The present privacy policy (hereinafter, the “Privacy Policy”) applies to the data processing made on or through the EasyBroker Platform, the Website and/or the Services of EasyBroker. This Privacy Policy is complementary to the Terms of Service, forming an integral part thereof and the terms defined therein shall have the same meaning in this document.

All the data processed or to which EasyBroker has access by virtue of or within the framework of the EasyBroker Platform, the Website and/or the EasyBroker Services shall be processed according to this Privacy Policy. Through this Privacy Policy, EasyBroker informs how it processes the personal information of the visitors of the Website, of the Users, of the Agents Users and/or any other personal information subject to processing by EasyBroker and/or through its Website, the EasyBroker Platform and/or the Services.

When downloading, installing, accessing or using the EasyBroker Platform and/or its Services, you acknowledge reading and understanding the Terms of Service, the Privacy Policy and any supplementary document, and accept to be bound by them and that, furthermore, you will comply with all the applicable laws and regulations regarding the use of the EasyBroker Platform and its Services.

IF YOU DO NOT AGREE WITH THESE TERMS, DO NOT DOWNLOAD, INSTALL, ACCESS OR USE THE EASYBROKER PLATFORM, THE WEBSITE OR THE SERVICES OF EASYBROKER IN ANY MANNER.

1. Information gathering and usage

The usage of the EasyBroker Platform, the Website and the rendering of Services by EasyBroker shall imply the gathering and treatment by EasyBroker of certain personal data. “Personal Data” shall include any information that allows the direct or indirect identification of a person.

The EasyBroker Platform may require certain mandatory data such as name, identity document number, e-mail, address, gender, mobile number and/or other contact data, birth date, nationality, company and/or legal entity in the name and on behalf of which you use the EasyBroker Services, the Website and/or the EasyBroker Platform, among others, in order to register your Agent User Account and/or Administrator Agent Account and this way enable access to the EasyBroker Platform. Furthermore, EasyBroker gathers the information from the e-mail addresses of those who communicate with us via e-mail, information volunteered by the clients, survey information and/or site registrations and payment information (e.g., credit card number and billing address) among other information necessary to render the Services.

Additionally, EasyBroker may gather information regarding the devices through which you access to the EasyBroker Platform, such as those devices concerning the mobile operator, mark, model and operating system of the device, the place from where you access to the Website and/or the EasyBroker Platform and/or the Services, and may monitor the traffic, viewings, interactions and any other activity of the User and Agent User on the Website and/or EasyBroker Platform (these data may be gathered through the use of cookies, web beacons, pixels, canvas finger printing and/or the like).

In case the Personal Data required by EasyBroker is not provided, EasyBroker will not process the Services and/or the Agent User will not be able to use the EasyBroker Platform and/or any or all of the Services and features provided therein.

For each visitor to our Website, our server will automatically recognize only the clients´ domain name, but not the e-mail address (where possible).

2. Truthfulness of the information

The User and/or Agent User will be solely liable for the truthfulness, accuracy, completeness, effect, authenticity, and certainty of the information provided to EasyBroker (both for own data or for that corresponding to third parties for which the Agent User is accountable), having to immediately notify of any update or modification that may be applicable. Notwithstanding the foregoing, EasyBroker may verify the Personal Data and/or information provided – by itself or through third parties – resorting to public entities, specialized companies, among others, which is expressly accepted by the User.

3. Personal Data of Third Parties

The Agent User shall be solely liable for the Personal Data of third parties and/or of any database and information “uploaded”, entered, administered and/or managed through the EasyBroker Platform and the Services it offers such as the case of the contact data of those interested in the properties that the Agents Users publish and/or market and/or manage through the EasyBroker Platform. In this respect, the Agent User releases EasyBroker and the companies and/or entities related thereto from any legal or factual responsibility and holds them harmless at all moments from any third-party claim. In particular, the Agent User understands that EasyBroker shall not be, in any manner, liable for the processing of the Personal Data that the Agent User makes through and/or facilitated through the EasyBroker Platform. In this respect, the Agent User represents and warrants the following:

1. The Personal Data of third parties, any database and information that the Agent User “uploads”, enters, administers and/or manages through the EasyBroker Platform and the Services has been gathered and is used by the Agent User and/or by whom it appoints, complying with all the applicable laws and regulations, including, among others, the laws on personal data protection that may require obtaining the consent of the owners of the data and/or a third party to use and process said information;
2. The processing of the Personal Data of third parties made by the Agent User within the frame of the EasyBroker Platform and/or the Services does not violate or infringe third party rights, in particular, of the owners of the Personal Data;
3. Its processes, proceedings and safety computer standards comply with the applicable regulations and the industry standards;
4. The processes and proceedings implemented are appropriate to comply with the access, rectification, cancellation and opposition rights of the owners of the Personal Data you are responsible of; and
5. The User shall eliminate and refrain from processing on the EasyBroker Platform (i) any Personal Data infringing the applicable regulations and/or in violation of third-party rights; (ii) any Personal Data that the owner requires to be eliminated within the exercise of its rights under the applicable laws; and (iii) all the Personal Data of third parties over which it does not have or stops having rights or power to process on the EasyBroker Platform, being bound to eliminate it from the EasyBroker Platform once the rendering of the Services terminates and/or when it has become useless for the purposes it has been gathered from the owner.

4. Purposes

The information and Personal Data gathered is used for the following purposes that the Users and Agents Users expressly consent:

1. Identification of the Users, Agents Users and their devices;
2. Management and processing of the EasyBroker Platform and the Services and services related thereto;
3. Improvement of the content, features and arrangement of the Website and the EasyBroker Platform for the Users and Agent Users;
4. Analysis, storage and processing of said information, including its grouping according to specific profiles with marketing and survey, promotional, commercial or advertising purposes;
5. Sending of promotional information of products and/or services of EasyBroker, through the sending of newsletter or any other type of formats, always giving the User the option to unsubscribe;
6. Sending of information and notifications regarding the updated of the Website, the EasyBroker Platform and/or the Services; and
7. Analysis and monitoring the use of the EasyBroker Platform and its features with business, statistical or promotional purposes.

5. Cookies

We use cookies to store Users and Agent Users preferences, customize our Website and EasyBroker Platform content based on Users' or Agent Users´ browser type or other information that the User or Agent User sends.

Therefore, in order to make full use of the features and services of the Website and the EasyBroker Platform, the User and/or Agent User shall accept certain cookies. When using or browsing the Website and/or EasyBroker Platform, the User and/or Agent User accepts the use of cookies by EasyBroker according to the characteristics described below.

“Cookies” are small text files that a web site places in the PC, telephone or any other device used to access thereto, with information regarding the browsing of the user in said website. Cookies are necessary to make the navigation easier and more friendly, and do not damage the computer or device used to access.

“Cookies” do not include information that allows the identification of the User and/or Agent User and for themselves do not allow obtaining contact personal information of the User and/or Agent User, such as the e-mail address. If the User and/or Agent User decides to provide personal information to the Website or to the EasyBroker Platform, for instance, through forms, said information may be linked to the data stored in the cookies. The information gathered trough the cookies consists of information regarding the browser used by the User and/or Agent User, the type of computer, operating systems, suppliers of the Internet service, sections of the Website that the User and/or Agent User visits, links established and any other information with similar characteristics. “Cookies” are an essential part of how the website works.

The main purpose of using “cookies” is to improve the experience of the User and/or Agent User during browsing. For instance, “cookies” help by remembering the preferences of the user (language, country, etc.) during browsing and in future visits. The information gathered in the “cookies” helps EasyBroker, for instance, to improve the Website and the EasyBroker Platform, through estimates of the numbers and usage patterns, the alignment of the Website and the EasyBroker Platform to the individual interests of the User and/or Agent User, faster searching, among others.

Furthermore, it is herein informed that EasyBroker may use the “cookies” to target advertising to the Users and/or Agent Users according to their browsing.

EasyBroker by no means imposes an obligation on the User and/or Agent User to maintain “cookies” active, but you are herein informed that some features and sections of the Website and/or EasyBroker Platform may be disabled or not function properly. For more information on how to disable in your browser the option to accept cookies, we recommend to visit the supplier websites of the different browsers used in today´s market, such as Internet Explorer, Google Chrome, Mozilla Firefox, among others, being able to verify the settings tutorials. It is customary that the setting of the cookies is done in the “Preferences” or “Tools” menu.

6. Right of Access, Rectification, Cancellation and Opposition

In order to exercise the access, rectification, cancelation and/or opposition rights, Users and/or Agents Users have the faculty to correct their account data by accessing the Edit profile settings. Non-Agent Users may request deletion of data held by EasyBroker by contacting hola@easybroker.com.

7. About Communications of EasyBroker and Opt-Out mechanism

If you provide your postal address or your on-line electronic mail, you will only receive the specific information for which you provided the address. Those providing the telephone number may receive telephonic contact from us offering new products, services or invitations to future events. If you do not want to receive this type of calls, please inform us sending an e-mail stating your name and telephone number to the address hola@easybroker.com to be removed from our lists.

8. Data retention

The Personal Data shall be retained during the time necessary for the purpose it has been gathered. The time EasyBroker retains the Personal Data will also depend on the legal basis over which your data is processed, e.g., in the case of data preserved by virtue of legal duties, the period of preservation of the data shall be governed by the applicable regulations.

Regarding the Personal Data of third parties that the Agent User may process, host and/or in any manner manage on the EasyBroker Platform, it is herein informed that when the relationship with the Agent User holding an Administrator Agent Account terminates for any reason, EasyBroker will be empowered to destroy and delete said information, so that the Agent User understands that it will be its sole responsibility to independently safeguard the information and to make the security copies you deem appropriate. Furthermore, EasyBroker shall be empowered to eliminate all or part of the information of the Agent User after 10 days once the payment deadline of the subscription has expired and/or from the cancellation of the Administrator Agent Account. Notwithstanding the foregoing EasyBroker may keep the information of the Agent User Account once the relationship with the Agent User has terminated as stated in the first paragraph herein.

The deletion of information according to the above will not give rise to any type of liability on the part of EasyBroker and/or the companies related thereto. If your account is an Agent User Account, the information and/or Personal Data you have created, hosted and/or processed will remain in possession of the Administrator Agent User Account to which your account was linked.

9. Security

We have appropriate and reasonable measures according to the standards of the industry with regards to safety and preservation of information in order to avoid any adulteration, alteration, loss, misuse, enquiry or unauthorized processing of the information and Personal Data we have gathered and to detect intentional deviations. Notwithstanding the foregoing and considering that EasyBroker makes its best efforts to prevent and avoid any security incident, due to the own nature of Internet, we cannot guarantee the complete security of the information.

If you discover or suspect some type of security incident and/or understand that the Website and/or the EasyBroker Platform does not satisfy the information security policy, you may contact us though the e-mail hola@easybroker.com.

10. International data transfer

The Personal Data gathered by EasyBroker through its Website and the EasyBroker Platform will be hosted and processed in the United Stated of America by the company Amazon AWS and/or by any other suppliers in jurisdictions that may not provide the same levels of data protection than the ones foreseen under the applicable laws on Personal Data Protection. In this respect, Users and Agents Users expressly agree to the transfer of their Personal Data to said jurisdictions.

11. Assignment

EasyBroker does not assign your Personal Data or the one corresponding to third parties you register, store, manage and/or process on the EasyBroker Platform without your consent. In this respect, you should take into account that when sharing your API KEY you are sharing all this information with the person to whom you have shared it and that the use of certain features and/or Services of the EasyBroker Platform imply the assignment of this information and Personal Data to third parties outside the control and responsibility of EasyBroker and its related and/or affiliated entities. For instance, when linking your Agent User Account to the one of an Administrator Agent, this last one will have access to all the information of your Agent User account; when publishing the Listings in properties’ portals of third parties through the EasyBroker Platform, you are assigning all the information linked to that Listing and identification of Agent User with this portal, among other cases of Third-Party Services available on the EasyBroker Platform.

12. Confidentiality

EasyBroker shall maintain the confidentiality of the Personal Data and shall not disclose it unless in compliance with legal procedures such as a search warrant, a court order, or on the instructions of legal or administrative authorities always issued by competent bodies in the jurisdiction concerned, and that may be considered valid under applicable laws.

EasyBroker may also disclose personal data of the Users and/or Agents Users and/or the information they process on the EasyBroker Platform in such situations that jeopardize the security of the EasyBroker Platform by virtue of a legitimate interest of EasyBroker, an attempt of breakdown or physical hazard or threat against it or other Users, Agents Users and/or third parties, and based on the exceptions foreseen in Personal Data Protection Laws.

Furthermore, EasyBroker may share the information within the frame of processes related to the assignment, merger, consolidation, corporate reorganization, sale of all or a substantial part of its assets or shares, procurement of credits and/or within the frame of any internal audit procedure of EasyBroker and/or of third parties.

13. Amendment to this Privacy Policy

EasyBroker may at any time and without prior notice, make changes and updates to the present Privacy Policy. These changes shall be published in the EasyBroker Platform and will be effective immediately upon its publication. Even though we may send you a courtesy communication informing about these changes, as we are not forced to do it, we encourage you to periodically review if there are any changes in the Terms of Service or Privacy Policy given that the continued use of the EasyBroker Platform by the User and Agent User will imply full acceptance thereof. If you do not agree with the updates or changes of the Terms of Service and/or Privacy Policy, you shall refrain from using the EasyBroker Platform and its Services.

14. Applicable Law

Any issue relating to the Terms of Service, Privacy Policy as well as any issue that lies in and is related, in whole or in part, to the EasyBroker Platform and the Services is governed in each of its points by the Laws of the State of Florida, United States of America.

15. Contact

If you should have any queries or consultations regarding these Terms of Service, Privacy Policy and/or any other point of EasyBroker, the EasyBroker Platform and/or the Services, you may contact our support team by email to: hola@easybroker.com