TERMS OF USE OF THE KLUB APPLICATION BY USERS Version of [30/09/2022] The “Klub” application for mobile device is published and hosted by Klépierre Management SNC, registered with the Paris Trade and Companies Registry under number 562 100 214 (“Klepierre”). Klepierre can be contacted in case of malfunction of the Application, as defined hereunder, by email at: support@klub.klepierre.com. ARTICLE 1: DEFINITIONS The following capitalized terms, whether used in the singular or plural, shall have the following meaning: Application: means the “Klub” mobile application, as further amended from time to time by Klepierre as set forth in Articles 4 and 7 below. Identification Code(s): means the login(s) and/or password(s) used by Users to access and use the Application. Klepierre Local Entity: means the company directly or indirectly owned by Klepierre or by Klépierre SA (whose registered office is located at 26 Boulevard des Capucines 75009 Paris, registered in the Paris Trade and Companies Register under number 780 152 914) which is in charge of the management of the shopping center in relation to which access and use of the Application is requested. ToU: means these general terms of use of the Application, as further amended from time to time by Klepierre as set forth in Article 2 below. User Account: means each User’s personal and dedicated account in the Application, accessible by User through the Identification Codes. User System: means any device and notably mobile telephone (including all hardware, software, wiring and fittings) used by the User to access the Application. User(s): means any individual authorized to access and use the Application and who has created a User Account. Users are either employees or independent service providers of Klepierre or the Klepierre Local Entity, as the case may be, or independent service providers or employees of third-parties (shopping center managers and/or retailers within a shopping center) linked to the shopping center to which the Application relates. Users are using the Application only and solely for professional purposes and in a professional context as set forth below. Certain functionalities of the Application will only be accessible to certain categories of Users. As such: "My Shopping Center" Users include: employees of Klepierre or the Klepierre Local Entity, as the case may be, employees of independent service providers, employees of the shopping center, employees of the retailers (including the store manager). “Turnover Collect" Users include: certain members of the retailers’ employees (the store manager or director/head of the store), employees of Klepierre or the Klepierre Local Entity, as the case may be, employees of the shopping center. “Customer Excellence" Users include: employees of Klepierre or the Klepierre Local Entity, as the case may be, employees of the shopping center's independent service providers, employees of the shopping center. ARTICLE 2: PURPOSE OF THE TOU The purpose of these ToU is to establish the main terms and conditions under which Users are entitled to access and use the Application. The User’s first access to the Application is only granted once the User has read and accepted the ToU by (i) checking the box “I acknowledge that I have read and accepted the Terms of Use” and (ii) clicking the button “Validate”. These ToU may further be amended at any time, without notice. To be authorized to access the Application after amendment of the ToU, the User must accept the amended ToU by checking the box “I acknowledge that I have read and accepted the Terms of Use” and click on the button “Validate”. The ToU can be consulted at any time on the Application in the "ToU" section in the MAIN MENU. Where applicable, the accessible version shall prevail over any other version or any other previous document. Users are advised to read the ToU carefully and consult them regularly. Any User, who accepts the ToU and is therefore authorized to use the Application, is deemed to have read the ToU, accepted all of their terms and conditions, and agreed to observe all of them without reservations. ARTICLE 3: USER ACCOUNT In order to access and use the Application, each User shall ensure to: (i) have a compatible User System; (ii) have an Internet connection, the costs of using remote communication techniques (Wi-Fi, 2G, 3G, 4G, etc.) being borne by the User; (iii) create a User Account on the Application; and (iv) accept these ToU. In order to create a User Account, each User shall follow the following steps: · Step 1: User Account creation request if the User does not have a Klepierre email address (i.e., @klepierre.com and @external.klepierre.com), the User can make a User Account creation request by clicking on the " Create an account" button and by filling the following information: o name / surname o contact details (telephone number) o employment, job or occupation (e.g., shop manager, seller, cleaning staff, security staff, etc.) o name of the shopping center in relation to which access and use of the Application is requested o if the User is an employee of a tenant retailer, name of the concerned tenant and store o identification email o secure password (which shall contain at least 8 characters including 1 upper case, 1 lower case, 1 special character, 1 number) If the User does have a Klepierre email address (i.e., @klepierre.com and @external.klepierre.com), the connection and access to the Application is automatic through a single sign-on authentication method and all the information of the User (i.e., first name, last name, position, professional email address and phone number) will be automatically recovered. · Step 2: validation of the User Account creation If the User is a store manager or an employee from Klepierre or the Klepierre Local Entity, as the case may be: the creation of the User Account needs to be validated by the shopping center management. If the User is an employee of a retailer (other than the store manager): the creation of the User account needs to be validated by the manager of the store to which it belongs. Following the creation of the User Account, the User may access the Application once the ToU have been accepted as per the process described in Article 2. Users acknowledge that the Identification Codes are personal, confidential and may not be passed on to any other person, and Users are solely liable for their use and storage. Accordingly, any access to the Application and any data transmission made using those Identification Codes will be deemed to have been made by the User on their own behalf. Users remain exclusively liable for any use that could be made of their Identification Codes, and for their confidentiality. For Users with several roles and geographic postings, it is specified that their acceptance of the ToU and the assignment of Identification Codes are valid for all their roles regardless of the scope and/or geographic posting. The User shall inform Klepierre without delay in the event that the Identification Codes are lost, stolen or disclosed to an unauthorized third party. In general, Users undertake to immediately inform Klepierre of any fraudulent use of their Identification Codes or risk thereof, and of any breach of the confidentiality and security of the codes, at the following address: support@klub.klepierre.com Unless proven otherwise, the data recorded in the Application's information system is evidence of all exchanges with Users. The User may terminate its User Account at any time by clicking on the button provided for this purpose in the section “My Account” in the MAIN MENU. In such a case, the User will no longer have access to the Application, including its User Account and its content. Users are informed that in case of inactivity of their User Account during a period of one (1) month, they will be notified by Klepierre. In the absence of response of said Users to the notification within three (3) months, Klepierre reserves the right, at its sole discretion to delete any inactive User Account, under the conditions of article 8 below. In case of breach by the User of the ToU, Klepierre reserves the right, at its sole discretion, to suspend or delete the User Account, under the conditions of article 8 below. ARTICLE 4: DESCRIPTION AND USE OF THE APPLICATION The Application provides the User with the following functionalities: · MY SHOPPING CENTER – Newsfeed: allow (i) “My Shopping Center” Users to post news regarding the daily life of the shopping center (such as event, important information, opening, etc.) and (ii) all Users to consult them. · DIGITAL STAFF CARD: allow (i) the shop directors to post in-store commercial offers relating to their corresponding shop and (ii) all Users to consult and take advantage of in-store commercial offers from the retailers. · TURNOVER COLLECTION: allow (i) Turnover Collection Users which are shop directors to communicate to Klepierre and/or the Klepierre Local Entity, as the case may be, the monthly turnover of the retailer they are connected to and (ii) Turnover Collection Users from the shopping center management team to consult them. · CUSTOMER EXCELLENCE o Opening tracking: allow (i) Customer Excellence Users from the shopping center team to report any non-routine store closure and (ii) Customer Excellence Users from the shopping center management team and from the shopping center security team to consult them. o Daily operations tour: allow Customer Excellence Users from the shopping center team to verify each morning that the shopping center offers a sufficient customer experience (i.e., the correct functioning of the elements allowing the reception of the customer such as the doors, the lifts, the cleanliness, the signage, etc.) to allow the opening of the shopping center and report any malfunctions or anomalies. Users acknowledge and agree that the Application (and in particular the abovementioned functionalities) may be modified at any time, without notice, including through addition, modification or deletion of functionalities or processes. The modifications may not be systematically notified to Users and the accessible version of the Application shall prevail over any other version and Users shall not rely on any version they have accessed to or assume it will remain accessible (including any User content previously communicated/displayed/loaded though or on the Application). Users acknowledge and agree that their right to use of the Application (as modified from time to time as the case may be) is limited to the context of the Users’ professional activities in relation to the shopping center to which the Application relates (either in the context of their direct employment or other relationship with Klepierre or the Klepierre Local Entity, as the case may be, or in the context of their indirect relationship with Klepierre or the Klepierre Local Entity, as the case may be, through the retailers and/or shopping center to which they are connected). ARTICLE 5: RIGHTS AND OBLIGATIONS OF THE USER Users undertake to use the Application in accordance with the provisions of the ToU and their purpose. Users acknowledge that they have the necessary training, skills, technical resources and equipment, particularly mobile device, to use the Application. Users agree to provide true, accurate, comprehensive and up-to-date information. Each User warrants that it holds all the rights and authorizations necessary to create an Account and use the Application in accordance with the ToU and to publish any content on the Application. Except for Klepierre’s or the Klepierre Local Entity’s employees, Users acknowledge that they remain, in all circumstances, under the sole managerial, administrative and disciplinary authority of, as the case may be, the shopping center, the retailers and/or any other third-party providers, which shall be solely responsible for the administrative and social management of said Users. Under no circumstances the access or the use of the Application by said Users shall place them under the managerial, administrative and disciplinary authority of Klepierre and/or the Klepierre Local Entity, as the case may be. Users are fully and solely liable for their use of the Application. As such, Users agree to appropriately and lawfully use the Application and its contents, in accordance with applicable legislation, the ToU, standards of decency and public order. Users who use the Application for purposes prohibited by law and/or in violation of these ToU may be prosecuted and subject to legal proceedings, and data identifying them may be provided to the competent authorities in the event of legal proceedings initiated against them. Users are informed that they are formally prohibited from actions including, but not limited to: Using the Application in an unauthorized, fraudulent manner and/or contrary to these ToU, Using the Application, including its contents, for illicit purposes or ends and/or for any other activity that could infringe the rights of Klepierre, other Users and/or any other third parties; Accessing or attempting to access restricted resources or areas of the Application without complying with the relevant access requirements; Introducing or disseminating spam, computer viruses, Trojan horses, computer code, files, scripts, programs or any other physical and/or logical systems on the network and/or using the Application in a way that could be harmful or that are likely to (i) cause damage to the physical or logical systems of the owner of the Application, its suppliers, other Users or any third party, and/or (ii) disrupt or damage the Application, devices, servers, networks or other property of Klepierre and/or any third party; Disseminating any data, information or content that is defamatory, harmful, obscene, racist or xenophobic, offensive, that incites hatred or violence, threatens or constitutes an act of harassment, and in general any content that would be in violation of the applicable laws and regulations, standards of decency and public order; Disseminating any data, information or content that constitutes an infringement or violation of the rights of third parties; Assuming a false identity. Users must not impersonate any other User, or any other person, or communicate under a false name, capacity or pseudonym that they are not authorized to use. ARTICLE 6: LIABILITY The Application is used by each User under its sole liability. In this respect, the User warrants Klepierre against any complaint, claim, action, demand and/or recourse of any nature that other Users and third parties could make against Klepierre on the basis of the violation, by the User, of one of its obligations or guarantees under the terms of these ToU, or, of the use by the User of the Application. The User agrees to indemnify Klepierre for any prejudice, loss and/or damage that Klepierre may suffer and to pay all costs, charges and/or condemnations that it may have to bear in this regard. Klepierre is solely liable towards the User for facts which are directly attributable to Klepierre and causing direct damage to the User within the limits set forth in the separate license agreement concluded between Klepierre and, as the case may be, the Users directly or the shopping center to which the Application relates. Klepierre (and/or any company directly or indirectly controlled by Klepierre or KLEPIERRE SA, including the Klepierre Local Entity) shall not be held liable for any indirect prejudice, notably moral prejudice, loss of clientele, loss of exploitation, loss of turnover or profits, loss of results, loss of data, any claim from a third party, etc. Each User definitively and irrevocably acknowledges and accepts that, notwithstanding any contrary clause contained in the ToU (where applicable, as modified or updated) and/or any contrary clause contained in a separate contract entered into between Klepierre (and/or the Klepierre Local Entity) and a User, as the case may be, neither Klepierre nor any company held directly or indirectly by Klepierre (and/or KLEPIERRE SA), including the Klepierre Local Entity, or any of their respective legal representatives or employees shall incur any liability in respect of the Application and its use by the User, including for instance: (i) in respect of the use and/or damage caused by other Users (except, and within the limits of the applicable mandatory legal and regulatory provisions); (ii) in case of damages resulting from a non-proper use of the Application and/or a use of the Application which is non-compliant with these ToU; (iii) for the inadequate functioning of the Application caused by maintenance operations, incidents, or problems affecting Klepierre’s ability to support the systems required for the use the Application), and notably for delays related to telecommunications services; (iv) for any inconvenience or damage related to the use of the Internet and telecom network, including but not limited to, poor transmission and/or reception of any data and/or information on the Internet, failure of any receiving equipment or communication lines, any malfunction of the Internet and telecom network preventing the proper functioning of the Application; (v) any other facts or events. This article remains applicable in case of nullity, resolution or termination of these ToU. The User agrees that Klepierre is not the publisher of the Users’ content. The User acknowledges and accepts that Klepierre does not exercise any a priori control over the content published by Users on the Application. Klepierre does not warrant the accuracy, quality, truthfulness and reliability of the Users’ content. Klepierre shall not be liable for such Users’ content unless it can be shown that Klepierre: (i) had knowledge of the illicit nature of the said content, and (ii) did not act promptly upon such knowledge to remove such content or make it inaccessible. Klepierre is not the publisher of the content exchanged between the Users and does not exercise any a priori control over this content. Klepierre acts only as a technical intermediary allowing the exchange of this content, which the User acknowledges and expressly accepts. To the extent that the Application may contain content that includes links to third party applications and/or websites over which Klepierre has no control, the User acknowledges and agrees that Klepierre shall not be liable for the content of such third-party applications and/or websites. ARTICLE 7: TERMINATION OR SUSPENSION Without prejudice to the provisions of Article 4, Klepierre reserves the right to modify any information or content contained in the Application, at any time and without prior notice, in order to update it or to correct errors or inaccuracies, or if it deems appropriate, without giving rise to any right to compensation for Users. The User acknowledges and accepts that Klepierre may be required to interrupt access to the Application to perform technical or maintenance work whatever the origin or cause, without this entailing any liability of Klepierre. Klepierre shall make its reasonable efforts to inform the Users on the home page of the Application as soon as possible, and to implement all reasonable means to reduce the period of unavailability of the Application. In addition, Klepierre may unilaterally discontinue, temporarily or permanently, access to the Application at any time and without prior notice, in particular in the event that Klepierre ceases (and notably assign by any means including by way of share deal) the business activity in question, including inter alia if Klepierre or the Klepierre Local Entity, as the case may be, ceases to manage the shopping center to which the Application relates, or in the case of the voluntary or mandatory liquidation of Klepierre and/or the Klepierre Local Entity, or in the event that Klepierre suspends or terminates making the Application available to Users. These ToU will then be automatically terminated, without entitling the User to any compensation. In the event of the User's death, his or her personal account will be deactivated as soon as Klepierre has been informed or when the rightful heirs present the relevant supporting documents. As the account's contents are strictly confidential, they may only be transmitted to the rightful heirs subject to court order. In case of violation of these ToU or of the applicable laws and regulations, in particular in event of a breach by a User of one or more provisions of the ToU, in the event that the User’s conduct compromises or risk compromising the proper functioning of the Application or harms the rights of third parties or their reputation, Klepierre reserves the right to unilaterally suspend and/or terminate, at any time and without prior notice, the enforcement of the ToU under the conditions referred to in this article, and to block and/or remove the User's access to all or a portion of the Application, to deactivate their Identification Codes, and to temporarily or permanently delete the contentious content, without giving the User the right to any compensation, and without prejudice to any legal action that may be brought. Moreover, in the event that the information or content transmitted by the User to Klepierre or on the Application proves to be false, incomplete, obsolete or does not allow for the performance of the Application under optimal conditions, Klepierre reserves the right to deactivate the Identification Codes and consequently to deny the User access to the Application, without prior notice and without giving the User any right to compensation. In the case of any suspicion or alert filed by a User concerning content that is illicit or violates these ToU, Klepierre reserves the right to deactivate the Identification Codes and User account of the User concerned and/or to delete the publication (possibly on a temporary basis) of the allegedly contentious content in order to verify the exact nature of the suspected improper information. Any improper alert may be sanctioned in accordance with the applicable regulations and the ToU and may result in the immediate suspension and/or termination of the ToU. ARTICLE 8: PERSONAL DATA COLLECTION AND PROCESSING Using the Application requires Klepierre to process the personal data of Users (hereinafter referred to as "PD"). Data processing is performed for the purposes and on the legal bases listed in the appendix (Appendix 1: Privacy). Klepierre undertakes to collect and process PD in strict compliance with applicable provisions of European and French law and regulations on personal data protection, including those set out in Regulation (EU) No. 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive No. 95/46/EC (General Data Protection Regulation), as well as the French Data Protection Act of January 6, 1978, as amended. Klepierre undertakes to disseminate the personal data processing policy to all of its employees. Accordingly, the personal data processing policy is set out in the appendices (Appendix 1: Privacy). Without prejudice to any other provision in these ToU, the terms of this clause shall survive the end or termination of the ToU for any reason whatsoever, for the duration of the limitations of the rights and obligations subject to them. Data subjects wishing to exercise their rights may contact the Data Protection Officer of Klepierre in the section “Resources” of the MAIN MENU where a pre-written email to dpo@klepierre.com will be proposed to the User. ARTICLE 9: INTELLECTUAL PROPERTY Users are being granted a personal, non-transferable, non-exclusive right to use the Application in compliance with these ToU either through a license granted directly by Klepierre or through a sublicense granted by the shopping center to which the Application relates. This license or sublicense is materialized by the User’s creation of its User account, unless otherwise set forth in a separate agreement between Klepierre and the User. Subject to the provisions set out below, the use of the Application does not entail any transfer of title, of any kind, to the User. Under no circumstances shall the ownership of the methods, tools, processes and know-how, copyrights and other intellectual property rights, of any nature, related to the Application, including all derivative works, be transferred to the User. The User therefore undertakes not to directly or indirectly reproduce, download, copy, alter, delete, distribute, disseminate, exploit, arrange or adapt the Application, make it available to third parties, market it, lend it or implement any right other than those strictly and expressly authorized in these ToU. The User undertakes to comply with all notices relating to the intellectual property rights or other rights held by third parties or, as appropriate, its licensors and not to distort, delete, alter or use them without the prior written permission of Klepierre or otherwise infringe them. The User is prohibited from developing or marketing any software or product that may compete with the Application. The Users may not pledge, assign, distribute or otherwise transfer all or part of the granted rights to any third party, whether against payment or free of charge, without the prior written permission of Klepierre. The User will notify Klepierre, as swiftly as possible, any claim or legal action by a third party for infringement, damages in contract or tort or on any other ground, relating to all or part of the Application. Under the quiet title warranty, Klepierre will be joined as a party, at its own expense, for any claim brought against the User in legal proceedings issued by a third party on the grounds that all or part of the Application allegedly infringes an intellectual or industrial property right. The User agrees to notify any claim or legal action referred to above to Klepierre without undue delay and provide it with all relevant information. In the event that the use of all or a portion of the Application is deemed to constitute an infringement of the rights of a third party, Klepierre may unilaterally suspend and/or terminate the Application, as of right, at any time and without prior notice, block and/or remove the User's access to all or a portion of the Application, without this entitling the User to any compensation. ARTICLE 10: CONFIDENTIALITY Users maintain (and undertake to cause, in particular, persons acting under their responsibility and other parties to maintain) the absolute confidentiality regarding all information relating to research, development work, know-how, technical data, documentation, software, software packages and business strategies for the purpose of and in connection with the use of the Application ("Confidential Information"). Accordingly, the ToU must be treated as Confidential Information. Consequently, Users undertake not to disclose any Confidential Information to third parties and to use any Confidential Information strictly in connection with their use of the Application. ARTICLE 11: GOVERNING LAW – DISPUTES – LANGUAGE OF USE The conclusion, interpretation, validity, execution, performance and termination of these ToU and in general any use of the Application are governed by French law, regardless of the User's nationality. In the presence of a dispute relating to the conclusion, interpretation, validity, execution, performance and/or termination of these ToU and in general relating to or in connection with the use of the Application, Klepierre and the User will attempt to settle the dispute amicably. Unless amicably settled, Klepierre and the User irrevocably consent to submit their dispute exclusively to the competent courts of Paris (France), notwithstanding multiple defendants or third-party applications for indemnity, and even in cases involving protective applications or expedited or ex-parte proceedings. In the event of any disputes, the French language version of these ToU shall prevail over any other version translated into another language. APPENDICES Appendix 1: Privacy 1. What personal data are collected? You have agreed to be a User of Klub and to use it in accordance with the applicable laws and regulations. Your personal data will be collected for the purpose of accessing and using all or some of the features of Klub. The data may be kept for the data retention periods mentioned below. These periods may be extended for a longer period if we are required to do so by law. Information about you will be collected depending on what features you have access to and those you use (hereafter “personal data”), such as: · Identifying information, including your name, surname and title; IP, date and hour’s login · Contact information, including your employer's contact information or the identity of your employer and your email address, when you provide this information to us; · Date and time of starting of Daily Operation Tour; · Identifying informations (Name, Surname, Alias, ID, IP, Login Information) of people creating and/or commenting on publications or posts, the content of comments and posts; · Relevant information required by anti-money-laundering and anti-corruption regulations as part of the “Know Your Supplier” (KYS) personal data processing carried out when engaging new suppliers. This may include documents obtained from you and information obtained from online or offline third-party sources. 2. For what purposes do we use your personal data? Your contact information is used for the purpose of accessing and using Klub. Klepierre does not resell, disseminate or operate or extract your personal data. None of your personal data is processed to make an automated decision, including profiling, about you. Your personal data may be processed for the various features and legal bases identified in the table below:
Purposes Legal basis Data Retention period
1. To create a user profile, a Digital Staff Card and access the features of Klub. This processing is carried out on the basis of consent. 12 months after from the date on which the person concerned has ceased whatever the reason, his or her functions that justified the right of access
2. To keep all User identification records in Klub. This processing is carried out on the basis of consent. Data Retention period according to the functionalities described in 1 and 3 to 8 of this chart
3. To report monthly turnover to Klepierre landlord (applicable to the Turnover Collect Users). We consider this processing to be necessary to ensure compliance with the parties' contractual obligations under a lease agreement between a tenant and a Klépierre landlord Duration of the lease’s contract.
4. To identify the person who performed the verification round, (applicable to the Customer Excellence Users) This processing is carried out on the basis of consent. 12 months from each verification round
5. To monitor and centralize the exchanges between the people who report the information and the center's support teams. This processing is carried out on the basis of consent. 12 months after the end of each exchange
6. To identify the profile of the user who performs the DOT (Daily Operations Tour).(applicable to the Customer Excellence Users) This processing is carried out on the basis of consent. 36 months after DOT performing
7. To create a Digital Staff Card and identify the person who is the holder of this DSC This processing is carried out on the basis of consent. 6 months from the date on which the person concerned has ceased whatever the reason, his or her functions that justified the right of access
8. To identify, monitor and centralize the identification of the person who comment on, send messages to, or interact with communications or content posted in the Newsfeed features; to maintain such posts, comments and actions and all the information of the date and logging (ID, IP) of the New, Comment, post or / and action. This processing is carried out on the basis of consent. 12 months after the publication of the post + 48 months as an intermediate archive with restricted access for evidentiary and/or defense purposes in the event of litigation.
3. With whom do we share your personal data? Your personal data will be used by Klépierre Management and its sub-contractor Kleegroup. Your personal data may be shared with various categories of third parties, as required for the purposes described in section 2 above: · Any company of the Klépierre Group, if strictly necessary; · Third-party service providers (maintenance, storage, payment, logistics, marketing services, social audits, etc.); · Professional advisors such as lawyers, accountants, and auditors; · Governmental, administrative or regulatory authorities; · Professional insurers or all other relevant types of insurers. This list is not exhaustive, and there may be other instances where your data shall be shared with third parties where necessary for compliance with a legal or mandatory obligation. In this context, your personal data will not be transferred outside the European Economic Area (EEA). In any case, any transfer outside the EEA (if required) to countries that do not offer a level of protection to your personal data equivalent to that which you enjoy within the EEA were to be envisaged, such transfer would be governed by standard contractual clauses adopted by the European Commission. 4. How long do we retain your personal data? Your personal data shall be retained for as long as it is authorized by the applicable regulations, or for as long as necessary to fulfill the purposes for which they were collected and, in general, for the time strictly necessary to manage the business relationship with you. Personal data shall be retained for a longer period of time, for example, where required by legal obligations or where the data are necessary to establish evidence of a right or a contract. In such case, your personal data are archived and stored for the period required by the applicable regulations, or for the duration of the applicable legal obligations. When it is no longer necessary to retain your personal data, they are deleted or, if this is not possible, rendered anonymous. 5. Security of your personal data Information systems security policies and appropriate technical measures have been implemented to protect the security of your personal data against unauthorized access, alteration, use, disclosure, unlawful destruction or accidental loss. 6. What are your rights ? · Withdrawal of consent. You may withdraw your consent to any processing of your personal data based on your consent at any time. · Access. You may ask to be confirmed whether your personal data are processed and, where applicable, to be informed of the characteristics of the processing carried out on your personal data, to be given access to and to obtain a copy of them. · Rectification. You may ask to have your personal data rectified or completed if they are inaccurate or incomplete. · Erasure. You may ask your personal data to be erased in the following cases: when they are no longer necessary for the purposes for which they were collected; you have withdrawn your consent; you have exercised your right to object; your personal data have been unlawfully processed; or for compliance with a legal obligation. Please note that the responsible for data processing is not obliged to comply with your request to erase your personal data, in particular if their processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. · Restriction. You may ask us to restrict the processing of your personal data (i.e., to retain them without using them) when: their accuracy is contested; their processing is unlawful but you do not want them to be erased; they are still necessary for the establishment, exercise or defense of legal claims; in the context of exercising your right to object, it is verified v whether there are any compelling grounds for processing. It may continue to use your personal data following a request for restriction: with your consent; for the establishment, exercise or defense of legal claims; or to protect the rights of another natural or legal person. · Portability. You may request to be provided with your personal data in a structured, commonly used and machine-readable format, or to have them being transmitted directly to another data controller, but only if the processing is based on consent or contract and is carried out by automated means. · Digital legacy. You have the right to set out instructions (general or specific) as to what happens to your personal data after your death. · Objection to the processing of personal data based on legitimate interest. You may object to any processing of your personal data that is based on our "legitimate interest" (see Section 2). You also have the right to lodge a complaint with the competent supervisory authority regarding the processing of your personal data. In France, the supervisory authority for the protection of personal data is the French Data Protection Agency (CNIL, www.cnil.fr). 7. Contact and complaints For more information about your rights, to exercise your rights or if you have any complaints or questions about the protection of your personal data, or to contact the Data Protection Officer, please contact them by email to: dpo@klepierre.com.