdings, bank details and tax file numbers for the payment of dividends and other amounts. If you provide us with personal information in connection with an employment opportunity, we may also collect information about your work and academic history. We may also collect non-personal information about you, including but not limited to data related to your activities on the web application and the GREM web application (including IP addresses) through the use of tracking technologies such as cookies, web beacons and software provision or measurement data relating to survey responses. You acknowledge that the personal information you provide to us and that we collect is your personal information or information that you are authorized to provide.

(b) Newsletter subscription. If you choose to download a free product, purchase any product sold or advertised by us, you will automatically be subscribed to our free newsletter.

(c) The process of modifying or deleting. Please contact us if you would like to change or delete your information: [email protected]

(d) Modifications and updates to the Privacy Policy. We may update and change this Privacy Policy. We may change this Privacy Policy at any time. If we change or update the policy, we will post a notice on the web application 30 days before the change takes effect. We may change this Privacy Policy at any time. You should check this Privacy Policy periodically to ensure that you are updated with any changes. If you are a customer and this change would materially change the rights or obligations of any party and therefore could cause you material harm, we will provide you with at least 30 days written notice by email before the changes become effective, and you may terminate your agreement with us during this period if you believe the change will result in material damage. For non-material changes that we make that will not cause financial damage to the customer, we will provide customers with at least 30 days' notice by email before the change becomes effective, but customers cannot terminate the agreement as a result of this modification during this period.

GREM may collect personal information about you from a variety of sources, including but not limited to:
(a) log in to use our web application through your social network (SNS) account; (b) signing up to receive alerts/electronic brochures and filling out forms, applications (such as the 1Form online rental application), surveys or surveys, participation in promotions and contests on or our service providers' websites; (c) contact us or our service providers for any reason, including but not limited to reporting a problem with the web application, requesting additional services, or seeking assistance; (d) posting or contributing material to our web application; (e) by contacting us directly at work, through an SNS site (such as LinkedIn) or through guarantors designated by you.

GREM may collect personal information about you if you:

(a) are a shareholder of GREM, then GREM may collect personal information about you from third parties (including, for example, collecting information from its share registrar or shareholders);
(b) subscribe to receive email notifications, media releases and other news related to GREM through the GREM web application.

We may also collect your personal information through our related entities, our service providers and third parties so that we can provide you with a better or more relevant service or product.

2.2. WHAT ADDITIONAL INFORMATION DOES THE COMPANY COLLECT?
(a) AUTOMATIC COLLECTION. Our servers automatically recognize visitors' domain names and IP addresses (a number assigned to computers on the Internet). No personal information about you is revealed in this process. The web application may also collect anonymous aggregated "traffic data" that does not personally identify you, but this may be useful for marketing purposes or to improve the services we offer.

(b) COOKING. We may use "cookies" to store a small piece of data on your computer during your visit to collect information. Cookies are used to obtain information about how you use the Internet, which we try to include on the site in order to improve your experience.

2.3. PHONE NUMBER
Sections 2.3, 2.4, 3.2, 6.1 and 6.2 apply to the GREM websites and to the GREM mobile apps for Android and iOS.

We ask for your phone number so that:

you can sign in to the app or the website and confirm your number with a code sent by SMS, including in the Swipe Match section. If you do not have a GREM account yet, we create one when you first confirm your number;
the broker who has accepted your request can contact you. Section 3.2 explains who receives your number and when;
you can confirm a request left on the website: on the request confirmation page and in the “We'll find a home for you” form;
we can contact you if you entered your number yourself in a feedback form, in your profile or in a Smart request.

SMS codes are sent on our behalf by the Zadarma service, which receives only your phone number and the code. A code is valid for a few minutes; we keep an irreversible fingerprint of the code, not the code itself. A confirmed number is saved in your GREM account.

2.4. WHAT DATA OUR APPS AND WEBSITES PROCESS
Our apps and websites process the following data:

your name and email address — for your account and to contact you;
your phone number — for the purposes in section 2.3;
property photos and your profile photo that you upload or take with the camera in the app;
messages in chats, including voice and video messages. Calls through the app are not recorded: we keep only their time and duration;
approximate location — the country and city that we determine from your IP address using our own database on our server (your IP address is not sent anywhere for this), to show properties in your region and to protect sign-ins to your account.;
the location of a broker's phone — only when the broker marks a meeting with a client as held on site in Swipe Match and agrees to it. The app asks for location access only while it is in use, never in the background, and takes the location once. Our server compares it with the property's point on the map and discards it at once: we keep only whether the broker was within 300 m of the property and the time of the mark. The coordinates are not stored and are not shown to the client. If the phone reports that its location is simulated, a moderator reviews the mark. Otherwise the app does not request the precise location of your device;
device data: a push notification token (Firebase Cloud Messaging), a random app installation identifier, the app version and the platform — to send notifications and keep the app working;
crash reports and diagnostic data — to find and fix errors: in the app through Firebase Crashlytics (a report is linked only to your internal account ID and the app language, and email addresses and phone numbers are masked in the app's logs), on the server through Sentry;
usage statistics: in the app through Firebase Analytics (events are linked to your account ID; the app does not receive the device's advertising ID; the app does not ask for separate consent to these statistics), on the websites through Google Analytics after you consent to cookies and through our own visit counting based on a random visitor ID;
which broker cards in Swipe Match you viewed, opened or skipped. These records are stored without your contact details for 180 days;
purchase history: card payments go through Stripe, in-app purchases through the App Store and Google Play, and in-app purchases are recorded by the RevenueCat service. You enter your bank card number on the payment services' side; GREM does not store it.

The app does not read your address book, SMS messages or call log. The Android permission to access the phone number is needed only for calls through the app, to show an incoming call on the lock screen; the app does not send your SIM card number anywhere.

Source of the IP-based location data: IP Geolocation by DB-IP

3. USE AND SHARING OF INFORMATION
3.1. WHAT MAKES A COMPANY OWN INFORMATION?
We may disclose personal information to our associated corporate bodies, service providers or business partners. We may also disclose your personal information:

(a) real estate agents or brokers, real estate developers, builders, public retirement operators and landlords who have listings or advertisements on our Webapp and who you have requested information by submitting a request;
(b) to our service providers to enable them to provide products or services to you on our behalf or products or services that you have requested directly from them, or to help us provide you with our products or services (including if you are a shareholder , exchange registrars and provide management services for plan management services);
(c) third parties from whom you requested information, services or products;
(d) in conjunction with a sale or similar transfer of business;
(e) relevant state, governmental or regulatory authorities, our legal representatives or other interested parties in special situations where we have reason to believe that disclosure of your personal information is necessary to identify, contact or bring legal action against someone , or interfere (intentionally or unintentionally) with our rights or property, users or anyone else who may be harmed by such actions;
(f) if we are otherwise authorized or required by law to do so.

If you request information from any organization through our Webapp, you will need to check their Privacy Policy to find out how they handle your personal information. We are not responsible for how these organizations collect, use, disclose or process the personal information you provide to them through our web application.

We do our best to comply with the law and other best practices in this area. We may use the information we collect about you:

deliver the products and services you requested;
manage your account and provide you with customer support;
to conduct research and analysis on your use of or interest in our products, services or content or products, services or content offered by others;
contact you via email, postal service, phone and/or mobile devices about products or services that you may be interested in, either from us or from third parties;
enforce our terms;
to manage our business and perform the functions you described at the time of collection.

We may use financial information or a payment method to protect or detect possible fraudulent transactions, or otherwise to manage our business.

We may also disclose your information:

in response to a court request or similar request for an investigation, court order, or request for cooperation from law enforcement or other government agency; establish or exercise our legal rights;
lawsuit protection;
when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing;
to protect the rights, property, or safety of our company, our users, our employees, or others;
comply with applicable law or cooperate with law enforcement;
enforce the terms of our website or other agreements or regulations;
in connection with a significant corporate transaction such as the sale of our business, sale, merger, consolidation or sale of assets, or in the unlikely event of bankruptcy;
as otherwise required by law.

(a) PERSONAL INFORMATION. We will not share your personal information with third parties without your consent, except to the extent necessary for you to provide proper services or to comply with the law. Examples of such services include, but are not limited to, third party email and hosting services. However, please note that if you leave the site and purchase a product or service that we are promoting, the company you purchased from will notify us of the purchase, as well as certain identifying information for you. We do not share this information with others.

(b) ANONYMOUS INFORMATION. We use anonymous information to analyze our website traffic. In addition, we may use anonymized IP addresses to diagnose problems with our server, administer our site, or display content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymized basis. Your personal information will not be detailed in this data.

(c) USE COOKIES. We use the information obtained from cookies to analyze the use of the web application and to make appropriate changes.

(d) PERSONAL INFORMATION DISCLOSURES. We may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to (1) comply with the directions of the law or comply with legal process brought against the Company, (2) protect the right or property of the Company or users of the web application, or (3) act under exigent circumstances to protect the safety of the public or web application users.

(e) SELLING INFORMATION. To accommodate changes in our business, we may sell or buy parts of our Company or other companies or assets, including information collected through this web application and from our product orders, including information about your customers. If the Company or substantially all of its assets are acquired by a third party, your personal information will be one of the assets transferred to the acquirer.

(f) We respect copyright law. If we receive a copyright infringement claim, we will comply with the requirements of copyright law.

We use the personal information we have collected primarily to provide you with the products and services you have requested, respond to your inquiries, create and maintain your account, and enforce you and our terms of use for the web application.

More specifically, GREM may use the personal information it has collected to:

(a) ensure that content from the web application is presented in the most effective manner for you and your computer;
(b) provide you with a better or more relevant service or product, for example by automatically completing forms on a web application when inquiring for selected real estate agents;
(c) combine your personal information with information that GREM has collected from its service providers, third parties, cookies or web beacons in order to provide you with a better or more relevant and personalized experience and improve the quality of its services and those of third parties persons. For example, we may combine the behavioral data we have collected about you using cookies or web beacons and combine it with your personal information in response to requests you make to third parties through our web application;
(d) personalize and customize your services, experiences, ads and content that you view and are interested in on the web application or service providers and business partners;
(e) respond to or provide you with the services, products, information and assistance you request from GREM;
(f) contact you to conduct surveys, research, and feedback about our products, services, or web application;
(g) verify your identity when registering or logging into our web application through your SNS account and remind you of your password and username;
(h) allows you to participate in interactive features of our service when you choose to do so;
(i) help fulfill our obligations arising from any contracts entered into between you and us;
(j) evaluate your loan application as a business in connection with our services;
(k) by disclosing information to debt collection agencies to recover any amounts you owe us;
(l) notify you of changes to our products and services.

You can choose not to provide us with certain information, but this may result in you not being able to use certain features of our web application as such information may be required to register as a member; purchases of products or services; participation in a contest, promotion, survey or sweepstakes; in order to properly question; or initiate other transactions in our web application.

3.2. WHEN A BROKER RECEIVES YOUR PHONE NUMBER
Swipe Match. Your name and phone number go only to the broker you chose yourself, and only with your explicit consent: before you send a request we show the text “By sending the request you accept the platform terms and agree to share your number with the chosen broker.” The broker receives your name and number only after accepting the request; until then they see the request without your contact details.

Backup broker. If your request names a backup broker (you can remove them before sending) and the chosen broker does not respond in time or declines, the request goes to the backup broker. They, too, receive your name and number only after accepting the request.

Requests from the website without a chosen broker. Such a request goes to a broker selected by GREM, and only if two conditions are met: you explicitly agreed to pass on your contact details (for example, by ticking “Pass my phone number to a broker selected by GREM”) and you confirmed your phone number with a code. Otherwise nobody receives your contact details. The broker who accepts the request sees your name, phone number and request details, as well as your email and comment if you provided them.

Recommendation by a colleague. For a request without a chosen broker, the broker may be suggested by another broker on the platform, who may receive part of the broker's fee for the recommendation. Your terms do not change. Only the broker who accepts the request receives your contact details. The recommending broker does not see your name, phone number or other details and only learns whether the colleague accepted the request and whether a deal took place — without the amount or the property.

Anonymised demand. Requests in which you agreed to pass your contact details to a broker selected by GREM are visible to brokers on the platform in anonymised form — without your name, phone number or the text of your request: the deal and property type, the budget (it may be shown as a range), the city and district from the platform directory, how long ago the request was made and whether the phone number is confirmed. Brokers on the platform in other countries may also see such cards. Only the broker who accepts the request receives your contact details.

Brokers on the platform may see public posts from open sources (social networks, messengers, classified ad sites): what the person is looking for, the city, the budget, a short excerpt and a link to the original. We do not pass phone numbers, email addresses or other contact details from such sources to brokers: the broker contacts the person where they published the post themselves. If you do not want your post to be shown, write to [email protected].

Specialists registered on the platform see a Smart request without your contact details: the name, phone number and email in the request go only to the specialist you chose yourself or replied to in the request chat.

Under the platform terms, a broker may use your data only to work on your request.

4. SAFETY
We are committed to protecting the security, integrity and confidentiality of the personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorized access, alteration and disclosure. Our employees, contractors, agents and service providers who provide services related to our information systems are required to maintain the confidentiality of any personal information we hold. We review and update our security measures in the light of modern technology. Unfortunately, no data transmission over the Internet can guarantee complete security. The web application has reasonable security measures in place to prevent the loss, misuse, and alteration of the information we collect from you, but we make no warranty as to our ability to prevent any such loss, misuse, or misuse to you or any third party arising from result of such loss, misuse or alteration.

In addition, we use encryption when transferring your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized individuals from accessing your personal information.

Users should also be careful about how they handle and disclose their personal information, and avoid sending personal information via insecure email.

We are committed to protecting the security, integrity and confidentiality of the personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorized access, alteration and disclosure. Our employees, contractors, agents and service providers who provide services related to our information systems are required to maintain the confidentiality of any personal information we hold. We review and update our security measures in the light of modern technology. Unfortunately, no data transmission over the Internet can guarantee complete security.

The website application has reasonable security measures in place to prevent the loss, misuse, and alteration of the information we collect from you, but we make no warranty as to our ability to prevent any such loss, misuse, or misuse by you or any third party arising from such loss, misuse or alteration.

This Privacy Policy does not create rights provided by third parties.

5. WEB APPLICATION AREAS 'UNCONTROLLED COMPANIES'
5.1. THIRD PARTY WEBSITES
The web application contains links and interfaces to third party websites and online platforms. These websites and online platforms have created their own terms of use and privacy policies. You are encouraged to read these documents as we have no control over their terms and these documents may differ greatly from our terms and conditions and privacy policy.

6. CORRECTION AND ACCESS
We will endeavor to take all reasonable steps to ensure that the information we hold about you is accurate and up-to-date. If at any time you discover that the information held about you is incorrect, or you would like to review and verify that your personal information is correct, you may contact us. You may also access the personal information we hold about you by subject to certain exceptions provided by law. To request access to your personal information, please contact us.

6.1. DELETING YOUR DATA, ACCESS AND OPTING OUT

You can delete your account yourself: in the app (Settings → Delete Account), in the web dashboard or on the deletion request page: grem.capital/en/delete-account
After deletion your profile is hidden, sign-in to the account is closed, sessions end and notifications stop. We keep deals, contracts, payments and the request event log for as long as the law requires.
To get a copy of your data or to correct it, write to [email protected] and give the email address or phone number of your account.
You can refuse to have your contact details passed to brokers at any time: write “STOP” in the Swipe Match request chat, reply “STOP” to an automated message in WhatsApp or Telegram, or write to [email protected]. After that we do not pass your contact details to any broker you have not chosen yourself. A refusal sent in a conversation also withdraws your consent to messages by SMS, in messengers and by email.

6.2. HOW LONG WE KEEP DATA

a confirmation code request (phone number and code fingerprint) — up to one day after the code expires;
sign-in sessions together with the push notification token — 30 days after the last activity;
records of Swipe Match card views — 180 days;
the Swipe Match request log (broker choice, acceptance, contact, meetings, deal) — 5 years, as stated in the platform terms;
technical logs of requests to our servers — 90 days;
verification documents in Germany (the broker licence under §34c GewO, documents for the Denkmalschutz and Erbbaurecht marks of a listing) — while the status or the listing exists; after a listing is deleted, only a record of a document rejected by our staff remains (without the document itself: an address fingerprint, the reason and the author) — 2 years, so that the same forged document cannot be submitted again;
your refusal to have your contact details passed to brokers — until you ask us to lift it; for this we keep only irreversible fingerprints of your phone number and email.

We keep other data for as long as it is needed for the purpose for which it was collected and as required by law.

7. RESOLUTION OF COMPLAINTS
GREM is committed to providing its customers with a fair and responsible system for handling complaints. If at any time you have any concerns, complaints or questions regarding your privacy or the operation of GREM, please contact our Privacy Officer so that we can resolve your concerns. Our Privacy Officer will review your request and endeavor to respond promptly.

8. COOKIES AND WEB BEACONS
We use cookies, web beacons and computing software and tools on the Web Platform and the GREM Web Platform, as well as our service providers and third parties such as our analytics, advertisers or advertising partners. We use and disclose information collected using cookies, web beacons and measurements and tools in accordance with this Privacy Policy. This includes using the information to provide statistics, analyze trends, administer our services, diagnose problems, and improve the quality of our products and services.

A cookie is a small text file that is stored on the user's computer for record keeping. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier to navigate our site. A persistent cookie remains on your hard drive for an extended period of time.

When you visit our web application, we may assign one or more cookies to your computer to help you access our site and personalize your online experience.

Through the use of a cookie, we may also automatically collect information about your online activity on our website, such as the web pages you visit, the links you click and the searches you make on our website.

Most browsers automatically accept cookies, but you can change your browser settings to refuse cookies. If you choose to refuse cookies, please note that you may not be able to log in or use some of the interactive features offered on our web server.

We may store your unique data in an automatic registration cookie. This cookie is deleted when you log out. For security purposes, we will encrypt unique data and any other data related to a user or member account that we store in such cookies. In the case of sites and services that do not use a user or unique data, the cookie will contain a unique identifier.

We may allow our authorized service providers to send cookies from our web application to help us with various activities such as analyzing and researching the effectiveness of our site, content and advertising.

You can delete or reject cookies by changing your browser settings. (Click 'Help' on the toolbar of most browsers for instructions.) If you do this, some features and services of our web server may not work properly.

We may use standard Internet technologies such as web beacons and similar technologies to track your use of our site. We may also include web beacons in promotional emails or newsletters to determine if the messages have been opened and are active.

Web beacons (also called transparent gifs, pixel tags, or web bugs) are tiny graphics with a unique identifier, similar to cookies, used to track web users' online movements or to access cookies. Unlike cookies, which are stored on a user's computer's hard drive, web beacons are embedded invisibly on web pages (or email) and have a period of time at the end of this sentence.

Web beacons can be used to deliver or exchange messages with cookies, to count users who have visited certain pages, and to understand usage patterns. We may also receive an anonymous identification number if you visit our web application. from online advertisements provided on a third party website.

9. APPLICATIONS, MEASURES OR LINKS TO OTHER WEBSITES
We provide links to websites outside of the web application and the GREM web application, as well as third-party web applications. These linked sites, applications and widgets are not under our control and we cannot be held responsible for the conduct of companies associated with the GREM Web Application and Web Application or their collection of information through these third party applications or widgets. Before disclosing your personal information on any other website or using these applications or widgets, we advise you to review the terms of use of this website and the data collection practices and means of the relevant third parties in their privacy policies.

10. Changes to this Privacy Policy
We will update this Privacy Policy from time to time to reflect changes to our operations and services.

Privacy policy modifications and updates. We may update and change this Privacy Policy. We may change this Privacy Policy at any time. If we change or update the policy, we will post a notice on the web application 30 days before the change takes effect. You should check this Privacy Policy periodically to ensure that you are updated with any changes. If you are a customer and this change would materially change the rights or obligations of any party and therefore could cause you substantial harm, we will provide you with at least 30 days written notice by email before the change becomes effective , and you may terminate your agreement with us during this period if you believe that the change will result in material damage. For non-material changes that we make that will not cause material damage to the customer, we will provide at least 30 days notice by email before the change becomes effective, but customers cannot terminate the contract as a result of this modification during this period.

11. CONTACT INFORMATION AND POLICY UPDATES
If you have any questions about this Policy, our work in connection with this web application, please email us at [email protected].