PRIVACY POLICY

This Privacy Policy is made by SCHAETZ CRO, Seefeldstrasse 219, 8008 Zürich, for its online real estate matching platform www.globalrecom.com (hereinafter referred to as: “GLOBALRECOM”) and informs about how SCHAETZ CRO handles data, which are collected and processed on GLOBALRECOM. SCHAETZ CRO’s is responsible for processing personal data and the compliance with the applicable data protection laws on GLOBALRECOM.

SCHAETZ CRO abides by the applicable data protection regulations. "Personal Data" and/or “Data” means any information concerning personal or factual circumstances of an identified or identifiable individual person. Therefore, it involves information that can be assigned to an individual person. "Processing" means any handling of Data and in particular collection, storage, administration, use, transmission, disclosure or deletion of Data. Please note that the present Privacy Policy may be amended from time to time. Therefore SCAHETZ CRO recommends regularly visiting this Privacy Policy. Third party websites which may be accessed through GLOBALRECOM are not subject to the principles set forth herein. SCHAETZ CRO does not assume any responsibility and/or liability for compliance with data protection of any third-party websites.

In this Privacy Policy SCHAETZ CRO informs about which Personal Data is collected and saved on GLOBALRECOM, and about how this Data is used and with whom this data may be shared. SCHAETZ CRO also informs about the rights of the Users of GLOBALRECOM with respect to the handling of Personal Data.

1. Scope and Purpose of Processing of Personal Data

a) Visiting GLOBALRECOM

Web-server technology of GLOBALRECOM automatically saves general technical visit information in so-called log files. This includes the IP address of the device used, from which the visit takes place, information on the type of browser, internet service provider and the operating system used, which digital services were visited, reference and exit sites, time and duration of the visit. The collection and processing of such information serves to enable the use of GLOBALRECOM (connection), to ensure security and stability of the platform, to analyse the use of GLOBALRECOM’s offers and services, to collect broad demographic information and generally for the optimisation of GLOBALRECOM (in particular, but not limited to, product enhancements, marketing activities, etc.) as well as for internal statistical purposes. An identification of the User does not take place. Likewise, no link between this automatically collected information and the Personal Data collected on GLOBALRECOM is generated in principle. However, exception is made for accessing GLOBALRECOM on a registered account. With regard to the processing of Personal Data of registered Users please refer to Section 1(b) and 1(c) below. GLOBALRECOM also uses cookies and analysis tools (e.g. Google Analytics). For further information please refer to section 8 and 9 of this Privacy Policy.

b) Accessing GLOBALRECOM through a Registered Account

For personalised services and access to the access-protected areas of GLOBALRECOM as well as for processing of requests and administration of subscriptions the registration and thus the creation of a User Account are required in accordance with the Utilisation Agreement (utilisation agreement). Registration is granted exclusively to qualified real estate agents. The entering of certain Personal Data from the User (hereinafter referred as to: “User Data”) will be required, such as e.g.:

- e-mail address which can also be used as username;

- contact e-mail address for other Users;

- password;

- first name and family name;

- company name;

- licensed areas;

- address (complete mailing address, ZIP, city);

- phone number;

- information regarding subscribed newsletters or other advertising.

By using search preferences User may voluntarily enter and store more Personal Data.

The User Data will be used to handle and administer the digital services offered on GLOBALRECOM, to check the data entered with regard to its plausibility, for the creation, implementation and amendment of the Utilisation Agreement (www.globalrecom.com/utilisation-agreement) between the User and SCHAETZ CRO, to exchange the User contact details upon a acceptance of a contact request, and for billing purposes. To the extent that a User voluntarily posts further data on GLOBALRECOM, then this data may also be published by SCHAETZ CRO on GLOBALRECOM, and therefore be regarded as publicly available. SCHAETZ CRO informs that such further data once published on the internet even if promptly deleted or anonymised by the User or SCHAETZ CRO may still remain available for third parties, e.g. for search engines.

By confirming the registration or the amendment of the User Data the User warrants and represents that the User Data entered on GLOBALRECOM is complete, true and updated.

c) Visiting GLOBALRECOM as a Registered User

During the visit of GLOBALRECOM by registered Users SCHAETZ CRO collects Data which is required in order to provide the matching services to be provided by GLOBALRECOM under the Utilisation Agreement (utilisation agreement) , for statistical purposes in order to enable the smooth functioning of the platform and to analyse, optimise and personalise the use of GLOBALRECOM’s services. SCHAETZ CRO collects Data on whether and how the digital services of GLOBALRECOM are used, in particular which functions and services are perceived. When using GLOBALRECOM as a registered User, Personal Data may be disclosed to other registered Users. Upon acceptance of a contact request based on the matched real estate objects GLOBALRECOM will disclose to both respective Users the contact details of the other respective User (hereinafter referred to as: “the User Contact Details”), such as:

- first name and family name of the User;

- company name of the User;

- contact e-mail address of the User;

- address of the User (complete mailing address, ZIP, city);

- phone number of the User.

The User warrants and represents that the User Contact Details are complete, true and up to date.

order to use the real estate matching services of GLOBALRECOM registered Users are able to enter following data and store the following type of documents:

(i) Object Data

Registered Users are able to enter the following data and store the following documents (hereinafter referred to as: “Object Data”) regarding the real estate objects offered and searched for (hereinafter referred to as: “Object(s)”).

- first name and family name of the client searching for or offering an Object (hereinafter referred to as: “Name of the Client”);

- type of property;

- type of contract (purchase, rent or holiday);

- urgency level;

- (minimum) size (m2);

- (minimum) number of rooms;

- (minimum/maximum) construction year;

- (maximum) price (incl. currency);

- ZIP-code;

- geographic area;

- search/offer headline (hereinafter referred to as: “Headline”);

- remarks regarding the Object, the offer and/or search (hereinafter referred to as: “Remarks”);

- (target) availability date;

- uploaded documents (e.g. plans, etc.).

The User represents and warrants that all Object Data entered is accurate, true and up to date. The User furthermore represents and warrants that she/he has all required authorisations from her/his Client(s) to enter and store the Object Data on GLOBALRECOM. All Object Data are received and stored encrypted. In principal the Object Data can be seen, amended and deleted only by SCHAETZ CRO and the registered User who has entered the respective Object Data. While the Name of the Client, the ZIP-code and the uploaded documents are not visible to other Users, other Users will see all other Object Data and a generic geographic area indication of the Object. The User shall not enter any Personal Data in the fields foreseen for the Headline and the Remarks.

(ii) Client Data

Registered Users are able to enter the following Personal Data (hereinafter referred to as: “the Client Data”) of their Clients (hereinafter referred to as: “the Client(s)”):

- first name and family name of the Client;

- first name and family name of the Client’s partner (hereinafter referred to as: “the Partner”);

- number of children resp. family members;

- company name of the Client;

- full address of the Client;

- email-address of the Client;

- email-address of the Partner;

- phone number of the Client;

- phone number of the Partner;

- remarks

The User represents and warrants that all Client Data entered is accurate, true and up to date. The User furthermore represents and warrants that she/he has all required authorisations from her/his Client(s) to enter and store the Client Data on GLOBALRECOM. All Client Data are received and stored encrypted. The Client Data can be seen, amended and deleted only by SCHAETZ CRO and the registered User who has entered the respective Client Data.

(iii) Data Disclosed upon Acceptance of a Contact Request

Upon acceptance of contact request regarding an Object search and an Object offer, which have been matched according to the criteria foreseen pursuant to the sole discretion of GLOBALRECOM, the following User and Object Data will be mutually disclosed to the respective accepted User (hereinafter referred to as: “Accepted User”):

- first name and family name of the Accepted User;

- company name of the Accepted User;

- full address of the Accepted User and of his/her company;

- phone number of the Accepted User;

- contact email-address of the Accepted User;

- type of property;

- type of contract (purchase, rent or holiday);

- urgency levels;

- minimum/actual size (m2);

- minimum/actual number of rooms;

- minimum/maximum and actual construction years;

- minimum/maximum prices (incl. currency);

- ZIP-code;

- geographic area;

- Headline;

- (target) availability date;

- Remarks;

- uploaded documents (e.g. plans, etc.).

Upon accepting a contact request the Accepted Users are free to establish outside GLOBALRECOM a direct contact among each other and to directly exchange further details and Personal Data, including Client Data and further Object Data. SCHAETZ CRO and GLOBALRECOM will not be involved in such direct communication, negotiation and/or stipulation of agreements between the Accepted Users respectively between their Clients.

(iii) Payment for Services

After a possible initial free period of access to GLOBALRECOM as specified in the Utilisation Agreement (utilisation agreement) registered Users need to pay an annual Usage Fee. This Usage Fee is payable through an online payment system such as credit card or PayPal, or through such other online payment system as may be provided by GLOBALRECOM. The processing of personal and payment Data is performed directly through the provider of the respective online payment system. SCHAETZ CRO does neither know nor store such payment information. Therefore, the privacy policy of the respective provider of the online payment system applies.

d. Consent

By entering and amending the Data, the User consents to the processing, use and disclosure of such Data within the context and Purposes described in this Privacy Policy.

2. Email Marketing

By registering on GLOBALRECOM the User agrees that his Personal Data is used for personalised marketing campaigns. This concerns both personalised advertising emails, e.g. emails containing general information or advertising (newsletters), as well as the delivery of personalised content and advertising on GLOBALRECOM. For this purpose SCHAETZ CRO may automatically evaluate information about the User’s usage patterns on GLOBALRECOM (hereinafter referred to as: “Usage Data”). By registering a User Account a User automatically subscribes to SCHAETZ CRO’s and GLOBALRECOM’s newsletters and the User’s email address can be used accordingly for promotional purposes, until the User unsubscribes from the corresponding newsletter. At the end of each newsletter email sent by SCHAETZ CRO and/or GLOBALRECOM the User will find a link in order unsubscribe. Furthermore, the User can unsubscribe at any time from the newsletter by sending an email to privacypolicy@globalrecom.com. SCHAETZ CRO is entitled to commission third parties with the technical processing of marketing measures and may share the Data for this purpose with third parties (cf. below Section 3).

3. Transfer of Data to Third Parties

SCHAETZ CRO may cooperate with other companies and/or individuals or instruct other companies and/or individuals with the processing and storage of Data. These third parties may have access to Personal Data or to Usage Data, however only to the extent necessary for the performance of their tasks. Hence, the Personal Data and Usage Data may be shared for the evaluation, improvement and configuration of GLOBALRECOM’s services, respectively the services of related companies for customer care, personalised use and for marketing purposes. Moreover, SCHAETZ CRO may share the Personal Data und Usage Date with third parties to the extent that it is required in order to fulfil their contractual obligations. These service providers are entitled to use the Personal Data exclusively for fulfilling their contractual obligations and not for any other purposes. To the extent necessary for the purposes mentioned in Section 1, the transfer may also take place abroad. However, the Personal Data which is provided on GLOBALRECOM will not be sold, rented or traded. Except for the transfer of data described above, SCHAETZ CRO shares the Personal Data only based on the User’s approval, based on a legal obligation, if it is necessary for SCHAETZ CRO in order to fulfil its services under the Utilisation Agreement (utilisation agreement) and/or in order to enforce SCHAETZ CRO’s rights, in particular the enforcement of claims arising from the Utilisation Agreement (utilisation agreement). In case of a sale, merger and/or reorganization of some or all of the assets of SCHAETZ CRO, Personal Data can be transferred as part of this transaction or reorganization, sold or otherwise shared with third parties.

4. Handling of Personal Data for Marketing and Analysis Purposes

SCHAETZ CRO aims at continuously improving the services offered on GLOBALRECOM. Therefore, SCHAETZ CRO may use with regard to user-specific usage behaviour various analysis tools in order to analyse historical and future Data at its disposal. In order to exclude the collection of usage data or at least to reduce such collection Users have to disable cookies following the steps mentioned in Section 8. This may have the result that the some of the services offered on GLOBALRECOM are no longer available.

5. Transfer of Personal Data Abroad

SCHAETZ CRO is are entitled to transfer Personal Data to third parties (contracted service) abroad, where this is appropriate for the data processing operations as described in this Privacy Policy. Such third parties are bound to the same extent as SCHAETZ CRO to compliance with data protection. If the level of data protection does not meet the level as foreseen in Switzerland, SCHAETZ CRO contractually ensures that the protection of Personal Data meets the Swiss standards at any time.

6. Entitled to Information, Correction or Deletion

Users and Clients have the right at any time to enforce their privacy rights and to request information about whether and what Personal Data is processed by SCHAETZ CRO. By provision of a written request to privacypolicy@globalrecom.com. Users and Clients may upon showing appropriate proof of their identity at any time view their Personal Data, correct, block or delete it. SCHAETZ CRO reserves its right to correspond in this regard with the User and/or Client. However, under statutory or contractual preservation periods (e.g. for billing purposes) SCHAETZ CRO needs to preserve some Personal Data even after a request to delete Personal Data is made, and SCHAETZ COR may only lock such Personal Data for this purpose. Furthermore, a deletion or block of Personal Data may result for a User in not being able to further use the services on GLOBALRECOM any longer.

7. Data Security

SCHAETZ CRO uses appropriate technical and organizational security measures in order to protect Personal Data against accidental, unlawful or unauthorized manipulation, destruction, alteration, access, disclosure or use, as well as partial or total loss. The security measures are adjusted and improved continuously in line with technological development. SCHAETZ CRO accepts no liability for any loss of data or for the acknowledgement and/or use by third parties. If a User registers as a User, then access to the respective user account is granted only by entering the Access Code. Payment and access information should always be treated as confidential. The browser window should be closed after finishing the visit on GLOBALRECOM, especially if the computer is shared with others. SCHAETZ CRO’s employees and the service providers appointed are obliged to maintain secrecy and to comply with data protection regulations.

8. Cookies

Cookies help to render the use of GLOBALRECOM easier, more enjoyable and reasonable. Cookies are data files which are automatically stored by the User’s browser on the hard drive of the User’s computer when GLOBALRECOM is visited. Cookies neither damage the hard disk of the User’s computer, nor will cookies send Personal Data to SCHAETZ CRO. SCHAETZ CRO uses cookies, for example, to track who has visited GLOBALRECOM and in order to track how often certain pages or offers are visited, which parts of GLOBALRECOM are enjoying great popularity, as well as in general to assess how GLOBALRECOM is used. Other cookies are used in order to freely move through GLOBALRECOM and use its functionality, especially when accessing access protected areas. Generally, the use of cookies serves to improve services and to make the online platform more effective and safer. Cookies are used also to collect information in order to offer personalised advertising which may interest the User. Most internet browsers automatically accept cookies. User can configure the browser so that no cookies are stored on the computer or a message appears whenever a new cookie is received by the browser. The digital services of GLOBALRECOM can basically be used without accepting cookies, but some features may then be limited.

9. Tracking and Analysis Tools

The use of the digital services of GLOBALRECOM is also measured and evaluated by using various technological systems, primarily offered by third parties such as Google Analytics. These measuring can be carried out both anonymously and person related. It is possible that the Data collected is disclosed by SCHAETZ CRO or by such third party offering such technical systems to other third parties for processing. The most commonly used analysis tool is Google Analytics, a service of Google Inc. Thus, the data can always be transmitted to a Google server in the U.S., where the IP addresses are anonymised using IP-anonymisation, in order not to allow an identification. The IP address transmitted by the User’s browser to Google Analytics will not be merged with other data from Google. The collection and processing of these Data by Google Analytics can be prevented by setting an opt- out cookie, which prevents future collection of data, by visiting this website: (http://tools.google.com/dlpage/gaoptout?hl=.)

10. Plug-ins and Integration of Third Parties’ Offers

The digital services of SCHAETZ CRO on GLOBALRECOM may be linked in various ways with functions and/or systems of third-parties, such as through integration of plug-ins of social networks of third parties, in particular Facebook, Google Plus and Twitter. If a User has got an account with such third parties, the User should be aware that such third party may also be able to measure and evaluate the use of services rendered on GLOBALRECOM. Furthermore, personal data, such as IP address, personal browser settings and other parameters may be transmitted to such third parties and stored there. When using social login services such as Facebook-Connect, the supplier of such social login services may transmit to GLOBALRECOM Personal Data such as name, email address and profile picture. SCHAETZ CRO has no control over the use of such Personal Data collected by such third parties and does not assume any responsibility or liability therefore.

11. Contact

If a User and/or Client has any questions about data protection on GLOBALRECOM, or wishes to request information or would like to request the deletion of his/her data, please send an email to privacypolicy@globalrecom.com.

12. Changes in the Privacy Policy

As GLOBALRECOM evolves, new technologies may be necessary to change this Privacy Policy. Any significant change in the Privacy Policy will be communicated to the Users via email to the email address specified in the User’s Contact Details or by a note placed after logging into the User Account. The current Privacy Policy can also be accessed at any time and printed out on the website at (http://www.globalrecom.com/en/privacy-policy.html.).

December 2018 Copyright © SCHAETZ CRO - all rights reserved.

Any further processing, republication or permanent storage without SCHAETZ CRO’s express permission is prohibited.