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GENERAL TERMS AND CONDITIONS

VERSION IN FORCE AS OF 03/07/2026

1. IDENTIFICATION OF ASSETWINS

The company Asset Wins Pte. Ltd. (UEN: 202617976H), a company incorporated in Singapore with its main office at 1 Marina Boulevard, #28-00, One Marina Boulevard, Singapore 018989 ASSET WINS can be contacted at the following e-mail address: support@assetwins.com.

2. DEFINITIONS

Terms beginning with a capital letter have the following meaning:

3. PURPOSE

ASSET WINS offers the Client a software tool operated in « SaaS » mode, accessible via the Platform, allowing the centralized management of luxury physical assets, notably through CRM, task and project management, document storage, and simplified accounting functionalities.

The General Terms and Conditions aim to define the terms and conditions of access to the Platform and the provision of Services by ASSET WINS to the Client. Together with the Commercial Proposal to which they are annexed, they constitute an inseparable contractual whole.

4. CONTRACTUAL DOCUMENTS

The Contract between the Client and ASSET WINS is governed, in descending order of priority, by:

In the event of a contradiction, the Commercial Proposal shall prevail over the General Terms and Conditions.

5. TERMS OF SUBSCRIPTION TO THE SERVICES

5.1 Acceptance of the Commercial Proposal

ASSET WINS prepares a Commercial Proposal based on the needs expressed by the Client.

The Client must accept it in writing (including by email) within 30 days from its issuance. This acceptance constitutes acceptance of the General Terms and Conditions in their version in force on the date of the Commercial Proposal.

Once the Commercial Proposal is accepted and the price of the Services is paid in accordance with the terms of the article « Financial Conditions », ASSET WINS proceeds to open the Account and activate the Services. The Client can then freely create access for its Users, in an unlimited number.

5.2 Modification of the Services

The accepted Commercial Proposal is firm and final. Any request for modification (the addition of assets or extension of Storage) will be the subject of an additional Commercial Proposal.

6. DURATION OF SUBSCRIPTION TO THE SERVICES

The Client subscribes to the Services for the initial Period indicated in the Commercial Proposal, starting from the activation date of the Services or any other date specified therein, it being specified that:

Regarding the Consumer Client, Article L215-1 of the Consumer Code provides:

“For service contracts concluded for a fixed term with a tacit renewal clause, the professional service provider shall inform the consumer in writing, by dedicated personal letter or email, at the earliest three months and at the latest one month before the end of the period allowing the rejection of the renewal, of the possibility of not renewing the contract concluded with a tacit renewal clause. This information, delivered in clear and understandable terms, shall mention, in a prominent box, the deadline for non-renewal.

Where this information has not been sent to them in accordance with the provisions of the first paragraph, the consumer may terminate the contract free of charge, at any time from the date of renewal.

Advances made after the last renewal date or, in the case of open-ended contracts, after the date of conversion of the initial fixed-term contract, are in this case refunded within thirty days from the date of termination, less the sums corresponding, up to the latter, to the performance of the contract. The provisions of this article apply without prejudice to those which legally subject certain contracts to specific rules regarding consumer information.”

7. DESCRIPTION OF THE SERVICES

7.1 The Services

The Client acknowledges that the use of the Services requires an internet connection, the quality of which is their exclusive responsibility.

The Services offered by ASSET WINS include, in particular, access to the following features:

ASSET WINS reserves the right to develop the content of its Services and to offer new features.

7.2 Additional services

During the term of the Services, the Client benefits from maintenance, in particular corrective and evolutionary maintenance. In this context, access to the Platform may be limited or suspended.

Regarding corrective maintenance, ASSET WINS uses its best efforts to provide the Client with corrective maintenance in order to correct any malfunction or bug identified on the Platform.

Regarding evolutionary maintenance, during the term of the Services, the Client benefits from evolutionary maintenance, which ASSET WINS may carry out automatically and without prior notice, and which includes improvements to the Platform's features, the addition of new features and/or technical installations used in connection with the Platform (aimed at introducing minor or major extensions).

Access to the Platform may also be limited or suspended for scheduled maintenance reasons, which may include the mentioned corrective and evolutionary maintenance operations.

ASSET WINS ensures, under the terms of an obligation of means, the hosting of the Platform and associated data through a professional hosting provider. The Clients data are hosted on servers located in the European Union.

In the event of difficulty, the Client may contact ASSET WINS technical support at support@assetwins.com.

8. FINANCIAL CONDITIONS

8.1 Price of the Services

The price of the Services is set in the Commercial Proposal. It is established on the basis of an annual subscription per managed Property, according to the ASSET WINS pricing policy in force at the time the Commercial Proposal is drawn up.

All prices are expressed excluding taxes, in the currency indicated in the Commercial Proposal. The Client is responsible for all taxes, duties and fees applicable in their country of residence or establishment, including VAT or any local sales tax, which ASSET WINS will add to invoices in accordance with the legislation in force.

Each subscription includes up to 1TB of storage. Beyond this limit, additional storage is invoiced at cost price, according to the conditions communicated by ASSET WINS at the time of the request.

Any Period started is due in its entirety. ASSET WINS' prices may be revised under the conditions of the article “Amendment of the General Terms and Conditions”.

8.2 Addition and removal of Assets during the Period

Additional Assets may be added at any time during the Period, at the contractual rate per asset. Invoicing for added asset is calculated on a pro rata temporis until the end date of the current Period.

Asset may only be removed from the subscribed scope on the renewal date of the Contract. No price reduction or refund will be granted for properties removed during the Period.

Any Period started is due in its entirety. ASSET WINS' prices may be revised under the conditions of the article “Price revision”.

8.3 Invoicing terms

Annual plan: The invoice is issued upon signature of the Contract. It is payable within thirty (30) days from its date of issue. Renewal invoices are issued thirty (30) days before the expiry date of the current Period.

Payment is made exclusively by bank transfer. The Client is responsible for all transaction and exchange (FOREX) fees related to the transfer. The amount actually received by ASSET WINS must be equal to or greater than the amount of the Commercial Proposal.

8.4 Late payment or default

In the event of default or late payment, ASSET WINS reserves the right, from the day following the due date appearing on the invoice:

9. RIGHT OF WITHDRAWAL OF THE CONSUMER CLIENT

9.1. General principle

In accordance with Articles L221-18 et seq. of the Consumer Code, the Consumer Client has a period of 14 days from the date of subscription to their Subscription to exercise their right of withdrawal, without having to justify their decision or bear any costs other than those provided for by law.

The refund will be made within a maximum period of 14 days from receipt of the withdrawal request, using the same means of payment as that used for the order.

9.2. Exception in the event of immediate execution

In accordance with Article L221-25 of the Consumer Code, if the Consumer Client wishes to benefit from the Services before the end of the withdrawal period, they must make an express request to this effect upon subscription and acknowledge that they waive their right of withdrawal from the start of the execution of the Services.

Thus, if the Client accesses the Services before the end of the 14-day period, they acknowledge that the execution of the Services has begun and that they lose their right of withdrawal.

10. OBLIGATIONS OF THE CLIENT

The Client undertakes to provide ASSET WINS with all information necessary for the subscription and use of the Services and:

The Client is solely responsible for creating and managing access for its Users.

The Client is responsible for the use of the Services by itself and by its Users. It undertakes to ensure that the Services are used in accordance with their intended purpose and these General Terms and Conditions.

The Client is in particular prohibited from:

The Client is also prohibited from:

The Client is solely responsible for the content it integrates into the Platform and indemnifies ASSET WINS against any claim resulting from a breach of its obligations.

The Client indemnifies ASSET WINS against any claim and/or action that could be brought against it as a result of the breach of one of the Client's obligations. The Client shall compensate ASSET WINS for the damage suffered and reimburse it for all sums it may have to bear as a result.

The Client is responsible for maintaining the confidentiality and security of its Login Credentials. Any access to the Platform using the latter being deemed to have been made by the Client.

11. OBLIGATIONS AND LIABILITY OF ASSET WINS

11.1 Quality of Services

ASSET WINS undertakes to provide the Services with diligence, within the framework of an obligation of means. It regularly carries out checks to verify the functioning and accessibility of its Services.

ASSET WINS is not responsible for difficulties in accessing the Services related to:

11.2 Data backup

ASSET WINS uses its best efforts to back up the data produced and/or entered on the Platform. Except in the event of proven fault on the part of ASSET WINS, it is not responsible for data loss occurring during maintenance operations.

11.3 Data security

ASSET WINS provides sufficient storage capacity for the operation of the Services within the limits of the Storage capacities provided for in the Commercial Proposal.

ASSET WINS uses its best efforts to ensure data security by implementing measures for the protection of infrastructures and the Platform, detection and prevention of malicious acts, and data recovery. In the event of a security incident or threats or vulnerability situations, ASSET WINS undertakes to take the following measures:

  1. Blocking of external access: refusal of all incoming traffic, except for explicitly authorized administration IP addresses.
  2. Revocation of active sessions: modification of signing keys or validation parameters to invalidate all active or already issued tokens (JWT).
  1. Global rotation of secrets: update of the main administrator's password as well as all connection strings of the hosted applications.
  2. Audit logs: Extraction and retention of all activity logs (logs) and Application Insights data in order to identify the entry point.

11.4 Concerning the publication of content

ASSET WINS acts as a hosting provider for the content that the Client puts online. Consequently, it is not responsible for this content. If ASSET WINS receives a notification concerning illegal content, it will act promptly to remove it or make access to it impossible, and it may take the measures described in the article “Termination for breach”.

11.5. Subcontracting and assignment

ASSET WINS may use subcontractors for the performance of the Services. It remains solely liable to the Client for the proper performance of the Services.

ASSET WINS may substitute any person who will be subrogated to all its rights and obligations under its contractual relationship with the Client. If applicable, it will inform the Client of this substitution by any written means.

11.6. Limitation of liability

ASSET WINS's liability is limited solely to proven direct damages suffered by the Client as a result of using the Services.

With respect to Professional Clients, with the exception of personal injury, death, and gross negligence, and subject to having submitted a claim by registered letter with acknowledgment of receipt within one month following the occurrence of the damage, ASSET WINS's liability shall not be incurred for an amount exceeding the amounts it received in connection with the provision of the Services to a Professional Client during the 12 months preceding the occurrence of the alleged damage.

12. LEGAL WARRANTY OF CONFORMITY

The consumer is entitled to the implementation of the legal warranty of conformity in the event of a lack of conformity appearing during the term of the contractual relationship between the parties. During this period, the consumer is only required to establish the existence of the lack of conformity and not the date of its appearance.

The legal warranty of conformity entails an obligation to provide all updates necessary to maintain the conformity of the digital content or digital service during the term of the contractual relationship between the parties.

The legal warranty of conformity gives the consumer the right to have the digital content or digital service brought into conformity without undue delay following their request, free of charge and without major inconvenience to them.

**The consumer may obtain a reduction in price while retaining the digital content or digital service, or they may terminate the contract by obtaining a full refund in exchange for giving up the digital content or digital service, if: **

  1. The professional refuses to bring the digital content or digital service into conformity,
  2. The bringing into conformity of the digital content or digital service is unjustifiably delayed,
  3. The bringing into conformity of the digital content or digital service cannot occur without costs being imposed on the consumer,
  4. The bringing into conformity of the digital content or digital service causes a major inconvenience for the consumer,
  5. The non-conformity of the digital content or digital service persists despite the professional's unsuccessful attempt to bring it into conformity.

The consumer is also entitled to a price reduction or to the rescission of the contract when the lack of conformity is so serious that it justifies the price reduction or the rescission of the contract being immediate. The consumer is then not required to request that the digital content or digital service be brought into conformity beforehand.

In cases where the lack of conformity is minor, the consumer is only entitled to the cancellation of the contract if the contract does not provide for the payment of a price.

Any period of unavailability of the digital content or digital service for the purpose of bringing it back into conformity suspends the remaining warranty period until the digital content or digital service is provided in conformity again.
** **
The rights mentioned above result from the application of Articles L. 224-25-1 to L. 224-25-31 of the Consumer Code.

The professional who in bad faith obstructs the implementation of the legal warranty of conformity incurs a civil fine of a maximum amount of 300,000 euros, which may be increased up to 10% of the average annual turnover (Article L. 242-18-1 of the Consumer Code).
** **

The consumer also benefits from the legal warranty against hidden defects pursuant to Articles 1641 to 1649 of the Civil Code, for a period of two years from the discovery of the defect. This warranty entitles the consumer to a price reduction if the digital content or digital service is kept, or to a full refund in exchange for giving up the digital content or digital service.

13. INTELLECTUAL PROPERTY RIGHTS

The Platform, the Services, as well as the software, databases, content and elements of any kind operated by ASSET WINS are its exclusive property and are protected by all intellectual property rights in force.

The Client and the Users benefit from a non-exclusive, personal and non-transferable license to use the Platform and the Services, for the duration of the Contract and according to the subscribed scope.

14. CONFIDENTIALITY

Each of the Parties undertakes to keep strictly confidential all documents and information of a legal, commercial, industrial, strategic, technical or financial nature relating to the other Party, of which it may have become aware on the occasion of the conclusion or execution of the Contract, and not to disclose them without prior written consent.

This obligation does not apply to information:

The confidentiality obligation extends to all employees, officers, and advisors of the Parties. It takes effect upon the signing of the Contract and continues for 5 years after its termination.

15. COMMERCIAL REFERENCES

The Parties may use their respective names, trademarks, and logos as commercial references during the term of their contractual relationship and for 2 years thereafter.

16. PERSONAL DATA

16.1 Processing relating to the management of the commercial relationship

As part of their contractual relations, each Party shall undertake to comply with the applicable regulations on personal data processing and, in particular, the European Data Protection Regulation ("GDPR") and the law n°78-17 of January 6, 1978, relating to data processing, files and freedoms as amended from time to time (hereafter referred to together as the "Applicable Regulation").

Each Party processes personal data of contact person of the other Party involved in the performance of the Contract, as controller within the meaning of the Applicable Regulation for the purpose of managing the contractual relations between the Parties and for the duration of the Contract. These processing are carried out for the execution of the Contract and only identification data (in particular surname, first name, email address, telephone number) are processed by the Parties.

Personal data are retained during the duration strictly necessary for the purposes of managing the business relationship between Parties. The staff of the Party controller of the processing, its control services (notably auditor) and its processors could have access to personal data.

The processing may result in the exercise by each Party’s contact person of their rights under the Applicable Regulation.16.2 Data processing by ASSET WINS as a processor

In the context of the Services, ASSET WINS is required to process personal data in the name and on behalf of the Client, as a processor. The characteristics of the processing and the obligations of the Parties are detailed in Annex 1.

17. FORCE MAJEURE

ASSET WINS cannot be held liable for breaches or delays in the performance of its contractual obligations due to an event of force majeure occurring during the term of its relationship with the Client, as defined in Article 1218 of the Civil Code.

If ASSET WINS is prevented from performing its obligations due to an event of force majeure, it must inform the Client by registered letter with acknowledgment of receipt. The obligations are suspended upon receipt of the letter, and must be resumed within a reasonable timeframe upon the cessation of the event of force majeure.

ASSET WINS nevertheless remains bound to perform the obligations that are not affected by an event of force majeure.

18. TERMINATION OF SERVICES AND EFFECTS OF THE TERMINATION OF THE CONTRACT

18.1 Termination for convenience

Each of the Parties may terminate the Agreement by giving notice thereof by any written means or directly through the Platform, at least 60 days prior to the expiration date of the current Period.

18.2 Termination for breach

In the event of a breach by one of the Parties of any of its contractual obligations, the Agreement shall be terminated as of right 30 days after receipt of a formal notice that has remained without effect, by registered letter with acknowledgment of receipt, without prejudice to any damages.

Furthermore, ASSET WINS reserves the right to suspend the Services immediately, temporarily or permanently, in particular by deleting the Client's Account and without prior notice in the event of reasonable suspicion of a security incident attributable to the Client or of a use of the Services likely to compromise their integrity.

18.3 Effects of the termination of the Agreement

Upon termination of the Agreement, for any reason whatsoever:

19. AMENDMENT OF THE GENERAL TERMS AND CONDITIONS

ASSET WINS may modify its General Terms and Conditions at any time and will inform the Client by any written means at least 90 days prior to their entry into force.

The modified General Terms and Conditions are applicable as of the renewal of the Services.

If the Client does not accept these modifications, they may terminate the Services in accordance with the terms of the article « Termination of the Services and effects of the termination of the Agreement ».

Continued use of the Services after the entry into force constitutes acceptance.

20. ELECTRONIC SIGNATURE

The Agreement may be signed by any electronic means. The Parties acknowledge the reliability of the electronic signature process, which has the same legal value as a handwritten signature under the law.

21. MEDIATION

In the event of a dispute between the Consumer Client and ASSET WINS, the Consumer Client may refer the matter free of charge to the following consumer mediator with a view to an amicable resolution:

Consumer Mediation Center of Justice Conciliators (CM2C)
Postal address: 14 rue Saint Jean 75017 Paris
Telephone: 01 89 47 00 14
https://www.cm2c.net

If the Client is a foreign consumer but located within the European Union, they can visit the European consumer dispute resolution platform accessible here.

22. APPLICABLE LAW AND COMPETENT JURISDICTIONS

The Contract is governed by French law.

In the event of a dispute between the Professional Client and ASSET WINS, and in the absence of an amicable agreement within 2 months following the first notification, the dispute shall be submitted to the exclusive jurisdiction of the courts of Paris (France), unless mandatory provisions dictate otherwise.

ANNEX 1 – PERSONAL DATA (DPA)

1. Description of the subcontracted processing

Purposes of the processingProvision of the Services
Nature of the processing operationsCollection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Types of personal data processedIdentification and contact data (name, surname, phone number, email address, postal address); Professional data (job title, team, company, schedule); Data related to personal life (family members, habits); Login data; Financial data related to properties; Data generated and/or provided using the solution, related to managed properties (description, documents, photos, tasks, etc.).
Categories of data subjectsClient’s employees Client’s customers and their relatives when applicable Users
Duration of the processingDuration of the General Terms and Conditions, or otherwise instructed by the Client

2. Obligations of ASSET WINS towards the Client

2.1 Data processing

ASSET WINS undertakes to process the personal data solely for the purpose(s) listed in this Annex and in accordance with the documented instructions from the Client, including with regard to transfers of personal data to a country located outside the European Union. ASSET WINS undertakes to inform the Client if ASSET WINS considers that an instruction infringes the Applicable Regulation. ASSET WINS reserves the right to suspend processing until the Client modifies the instruction in question so that it no longer violates the Applicable Regulation, without incurring any contractual liability as a result of such suspension. This suspension shall not give rise to any refund of the price of the Services for the period of suspension. If the Client does not modify but maintains the instruction in question, ASSET WINS reserves the right to terminate the DPA immediately and without charge. Moreover, where ASSET WINS is compelled to transfer personal data to a third country or an international organization, under Union or Member State law to which ASSET WINS is subject, ASSET WINS undertakes to inform the Client of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest.

2.2 Security and confidentiality

ASSET WINS undertakes to implement appropriate technical and organizational measures to ensure the security, integrity and confidentiality of the data, its backup as well as the restoration of its availability in the event of an incident. ASSET WINS will also ensure that the persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

2.3 Subsequent processors

ASSET WINS is authorized to engage the subsequent sub-processors (“Sub-Processor(s)”) listed below:

Sub-Processor(s) authorizedProcessing activities sub-processedLocalization of the processingAppropriate safeguards implemented in case of transfer of personal data outside the EU
Microsoft AzurePlatform hosting Data hosting IA model hostingFranceN/A
Google AnalyticsAnalysis of user sessionsUnited States / Based of user’s location (Cloud based)EU-US Data Privacy Framework and Standard Contractual Clauses adopted by European Commission
Microsoft ClarityAnalysis of user sessionsUnited States / Based of user’s location (Cloud based)EU-US Data Privacy Framework and Standard Contractual Clauses adopted by the European Commission

In the event of a change, ASSET WINS will notify the Client in writing in advance. The Client has a period of 15 days to present legitimate and reasoned objections. Failing this, the Client is deemed to have accepted the use of the new sub-processor.

In the event of the Client’s continuing objections, the Parties shall meet in good faith and use their best efforts to discuss a resolution. ASSET WINS may choose to (i) not hire the Sub-Processor or (ii) take the corrective action requested by the Client in connection with the objections before hiring the Sub-Processor. If neither option is reasonably possible, and if ASSET WINS cannot for legitimate reasons hire another Sub-Processor for the intended processing, either Party may terminate this Agreement upon a thirty (30) days' notice.

The Sub-Processor is required to comply with the obligations of this Annex on behalf of and in accordance with Client’s instructions. ASSET WINS shall ensure that the Sub-Processor provides the same sufficient guarantees regarding the implementation of appropriate technical and organizational measures in such manner that processing meets the requirement of the Applicable Regulation. If the Sub-Processor fails to fulfil its data protection obligations, ASSET WINS remains fully liable to the Client for the Sub-Processor’s performance of its obligations.

2.4 Transfers outside the European Union

ASSET WINS is authorized to transfer data outside the European Union subject to the implementation of appropriate safeguards (Standard Contractual Clauses or other mechanism compliant with Chapter V of the GDPR).

The Parties acknowledge and agree that ASSET WINS is located in Singapore. In this context, if the Client is located within the European Union, any transfer of personal data made between the Client and ASSET WINS shall be undertaken through the European Commission Standard Contractual Clauses (the “EU SCCs”), which shall apply completed as follows:

  1. Module Two (Controller to Processor) will apply;
  2. in Clause 7, the optional docking clause will not apply;
  3. in Clause 11, the option to lodge a complaint to an independent dispute resolution body will not apply;
  4. in Clause 13, the data exporter is established in an EU Member State;
  5. in Clause 17, the EU SCCs will be governed by French law;
  6. in Clause 18 disputes shall be resolved before the courts of France;
  7. Appendix of the EU SCCs shall be deemed completed with the information set out in Annex 1A.

2.5 Assistance and notification

ASSET WINS undertakes to assist the Client and to respond without undue delay to any request for information sent by the Client, whether in the context of a request for the exercise of their rights by data subjects, a privacy impact assessment (to the extent such assistance is required by Article 35 or 36 of the GDPR and relates to ASSET WINS’ specific processing operations), or a request made by a supervisory authority or the Client's data protection officer.

2.6 Personal data breach

ASSET WINS shall notify the Client of any personal data breach relating to the processing operations covered by this DPA, without undue delay after becoming aware of it. Such notification shall be sent along with any necessary documentation to enable the Client, where necessary, to notify this breach to the competent supervisory authority.

2.7 Fate of the data

Upon expiration of the Services, ASSET WINS undertakes, at the Client's choice, to delete or return the personal data. The Client has a period of one (1) month from the end of the Services to exercise this choice. After this period, ASSET WINS will proceed with the deletion of all data.

2.8 Subsequent use of personal data by ASSET WINS

The Client hereby authorizes ASSET WINS to process the personal data collected within the framework of the Services (in particular the connection and identification data) for the purpose of improving ASSET WINS’ Services, and in particular for the realization of statistics on the way ASSET WINS’ solution is used by the users. ASSET WINS will act as a data controller within the meaning of the Applicable Regulation and will respect the legal provisions of the aforesaid regulation.

2.9 Documentation and audits

ASSET WINS provides the Client with the necessary documentation for demonstrating compliance with all its obligations and for allowing the Client or any other auditor it has authorized to conduct audits, including inspections, and for contributing to such audits. The Client may carry out audits once a year at its own expense. The Client shall inform ASSET WINS of the audit with a minimum of a 2-week prior notice. ASSET WINS may refuse the identity of the selected auditors if they belong to a competing company. The audit shall be carried out during working hours and in such a way as to cause the least possible disturbance for ASSET WINS’ activity. The audit shall not threaten in any way whatsoever (i) the technical and organizational security measures implemented by ASSET WINS, (ii) the security and confidentiality of the data of ASSET WINS’ other customers and (iii) the proper functioning and organization of ASSET WINS. In addition, the Client will ensure that the auditor and, more specifically, the staff carrying out the audit are subject to appropriate confidentiality obligations. Where possible, the Parties shall agree beforehand on the scope of the audit. The audit report will be sent to ASSET WINS so to make any written comments, which will be attached to the final version of the audit report. Each audit report will be considered as confidential information.

2.10 ASSET WINS’ liability

The Parties acknowledge and agree that the liability caps set forth in the General Terms and Conditions shall apply to ASSET WINS’ compliance with the terms of this Annex and Applicable Regulation.

3. Obligations of the Client

The Client undertakes to:

ANNEX 1A – TRANSFER OF PERSONAL DATA

  1. LIST OF PARTIES

Data exporter: the Client.

Activities relevant to the data transferred under these Clauses: management of a property.

Signature and date: signature and date of the General Terms and Conditions.

Role: Data controller.

Data importer: ASSET WINS.

Activities relevant to the data transferred under these Clauses: provision of a solution that streamlines property management for organizations, owners and professionals.

Signature and date: signature and date of the General Terms and Conditions.

Role: Data processor.

  1. DESCRIPTION OF TRANSFER
Categories of data subjects whose personal data is transferredClient’s employees Client’s customers and their relatives when applicable Users
Categories of personal data transferredIdentification and contact data (name, surname, phone number, email address, postal address) Professional data (job title, team, company, schedule) Data related to personal life (family members, habits) Login data Data generated and/or provided using the solution, related to managed assets
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialised training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.Some data could reveal data subjects’ health status or religious affiliation, e.g., when data subjects provide information about their allergies or dietary restrictions. However, this is not the primary purpose of the Services.
The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis).Continuous
Nature of the processingCollection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Purpose(s) of the data transfer and further processingProvision of the Services as provided by ASSET WINS under the General Terms and Conditions
The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that periodDuration of the General Terms and Conditions, or otherwise instructed by the Client
For transfers to (sub-) processors, also specify subject matter, nature and duration of the processingN/A
  1. COMPETENT SUPERVISORY AUTHORITY

The Commission Nationale de l’Informatique et des Libertés (CNIL), French supervisory authority.

  1. TECHNICAL AND ORGANISATIONAL MEASURES INCLUDING TECHNICAL AND ORGANISATIONAL MEASURES TO ENSURE THE SECURITY OF THE DATA

Description of the technical and organisational measures implemented by the data importer(s) (including any relevant certifications) to ensure an appropriate level of security, taking into account the nature, scope, context and purpose of the processing, and the risks for the rights and freedoms of natural persons.