Privacy and Data Protection Policy

Personal Data: Any information directly or indirectly identifying a natural person (e.g., a name, an identification number, location data, etc.).

Personal Data Processing: Any operation, or set of operations, performed on personal data, regardless of the process used.

Processing Purpose: Objectives pursued by the data controller in implementing personal data processing.

Data Protection Officer (DPO): Central actor responsible for ensuring compliance with the European data protection regulation for all processing operations implemented by the data controller.

Cookie: Information placed on the user’s terminal (computer, phone, or other device). These are trackers deposited and read when consulting a website. It contains several pieces of data: the name of the domain that deposited it, a unique identification number, and possibly an expiration date.

KOCLIKO collects personal data on the site and the platform and implements data processing as a data controller.

However, KOCLIKO may also collect data from platform users on behalf of its building manager clients who have subscribed to the platform’s services to achieve their own purposes. This primarily concerns data related to your heating consumption for the purpose of individualizing heating costs in accordance with the applicable regulations implemented by your building manager. In this case, your building manager will be considered the data controller, and we invite you to consult their privacy policy.

For the sake of transparency, KOCLIKO takes care to inform you of each processing operation concerning you in this policy, and also when collecting your information. Furthermore, it ensures that this information is accessible, particularly from the website www.kocliko.co or from the prod.kocliko.co platform.

KOCLIKO processes your personal data for legitimate purposes that it determines and makes explicit, notably by informing you of these purposes.

For each processing operation implemented, KOCLIKO undertakes to collect and use only data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

KOCLIKO ensures that data is, if necessary, updated and that procedures are implemented to allow for the erasure or rectification of inaccurate data.

As part of the personal data processing operations whose purposes will be presented below, KOCLIKO, as data controller, collects and processes the following categories of data:

– Identity information: first name, last name;

– Contact details: email address;

– Technical and navigation information: IP address, connection logs;

– Date of entry into the accommodation

This personal data is:

– collected directly from you when creating your user account or managing your personal information;

– provided by your building manager when they grant you access to the platform;

– derived from your navigation on our platform ( please consult our Cookie Policy from the Kocliko website or from the app.kocliko.co platform);

– that you may provide to us if you exercise your data protection rights.

As part of the personal data processing operations whose purposes will be presented below, KOCLIKO, as data controller, collects and processes the following categories of data:

– Identity information: title, first name, last name

– Contact details: email address, phone number

– Professional information: company name, sector of activity

– Technical and navigation information: IP address

This personal data is collected when:

– You browse our site: in this case, we collect your technical and navigation information (please consult our Cookie Policy from the website kocliko.co or from the app.kocliko.co platform);

– You contact us via our contact form accessible on the site under the “Contact” section.

When your data is transmitted to us via a form, mandatory information fields are marked with an asterisk.

Without them, your request cannot be processed, and no response can be provided.

The data processing operations implemented by KOCLIKO as data controller pursue the purposes identified below and are based on the following legal grounds:

The personal data we collect is intended for KOCLIKO as the data controller.

The following categories of recipients also receive your data:

– authorized KOCLIKO personnel, each for their respective responsibilities;

– Our subcontractors, technical service providers.

The hosting servers on which KOCLIKO processes and stores data are exclusively located within the European Union. KOCLIKO undertakes not to transfer data outside the European Union.

KOCLIKO will only retain data in a form that allows identification of the data subjects for the period necessary for the purposes for which it is processed.

Retention periods will be proportionate to the purposes for which they were collected and will be extended, if applicable, by the statutory limitation and retention periods.

The following main durations will apply:

KOCLIKO attaches particular importance to the security of your personal data.

Appropriate technical and organizational measures are implemented to ensure that data is processed in a way that guarantees its protection against accidental loss, destruction, or damage that could compromise its confidentiality or integrity.

In the event of using a service provider, KOCLIKO only communicates personal data to them after obtaining a commitment and guarantees from the latter regarding their ability to meet these security and confidentiality requirements.

In compliance with its legal and regulatory obligations, KOCLIKO concludes contracts with its subcontractors precisely defining the conditions and modalities for processing personal data by the latter.

KOCLIKO regularly audits its own services to monitor the proper operational application of data security rules.

KOCLIKO has defined a specific policy regarding cookies and other trackers. It can be consulted on our site www.kocliko.co and on prod.kocliko.co

16.1 – Your Right of Access

KOCLIKO is committed to respecting the rights granted to you regarding the processing of your personal data.

When your data is subject to processing, you have the right to request from KOCLIKO a copy of your data and information concerning:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipients and, where applicable if such communications were to be made, the international organizations to which personal data has been or will be communicated, in particular recipients established in third countries;
• Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• The existence of the right to request from the controller rectification or erasure of your personal data, the right to request restriction of processing of your personal data, the right to object to such processing;
• The right to lodge a complaint with a supervisory authority;
• Information regarding the source of the data when it is not collected directly from the data subjects;
• The existence of automated decision-making, including profiling, and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

16.2 – Your Right to Rectification of Your Data

You have the possibility to request KOCLIKO to rectify or complete your personal data if it is inaccurate, incomplete, ambiguous, or outdated.

16.3 – Your Right to Erasure of Your Data

You may request KOCLIKO to erase your personal data when one of the following grounds applies:

• The data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• You withdraw the consent previously given;
• You object to the processing of your data where there are no overriding legitimate grounds for the processing;
• The data processing does not comply with the provisions of applicable legislation and regulations.

Your attention is drawn to the fact that the right to data erasure is not a general right and can only be exercised if one of the grounds provided for in the applicable regulations is present.

Thus, if none of these grounds are present, KOCLIKO will not be able to favorably respond to your request. This will be the case if KOCLIKO is obliged to retain your data due to a legal or regulatory application or for the establishment, exercise, or defense of legal claims.

16.4 – Your Right to Restriction of Processing of Your Data

You may request the restriction of processing of your personal data in the cases provided for by legislation and regulations.

16.5 – Your Right to Object to the Processing of Your Data

16.6 – Your right to data portability

You have the right to the portability of your personal data where the legal basis for the processing is your consent or the performance of pre-contractual measures or a contract. In addition, not all data is portable and this right applies only to automated processing, excluding manual or paper-based processing.

The data to which your right to portability may apply is:

• Your personal data, which therefore excludes anonymized data or data that does not relate to you;
• Declarative personal data;
• Operational personal data.

The right to portability must not infringe the rights and freedoms of third parties, in particular with regard to trade secrets.

You may request data portability in accordance with the procedure defined below, specifying whether you wish to receive your data yourself or, if technically possible for us, for your data to be transmitted directly to another data controller.

In the latter case, you must ensure that you provide us with the exact name of that controller, their contact details, and the department or person who should receive it. To facilitate the exercise of this right, you must inform that recipient of your request to KOCLIKO.

16.7 – Your right to withdraw your consent

Where the data processing carried out by KOCLIKO is based on your consent, you may withdraw it at any time. KOCLIKO will then stop processing your personal data, without calling into question the prior processing operations to which you had consented.

16.8 – Your right to lodge a complaint with the CNIL

You have the right to lodge a complaint with the CNIL (3 place de Fontenoy, 75007 Paris) in France, without prejudice to any other administrative or judicial remedy.

16.9 – Your right to define post-mortem instructions

You may define specific instructions relating to the retention, deletion, and disclosure of your personal data after your death, with our departments in accordance with the terms defined below. These specific instructions will apply only to processing carried out by us and will be limited to that scope alone.

16.10 – How to exercise your rights

All the rights listed above may be exercised either by email at: dpo@kocliko.co, or by writing to:

KOCLIKO

Personal data

9 rue de Condé

33000 Bordeaux

As part of exercising your rights, you must prove your identity by any means. In the event of doubt as to your identity, KOCLIKO may ask you to provide additional information deemed necessary to identify you, including a photocopy of an identity document bearing your signature.