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.
您的个人数据控制者为 GREM CAPITAL LIMITED。有关数据处理的问题以及与您的权利相关的请求,请发送至
[email protected]。
注册号:14177574。地址: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. 电话号码第 2.3、2.4、3.2、6.1 和 6.2 节适用于 GREM 网站以及 GREM 的 Android 和 iOS 移动应用。
我们请您提供电话号码,用于:
- 让您登录应用或网站,并通过短信验证码确认号码,包括在 Swipe Match 板块中。如果您还没有 GREM 账户,我们会在您首次确认号码时为您创建;
- 让接受您申请的经纪人能够联系您。谁在何时获得您的号码,见第 3.2 节;
- 确认您在网站上提交的申请:在申请确认页面以及“我们为您挑选住房”表单中;
- 在您主动于联系表单、个人资料或智能请求中填写号码时,与您联系。
验证码短信由 Zadarma 服务代表我们发送,该服务只会获得您的电话号码和验证码。验证码在几分钟内有效;我们保存的不是验证码本身,而是其不可逆的指纹。已确认的号码保存在您的 GREM 账户中。
2.4. 我们的应用和网站处理哪些数据我们的应用和网站处理以下数据:
- 姓名和电子邮箱地址——用于您的账户以及与您联系;
- 电话号码——用于第 2.3 节所述目的;
- 您上传或在应用中用相机拍摄的房产照片和头像;
- 聊天中的消息,包括语音消息和视频消息。通过应用拨打的电话不会被录音:我们只保存通话时间和时长;
- 大致位置——我们使用自己服务器上的数据库,根据 IP 地址确定国家和城市(为此不会将您的 IP 地址发送到任何地方),用于展示您所在地区的房源并保护您的账户登录安全。;
- 经纪人手机的位置——仅当经纪人在 Swipe Match 中亲自将与客户的会面标记为“现场”完成并同意时。应用仅在使用期间请求位置权限,从不在后台请求,且只获取一次位置。我们的服务器将其与地图上的房源点比对后立即丢弃:只保存经纪人是否在距房源 300 米以内以及标记时间。坐标不会被保存,也不会展示给客户。如果手机报告位置为模拟位置,将由审核员核查该标记。除此之外,应用不会请求您设备的精确位置;
- 设备数据:推送通知令牌(Firebase Cloud Messaging)、应用安装的随机标识符、应用版本和平台——用于向您发送通知并保障应用正常运行;
- 崩溃报告和诊断数据——用于发现和修复错误:应用中通过 Firebase Crashlytics(报告仅关联您账户的内部标识符和应用语言,应用日志中的电子邮箱地址和电话号码会被隐藏),服务器上通过 Sentry;
- 使用统计:应用中通过 Firebase Analytics(事件关联到您的账户标识符;应用不获取设备的广告标识符;应用不会就这些统计单独征求同意),网站上在您同意 Cookie 后通过 Google Analytics,并通过我们自己基于随机访客标识符的访问统计;
- 您在 Swipe Match 中查看、打开或跳过了哪些经纪人卡片。这些记录不包含您的联系方式,保存 180 天;
- 购买记录:银行卡付款通过 Stripe 进行,应用内购买通过 App Store 和 Google Play 进行,应用内购买由 RevenueCat 服务记录。您在支付服务一侧输入银行卡号,GREM 不保存卡号。
应用不会读取您的通讯录、短信或通话记录。Android 的电话号码访问权限仅用于通过应用拨打的电话,以便在锁屏界面显示来电;应用不会将您的 SIM 卡号码发送到任何地方。
基于 IP 地址的位置数据来源:
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. 经纪人何时获得您的电话号码Swipe Match。只有您亲自选择的经纪人才能获得您的姓名和电话号码,而且必须经过您的明确同意:在发送申请前,我们会显示以下文字:“发送申请即表示您接受平台条款,并同意将您的号码提供给所选经纪人。”经纪人只有在接受申请后才能获得您的姓名和号码;在此之前,他看到的申请不含您的联系方式。
备选经纪人。如果您的申请中设有备选经纪人(您可以在发送前将其移除),而所选经纪人未及时回复或拒绝了申请,申请将转给备选经纪人。备选经纪人同样只有在接受申请后才能获得您的姓名和号码。
网站上未选择经纪人的申请。此类申请由 GREM 挑选的经纪人接收,且仅在满足两个条件时:您明确同意转交联系方式(例如勾选“将我的电话号码提供给 GREM 挑选的经纪人”),并且已通过验证码确认电话号码。否则,任何人都不会获得您的联系方式。接受申请的经纪人可以看到您的姓名、号码和申请内容;如果您填写了电子邮箱和备注,也能看到它们。
同事推荐。对于未选择经纪人的申请,经纪人可能由平台上的另一位经纪人推荐,推荐人可能因此获得该经纪人的部分佣金。您的条件不变。只有接受申请的经纪人才会获得您的联系方式。推荐人看不到您的姓名、号码和其他信息,只会得知同事是否接受了申请以及是否成交,不包括金额和房源。
匿名需求。对于您已同意将联系方式提供给 GREM 挑选的经纪人的申请,平台上的经纪人会以匿名形式看到它们,不包含您的姓名、电话和申请原文:交易和房产类型、预算(可能以区间显示)、平台目录中的城市和区域、申请时间以及号码是否已确认。其他国家的平台经纪人也可能看到这些卡片。只有接受申请的经纪人才会获得您的联系方式。
平台上的经纪人可能会看到来自公开来源(社交网络、即时通讯工具、分类广告网站)的公开帖子:对方在找什么、城市、预算、简短摘录以及原帖链接。来自这些来源的电话号码、电子邮箱和其他联系方式,我们不会转交给经纪人:经纪人会在对方自己发布帖子的地方与其联系。如果您不希望自己的帖子被展示,请发送邮件至
[email protected]。
平台上的注册专业人士可以看到智能请求,但看不到您的联系方式:请求中的姓名、电话和电子邮箱只提供给您亲自选择的专业人士,或您在该请求的对话中回复过的专业人士。
根据平台条款,经纪人只能将您的数据用于处理您的申请。
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. 删除数据、访问数据和拒绝- 您可以自行删除账户:在应用中(“设置” → “删除账户”)、在网页版控制台中,或在删除申请页面上: grem.capital/zh/delete-account
- 删除后,您的个人资料将被隐藏,账户登录将被关闭,会话将结束,您也不会再收到通知。交易、合同、付款以及申请事件日志将按法律要求的期限保存。
- 如需获取您的数据副本或更正数据,请发送邮件至 [email protected],并注明账户的电子邮箱或电话号码。
- 您可以随时拒绝我们将您的联系方式转交给经纪人:在 Swipe Match 申请聊天中发送“STOP”,在 WhatsApp 或 Telegram 中回复自动消息“STOP”,或发送邮件至 [email protected]。此后,我们不会将您的联系方式转交给任何并非由您亲自选择的经纪人。在对话中发送的拒绝还会撤回您对通过短信、即时通讯工具和电子邮件接收消息的同意。
6.2. 我们保存数据的期限- 验证码请求(号码和验证码指纹)——验证码失效后最多保存一天;
- 账户登录会话及推送通知令牌——自最后一次活动起 30 天;
- Swipe Match 中的卡片浏览记录——180 天;
- Swipe Match 申请的事件日志(选择经纪人、接受、联系、会面、成交)——按平台条款所述保存 5 年;
- 访问我们服务器的技术日志——90 天;
- 德国的审核文件(经纪人依据 §34c GewO 的许可证、房源 Denkmalschutz 和 Erbbaurecht 标记的证明文件)——在状态有效或房源存在期间保存;房源删除后,仅保留我们工作人员驳回的文件记录(不含文件本身:地址指纹、原因和提交人)2 年,以防同一份伪造文件再次提交;
- 您拒绝向经纪人转交联系方式的记录——保存至您要求撤销为止;为此我们只保存您号码和电子邮箱的不可逆指纹。
其他数据在其收集目的所需期间内保存,并按法律要求的期限保存。
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].