PRIVACY POLICY
Updated - November 2022
PREAMBLEPURPOSE OF THIS PRIVACY POLICYGENERAL PRINCIPLES AND COMMITMENTTYPES OF DATA COLLECTEDDATA ORIGINSPURPOSES OF THE PROCESSINGLEGAL BASESDATA RECIPIENTSDATA STORAGE DURATIONYOUR RIGHTSOPTIONAL OR MANDATORY NATURE OF ANSWERSRIGHT OF USESUBCONTRACTINGINTERNATIONAL DATA TRANSFERSSECURITYDATA BREACHRIGHT TO SUBMIT A COMPLAINT TO THE CNILEVOLUTIONFOR MORE INFORMATIONPREAMBLE
What is the HOMEETY project?
The HOMEETY project is a simple gateway between Web2 and Web3 which democratizes the use of Web3 technologies. HOMEETY's primary ambition is to provide access to blockchain functionalities through a mobile application linked to a 3D environment, Metaverse . Imagine a friendly and fun space with all your Web2 habits, your social networks, newsfeed... Now imagine this happening in a Metaverse environment , with all the functionality of Web3; your wallet, your NFTs , your assets, your tokens , easy access to create smart contracts and much more. Thanks to blockchain technology, the HOMEETY application connects virtual and real assets . Thanks to HOMEETY, you find your identity as well as your digital attributes correlated to reality thanks to the fundamentals of the blockchain.
What is this Privacy Policy for?
The website accessible at the address www.homeety.com (hereinafter “the Site”) is intended to present and host the HOMEETY project. When you visit the Site, or use our products, we collect information that is sent to us by your computer, mobile phone or other access device. When you browse the Site, or use our products or services , we (or Google Analytics or a similar service provider on our behalf) may process your personal data. We inform you here of the processing of your personal data and the circulation of this data on the site www.homeety.com . This policy explains what data METAMOOZ is likely to collect, how it is used, with whom it is likely to be shared, and the measures taken to ensure its confidentiality and security. The implementation of personal data processing is governed in particular by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data. personnel and the free movement of such data, hereinafter referred to as "GDPR". The GDPR requires the data controller to provide the data subject with certain information. Thank you for your attention to the following information. For any questions, we invite you to contact our Data Protection Officer whose contact details are given below.
Definitions
For a good understanding of this Privacy Policy, it is specified that:“User(s)”: designates any natural or legal person who consults the website www.homeety.com who connects to the User interface of the Site, and who comes into contact with the HOMEETY teams through the page “ Contact ";“controller”: means the natural or legal person who determines the purposes and means of processing personal data. Under this policy, the data controller is METAMOOZ;“processor”: means any natural or legal person who processes personal data on behalf of the controller. In practice, these are therefore the service providers with whom the METAMOOZ company works and who intervene on the personal data that it processes;“persons concerned”: means the people who can be identified, directly or indirectly. They are, hereunder, qualified as “User”;“recipients”: designates the natural or legal persons who receive communication of personal data. The recipients of the data can therefore be both internal recipients and external organizations (support service providers, state administrations, etc.).
PURPOSE OF THIS PRIVACY POLICY
1.1. In order to meet the expectations of visitors to its website www.homeety.com , and to improve the functionality of this site, the company METAMOOZ implements and uses the processing of personal data relating to its Users.
1.2. The purpose of this policy is to satisfy METAMOOZ's obligation to inform and thus to formalize the rights and obligations of its Users with regard to the processing of their personal data.
1.3. The processing of personal data can be managed directly by the company METAMOOZ or through a subcontractor specifically designated by it. it.
GENERAL PRINCIPLES AND COMMITMENT
2.1. No processing is implemented by METAMOOZ concerning User data if it does not relate to personal data collected by or for METAMOOZ or processed in connection with the website www.homeety.com and if it does not does not meet the general principles of the GDPR.
2.2 Any new processing, modification or deletion of an existing processing will be brought to the attention of the Users by means of an amendment to this policy.
TYPES OF DATA COLLECTED
3.1. METAMOOZ will in principle collect the following data from Users:
3.1.1. Non-technical data of Users who are natural persons (collected and processed according to use cases):The User's identification data: surname, first name, pseudonymContact details: Telephone, e-mail address, postal address…The registration of its cryptographic address where to receive the HOMEETYS.Document transmitted by the User as an attachment of his exchanges with METAMOOZ (Photo(s), videos, WORD or PDF documents, etc.)Information transmitted as part of the use of the "Contact" page of the website www.homeety.com
3.1.2. Non-technical data of Users who are natural persons (collected and processed according to use cases):Legal form,Commercial name or Company name,Registration numberRegistered Address,Registration certificate (K-bis extract or copy of any act or extract from the official register dated less than 3 months or extract from the Official Journal),Copy of the information on the beneficial owner(s) of the company, the natural persons who ultimately control the legal person wishing to become a subscriber, as well as the organization chart of the company allowing the beneficiaries to be clearly identified workforce.
3.1.3. The technical data of Users (collected and processed according to use cases):Identification data (logins, passwords, IP address, information generated by the user's terminal, etc.)Connection data (logs in particular)Data related to consent (click)
DATA ORIGINS
4.1. METAMOOZ collects the data of its Users from: data provided by the User when browsing or connecting to the Site electronic files or forms completed by the User; exchanges via social networks data provided by our business and banking partners third parties such as commercial intelligence, anti-fraud, anti-money laundering and terrorist financing, and anti-corruption agencies, in compliance with data protection regulations.
PURPOSES OF THE PROCESSING
5.1. The purpose of processing corresponds to the objective pursued, the need to which it responds for the data controller. Depending on the case, METAMOOZ collects and processes information about you and your data for the following purposes:Ensuring smooth navigation on our SiteAllow Users to register for the HOMEETY interface;Allow Users to connect to the HOMEETY interface;Manage our relationship with the User;Manage our events, newsletters or information feeds;respond to all questions posed to us (by telephone or online);produce statistics to improve our products and servicesprovide, where applicable, to the company you represent, products and services and validate any instruction or transaction that you request or authorize as the legal representative of the company you representmeet all of our legal, regulatory or tax obligations and in particular ensure our compliance with the laws and regulations in force;prevent or detect any risk of fraud or financial crime;
5.2. Personal data is subject to computerized processing for the purposes and under the conditions specified above, whether before, during or after entering into a relationship with METAMOOZ.
5.2. 1. With respect to the implementation of HOMEETY products and services: METAMOOZ uses your personal data as part of the implementation of products and services related to its activities, in particular by ensuring the security of personal data which is collected and stored in accordance with legal and regulatory obligations.
5.2.2. METAMOOZ uses your personal data for authentication purposes to provide you with online platforms and mobile applications. These platforms may also allow you to communicate with METAMOOZ.
5.2.3. Regarding risk management and crime prevention/detection: METAMOOZ uses your personal data to measure, detect, and reduce the likelihood of risks and to implement our internal risk strategy; in particular to take measures to prevent crimes and other offenses (including money laundering, terrorist financing, the fight against corruption and fraud). These risk prevention treatments are based on compliance with our legal and regulatory obligations. METAMOOZ is also likely to share your personal data with the competent judicial authorities and any other third party if the law expressly authorizes us to do so, for the purposes of preventing or detecting crimes and other offences.
5.2.4. Your personal data may be processed in order to promote and provide information about our products and services. You can, at any time, withdraw your consent to the use of your personal data for commercial prospecting purposes.
5.2.5. METAMOOZ is also likely to use your personal data and share it with the competent judicial authorities and any other third party if the law authorizes us to do so, in order to protect its rights, particularly in the context of the defense or protection of rights and legal interests (for example the recovery of sums due, the assignment of receivables, the defense of our intellectual property rights), legal actions, the management of claims or disputes, in the event of corporate restructuring or other operations merger or acquisition. This use of your personal data is based on the legitimate interests of METAMOOZ.
5.3. We are likely to use automated systems (i) for decision support, for example when you wish to subscribe to a product or service, (ii) or during checks aimed at preventing the risk of fraud, money laundering and financing of terrorism or corruption.
LEGAL BASES
6.1. METAMOOZ undertakes to use your personal data only (i) if you have consented to it or (ii) if this use is based on one of the legal bases provided for by the text:the performance of a contract entered into or of an undertaking in respect of which you and we are bound; compliance with a legal, regulatory or tax obligation; the preservation of the public interest, such as the prevention or detection of fraud or financial crime; safeguarding the vital interests of the data subject; the protection of the legitimate interests pursued by METAMOOZ.
DATA RECIPIENTS
7.1 In order to accomplish the aforementioned purposes, METAMOOZ may share your personal data with authorized internal or external recipients. The METAMOOZ company ensures that your data is only accessible by these recipients, and when necessary. Internal recipients can be the following:The staff of the METAMOOZ company (including trainees)The communication department of METAMOOZ, in particular for commercial prospecting purposesMETAMOOZ entities responsible for the management or prevention of operational risks (risk assessment, security and prevention of non-payment and fraud, fight against money laundering, etc.) The IT department
The technical external recipients may be the following:Service providers and subcontractors performing services on our behalf or support services (example: Blockchain service providers, KNOW YOUR CUSTOMER service providers, translation service, IT service provider, reprography, etc.)The partners, in particular commercial and banking, of METAMOOZThe Administration and the administrative, financial, judicial authorities or State agencies, public bodies on request and within the limits of what is permitted by the regulationsCertain regulated professions such as lawyers, notaries, auditors.
7.2. We reserve the right to share the information we have about you with companies with which we plan to merge or be acquired (if such a combination occurs, we will require the newly combined entity to follow these terms with respect to relates to your personal information, and you will also receive prior notification of any changes in the applicable policy).
DATA STORAGE DURATION
8.1. METAMOOZ retains data only for as long as necessary:for the purposes set out in this policy,compliance with regulatory obligations and preservation of evidence in contractual matters until the rights of the parties or third parties concerned are extinguished (particularly in terms of insurance). Consequently, except for special deadlines, the data may be kept for the maximum limitation period.
8.2. After this period, the data is either deleted or stored after being anonymized.8.3. Users are reminded that deletion or anonymization are irreversible operations and that METAMOOZ is no longer, thereafter, able to restore them.
YOUR RIGHTS
In accordance with the applicable regulations, in particular European Regulation 2016/679, known as the general data protection regulation (RGPD) and the national provisions relating to data processing, files and freedoms, the persons whose personal data are collected may exercise the following rights:
9.1. Right of access (right to copy)
9.1.1. Users have the right to ask METAMOOZ for confirmation whether or not data concerning them is being processed.
9.1.2. Users also have a right of access, the latter being subject to compliance with the following rules: the request comes from the person himself and is accompanied by a copy of an up-to-date identity document; the request must be made in writing to the following e-mail address: contact@homeety.com
9.1.3. Users have the right to request a copy of their personal data being processed from METAMOOZ.
9.1.4. Users are informed that this right of access cannot relate to confidential information or data or for which the law does not authorize communication.
9.2. Right to erasure
9.2.1. You can request the deletion of your personal data, within the limits of what is permitted by the regulations.
9.2.2. The right to erasure of User data will not apply in cases where the processing is implemented to meet a legal obligation.
9.2.3. Apart from this situation, Users may request the erasure of their data in the following limited cases:when the personal data are no longer necessary in relation to the purposes for which they were collected or processed;when the data subject objects to processing necessary for the purposes of the legitimate interests pursued by METAMOOZ and there is no overriding legitimate reason for the processing;when the personal data collected has been unlawfully processed.
9.4. Right to portability
9.4.1. When this right is applicable, you can request the communication of the personal data that you have provided to us; or, where technically possible, the transfer thereof to a third party.
9.4.2. METAMOOZ is entitled to the portability of data in the particular case of data communicated by the Users themselves, on online services offered by METAMOOZ and for purposes based on the sole consent of individuals.
9.5. Post-mortem law
9.5.1. Users are informed that they have the right to formulate directives concerning the storage, erasure and communication of their post-mortem data.
9.5.2. The communication of specific post-mortem instructions and the exercise of their rights are made by e-mail to the address: contact@homeety.com accompanied by a signed copy of an identity document.
9.6. Right of rectification
9.6.1. If you believe that your personal data is inaccurate or incomplete, you can request that this data be amended accordingly. The exercise of this right is exercised with the company METAMOOZ, by sending an e-mail to contact@homeety.com;
9.6.2. In order to allow regular updating of the personal data collected by METAMOOZ, the latter may solicit the Users who will have the possibility of satisfying its requests.
9.6.3. METAMOOZ cannot be blamed for a lack of updates if the User does not update their data.
9.7. Right to withdraw your consent
9.7.1. If you have given your consent for the processing of your personal data, you can withdraw this consent at any time by informing the company METAMOOZ by email at the address: contact@homeety.com
9.7.2. The withdrawal of the User's consent will not affect the legality of any processing carried out by METAMOOZ prior to the User's withdrawal, nor the processing of the User's personal information carried out on the basis of lawful processing grounds other than the consent.
9.8. Right of opposition
9.8.1. You also have a right of opposition, allowing you to oppose the processing of your personal data for reasons relating to your particular situation.
9.8.2. You have the right to object at any time to your personal data being used for commercial prospecting purposes, or for profiling purposes if this profiling is linked to commercial prospecting.
9.8.3. These rights can be exercised with METAMOOZ at the address: contact@homeety.com
9.8.4. You also have the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) - 3 Place de Fontenoy - TSA 80715 - 75334 Paris - Cedex 07.You will find more information about your rights on the CNIL website: https://www.cnil.fr
9.9. JUSTIFICATION
9.9.1. For all the mentioned rights enjoyed by the User and in accordance with the legislation on the protection of personal data, you are informed that these are rights of an individual nature which can only be exercised by the person concerned. with respect to its own information.
9.9.2. To fulfill this obligation, we will verify the identity of the data subject.Under these conditions METAMOOZ will respond to all requests received from persons wishing to exercise their data protection rights in accordance with applicable data protection laws.
OPTIONAL OR MANDATORY NATURE OF ANSWERS
10.1. Users are informed on each personal data collection form of the mandatory or optional nature of the answers by the presence of an asterisk.In the event that answers are mandatory, the company METAMOOZ explains to Users the consequences of a lack of answer.
RIGHT OF USE
11.1. METAMOOZ is granted by Users a right to use and process their personal data for the purposes set out above.
11.2. However, the enriched data which is the result of processing and analysis work by METAMOOZ, otherwise known as enriched data, remains its exclusive property (usage analysis, statistics, etc.).
SUBCONTRACTING
12.1. METAMOOZ informs its Users that it may involve any subcontractor of its choice in the processing of their personal data.In this case, the company METAMOOZ ensures compliance by the subcontractor with its obligations under the GDPR.
12.2. METAMOOZ undertakes to sign a written contract with all its subcontractors and imposes on the subcontractors the same data protection obligations as it does.
12.3. In addition, METAMOOZ reserves the right to carry out an audit with its subcontractors in order to ensure compliance with the provisions of the GDPR.
INTERNATIONAL DATA TRANSFERS
13.1. METAMOOZ favors the hosting of data primarily in France and then within the European Union. However, some projects may lead METAMOOZ to make international transfers.
13.2. In the event that your personal data is transferred to, hosted or accessed from a country outside the European Union where the data protection legislation is not equivalent to that of the European Union in the context of a particular operation; these transfers would be governed by the appropriate security and control measures, in compliance with the rules laid down by the CNIL.
SECURITY
14.1. It is up to METAMOOZ to define and implement the technical security measures, physical or logical, that it deems appropriate to fight against the destruction, loss, alteration or unauthorized disclosure of data accidentally. or illegal.
14.2. METAMOOZ has taken the necessary physical, technical and organizational measures to ensure this security of the data collected.These measures mainly include:security of access to our computer stations and smartphones (access code changed regularly); login and password for all our business applications; the management of authorizations for access to data (specific for our financial and accounting and communication departments);VPN for remote connections;complex password for our Wi-Fi network changed every month.Other security measures we use include firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.To implement these measures or ensure their effectiveness, METAMOOZ may be assisted by any third party of its choice to carry out, at the frequencies it deems necessary, vulnerability audits or intrusion tests.
14.3. We also allow access to personal information only to those employees who need it to fulfill their job responsibilities. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations.
14.4. In any case, the company METAMOOZ undertakes, in the event of a change in the means aimed at ensuring the security and confidentiality of personal data, to replace them with means of superior performance. No change can lead to a regression in the level of security.
14.5. In the event of subcontracting of part or all of the processing of personal data, METAMOOZ undertakes to contractually impose security guarantees on its subcontractors by means of technical protection measures. of this data and the appropriate human resources.
DATA BREACH
15.1. In the event of a personal data breach, METAMOOZ undertakes to notify the CNIL under the conditions prescribed by the GDPR.
15.2. If said violation poses a high risk to Users and the data has not been protected, the company METAMOOZ: notify the Users concerned; will communicate to the Users concerned the necessary information and recommendations.
RIGHT TO SUBMIT A COMPLAINT TO THE CNIL
16.1. Users concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely the CNIL in France, if they consider that the processing of personal data concerning does not comply with European data protection regulations, at the following address:CNIL Complaints department 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 Tel: 01 53 73 22 22
EVOLUTION
17.1. This policy may be modified, periodically updated or adjusted at any time to reflect in particular changes that may occur in practice, particularly in the event of legal or jurisprudential developments, decisions and recommendations of the CNIL or practices.
17.2. Any new version of this policy will be brought to the attention of Users by any means chosen by METAMOOZ, including electronically (dissemination by e-mail or online for example).We invite you to refer to it regularly on our site.
FOR FURTHER INFORMATION
18.1. For any other more general information on the protection of personal data, you can consult the CNIL website : www.cnil.fr.