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Privacy Policy

Privacy Policy

Updated April 25, 2023


Article 1 - Preamble

The company VERSITY, SA with a capital of 1.014.447,43 euros, whose head office is located at 25 avenue Jean Médecin - 06000 Nice, and registered with the Trade and Companies Register of Nice under the number 878 114 826 (hereinafter "Versity" or "we") undertakes to process the Personal Data of users (hereinafter "User" or "You") in accordance with applicable laws and regulations and in particular to the law n° 78-17 of January 6, 1978 as modified by the law of June 20, 2018 and to the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (hereinafter the "GDPR").


Article 2 - Definitions

The following defined terms, beginning with a capital letter, in the plural as well as in the singular, will have the following meanings in this Privacy Policy (hereinafter "Policy"):

Cookie: means a computer file, a tracer, deposited and read, for example, when consulting a website, reading an e-mail, installing or using a software or a mobile application, regardless of the type of terminal used (computer, telephone, etc.). The use of these tools is subject to your consent if they are not strictly necessary for the operation of the site concerned.

Joint Controller: this refers to the case where two or more controllers jointly determine the purposes and means of the processing (article 26 of the RGPD).

Recipient: means the natural or legal person, public authority, department or any other body that receives communication of personal data, whether or not it is a third party (Article 4-9 of the GDPR).

Personal Data: means any information relating to an identified or identifiable natural person, i.e. that allows that person to be identified directly (e.g. name and surname) or indirectly (e.g. connection data). (Article 4-1 of the RGPD)

Partners: refers to third party partners, service providers or subcontractors who have entered into a contract with Versity to enable the proper functioning of the Site and the services offered on the Site.

Data Subject (or "Person"): the natural person to whom the Personal Data relates.

Controller (or "Controller"): means the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing (Article 4-7 of the GDPR)

Processor: means the natural or legal person, public authority, department or other body which processes personal data on behalf of the controller (Article 4-8 of the GDPR)

Processing of Personal Data (or "Processing"): means any operation or set of operations (whether or not automated) on Personal Data, such as: collecting, recording, organizing, storing, adapting, modifying, retrieving, consulting or transmitting data (Article 4-2 of the GDPR)

Wallet: means a Web3 digital asset wallet that relies on cryptographic algorithms and allows for the deposit, storage and transfer of these assets.


Article 3 - Purpose and Scope

This Privacy Policy applies to Personal Data collected, processed and stored in connection with your use of the website, the Marketplace. (hereinafter the "Site") and more generally to the services offered by Versity (hereinafter the "Services").

The Privacy Policy uses the term "Personal Information" to encompass all information that can identify an individual, either alone or in combination with other information. This information includes first and last name, email address, telephone number and IP address.

This policy (the "Policy", in conjunction with our Terms of Use) explains and defines why and when we collect personal information about people who visit this Site, how we use it, the conditions under which we may disclose it to others, and the steps we take to keep it secure.

We may change this Policy from time to time, so please check back periodically to ensure that you agree to any changes.

Your continued use of our Site constitutes your acceptance and agreement to any changes.


Section 4 - Prior Consent to Processing Personal Data

By visiting this Site, you accept and consent to the practices described in this Policy. Please note that this includes consent to the collection and processing of any personal information you provide, as described below.

The User is free to choose whether or not to provide the required Personal Information, but certain information is absolutely necessary to provide a quality and efficient service. Therefore, your refusal to provide such Personal Information may prevent or restrict access to and use of our services.


Article 5 - Accuracy and truthfulness of Personal Data

As a User, you guarantee that the Personal Data you provide to us are genuine, accurate, complete, up-to-date and true. You are therefore solely responsible for it and exempt Versity from any liability in this respect.

The User also undertakes to inform us without delay of any change in this data at the following address: [email protected].


Article 6 - Personal Data collected and processed when browsing the Site

When you visit the Site, the Personal Data we collect may come from the following sources:

  • Data that you provide directly: when you create a user account, fill in online forms or contact us directly by e-mail, telephone or mail.
  • Data we collect automatically: when you browse our Site, such as information about your device, browser and IP address. We may also use cookies to collect data about your use of our Site.<
  • Data from third party sources: we may receive Personal Data about you from third party sources, such as business partners, service providers, social networks or public sources.


Note that when we collect Personal Data from third party sources, we ensure that these sources are legitimate and have obtained your consent or have a legal basis to provide the data to us.

You are also advised that third party sources may collect data about you, use cookies, embed third party tracking tools, track your interactions with such embedded content if you have a logged in account on their website or social network.


Section 6.1 - The Personal Data we collect

When you visit the website, we may collect and process the following categories of Personal Information in the course of our business, depending on your request and/or the contract you have signed:


Categories of dataType of data
Identification data:

Last name ;

First name ;

Pseudonym and/or Username ;

Photo (optional);

Connection data:

Username ;

Email address

Wallet address ;

IP address ;

Browser data:

Web Browser Information;

Operating System;

Date and time of visit to the Site;

Pages viewed and features used;

Language Preference;

Metaverse Usage Data:

Activity in the metaverse such as:

Items visited or acquired;

Interactions with other users;

Transactions performed;

Avatars created

Financial data:

Transaction information;

Crypto wallet address including associated data used to detect crypto currency holdings and NFT ;

(We may provide your personal information to third party payment processors who process transactions on our behalf).

Contact Information:

Mailing Address;

Email Address;

Phone Number;

Geolocation data:

City of connection (data anonymized immediately after location and not disclosed);

Zip code;

Other data:

Search preference;

Search criterion;

Type of property searched;

Audio recording (data used for service improvement and tracking purposes);


Please note, however, that we only collect Personal Data that is necessary for our purposes. If it is intended to use the collected data for purposes other than those for which it was originally collected, the persons concerned will be informed in advance and must give their consent.


Section 6.2 - Use of Personal Data

We collect and process your Personal Information for the purpose of enabling you to access the features and services offered on our Site. We make sure that we collect information about you that is current, correct and relevant.


a - The general purpose of processing your Personal Data is to meet at least one of the following purposes

- to provide you with relevant information and news;

- to send you personalized communications that you have requested and that may be of interest to you, which may be based on your activity on our Site (or our partners' websites). These may include information about campaigns, activities and events;

- to understand and measure the effectiveness of how we serve you and others, and to make suggestions and recommendations to you about services that may be of interest to you, which may be based on your activity on our Site (or our partners' websites);

- for analysis and profiling to create aggregate trend reports, to learn how visitors arrive at our Site, which sites and pages are visited, responses to marketing campaigns and to determine the most effective marketing channels and messages;

- to solicit your opinions or feedback on the service we provide;

- to notify you about changes to our service, policies and terms of use.


b - The processing of your Personal Data also serves the following purposes (non-exhaustive list):

Legal basisPurposes

Deposit of cookies ;

Sending of the Newsletter and changes on the Site;

Execution of commercial relations (CGU)

Providing services and responding to your requests;

Provide our marketing materials and facilitate sharing on social networks;

To fulfill our business purposes;

Analyze Personal Data for business reporting and provide personalized services;

Create and manage User accounts

Legitimate Interest

To manage your complaints and various requests;

To manage and collect your opinions on services and/or contents (improvement of the user experience)

Legal obligationTo manage your requests for access, rectification, opposition and any other right related to your Personal Data;


However, we inform you that we only use Personal Data when it is necessary for our purposes. If it is envisaged to use the collected data for purposes other than those for which they were initially collected, the persons concerned will be informed beforehand, and must give their agreement.


Section 6.3 - Recipients of Personal Data

We collect and process your Personal Data only for the purposes indicated above, using in particular our various internal services such as the commercial, IT, legal, administrative, financial departments, etc.

Your Personal Data is not communicated or accessible to third parties, except in the following cases

To fulfill our contractual obligations with you, in collaboration with our business partners, subcontractors, external third party service providers such as IT systems service providers, support, hosting, storage, authentication, payment and subcontracted service providers who assist us in the performance of our activities,

In the event of a reorganization of our business, including a sale of all or part of our assets, a merger, acquisition, spin-off or other reorganization of our business.

In the event that the user shares personal information by posting and/or broadcasting content on the Site, chat rooms (voice or written), and other similar services. However, please note that any information you post or share in this manner will be made public and may be viewed by other users and the general public.

To comply with a judicial or administrative order, or as necessary for audit, legal and corporate governance functions.

To combat fraud or other criminal activity and to protect our rights and those of our business partners and users

To respond to domestic or foreign judicial, administrative or tax authorities who request or are entitled to have such information automatically transmitted in accordance with applicable regulations.


If you fail to communicate the Data that would be required in the above-mentioned cases, you are warned that sanctions could be applied to you. We cannot be held responsible if the User refuses to communicate the requested information.


Section 6.4 - Duration of retention of Personal Data

The duration of the retention of Personal Data collected by Versity may vary depending on the type of processing and is governed by :

The duration necessary to fulfill the purpose;

A legal retention period;

A period determined for regulatory or control reasons.

Thus, and without this list being exhaustive:

Management of commercial relationships: the entire duration of the commercial relationship and up to five (5) years thereafter (in accordance with Article 2224 of the Civil Code and Article L561-12 of the Monetary and Financial Code relating to the obligation to retain customer information as part of the fight against money laundering and terrorist financing).

Legal registers of the Company: it is specified that the legal registers kept by the Company must be kept for ten (10) years (articles 53, 65 and 72 of the decree of July 20, 1972); the names and addresses of the Company's clients appearing therein will therefore be kept for this entire period.

Sending of the newsletter: Duration of the subscription to the newsletter.


At the end of this retention period, these Personal Data are archived, deleted or anonymized, according to the prescriptions of the CNIL and in the respect of the preservation of the exercise of the rights of the persons.


Section 6.5 - Storage and Transfer of your Personal Data

a - Storage of your Personal Data

We prefer to host your Personal Data on servers located in the European Economic Area, but if necessary, we will use the "Standard Contractual Clauses" of the European Commission for the transfer of personal data to third countries. These clauses comply with Decision 2004/915/EC and Decision 2010/87/EU, as applicable.

b - Transfer of your Personal Data

Your Personal Data may also be transferred outside the European Economic Area (EEA) or Switzerland for two reasons: either for the performance of business relations between Versity and you, or because some of our service providers are located outside the European Economic Area. In such a case, we take particular care to ensure that this transfer is carried out in accordance with the applicable laws and regulations, and in particular with Law No. 78-17 of January 6, 1978 as amended by the Law of June 20, 2018 and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.

If you would like to know more about these transfers and storages, you can simply contact us at the address indicated in Section 12.1 "Asserting your rights", and we can provide you with additional information, including the European Commission's standard contractual clauses.


Section 6.6 - Data Security

In accordance with applicable regulations, Versity implements technical and organizational security measures to ensure the security and confidentiality of the Personal Data you provide, including preventing access, disclosure, loss or damage to such data by unauthorized persons.


Versity has implemented high security measures. In particular, the following measures may be cited:

Good hosting practices

Containerization of projects

Connection via SSH key

Physical and logical access management

Datacenters under video surveillance and guarding (SSIAP2 security agents) 24/7

Badge access control coupled with biometrics


When Versity uses a service provider, it will only disclose Personal Information to that service provider after it has imposed its own security principles.

Please note that no security measure is perfect or unbreakable. We cannot and do not guarantee that your Personal Information will not be accessed, viewed, disclosed, altered or destroyed by a breach of our physical, technical or managerial security measures.


Article 7 - Newsletter

The provisions of this Privacy Policy also apply to the request and sending of our newsletter.

The newsletter will only be sent after a request for prior consent from the user according to the so-called opt-in procedure.

Users of the newsletter are also assigned a user ID, which enables the Versity platform to determine when the relevant newsletter was opened and which links or functions of the relevant newsletter were activated. To do this, we may use tracking systems such as pixels or web beacons to detect message opening, link clicks, IP address or type of browser used to read the message and other similar information.

The tracking is done to optimize the newsletter internally: the Personal Data collected will therefore not be shared with third parties. The legal basis for this processing is Article 6(1)(f) of the GDPR. This authorization is justified because, on the one hand, Versity has a legitimate interest in evaluating this data in order to optimize its newsletter, and on the other hand, a data subject can reasonably expect, at the time of collection of the Personal Data, that the Personal Data will be processed for this purpose, taking into account the measures mentioned above.

The user has the right to withdraw consent at any time. If the user of the newsletter does not wish to receive this follow-up, he/she can unsubscribe from the newsletter. To do so, simply unsubscribe via the link in the newsletter or send an email to [email protected].

Withdrawal of consent does not affect the lawfulness of the processing based on the consent prior to its withdrawal.


Article 8 - Profiling

When you access the Site and use our services, we may use certain "profiling" techniques to send you personalized information or communications that concern you. Profiling can be defined as the automated processing of Personal Data consisting of using this Data to analyze and evaluate certain personal aspects relating to an individual (personal preferences, interests, behavior, location, movements, etc.). We may also rely on external data to improve our efficiency in this process.


Article 9 - Services and sites of third parties and hypertext links

Our Website includes a number of hypertext links directing the User to external websites that are totally independent from the structure of the Website and Versity. These sites listed below (non-exhaustive list) collect and process data.

When accessing and browsing these third-party sites, the User is informed when he/she is directed to another site. In this case, the User's Personal Data is exclusively subject to the general terms of use and sale as well as the privacy policy of the corresponding third party sites. We therefore invite you to read these documents on the third-party websites you visit. We cannot be responsible for the privacy policies and practices of other sites, even if you access them via links from Versity.


Sites concerned (non exhaustive list)






Article 10 - Cookie Management

Our Site uses cookies to distinguish you from other visitors. Cookies are small text files that may be stored on your computer (or other Internet-connected devices, such as a smartphone or tablet). They are sent by a server to your computer and stored on your hard drive to allow a website to recognize you when you visit a website.

Cookies can be used by a website to make the user experience more efficient. Our Site uses different types of cookies. Some cookies are placed by third-party services that appear on our pages. We use cookies to personalize content, provide social media features and analyze our traffic. This improves your experience when you browse our Site and allows us to improve the service we provide.

We also share information about your use of our Site with our Partners (e.g., social media and analytics), who may combine it with other information you have provided to them or that they have collected through your use of their services.

The Site does not store sensitive personal information such as your password, address, banking information, etc. in the cookies we use. The Site does not resell the information collected through cookies. This information is used only by the Site.

You can change or withdraw your consent to the declaration of cookies on our website at any time. Your consent applies to the following domains and all its sub-domains.

You are informed that, during your visits to our Site, cookies may be installed on your terminal equipment.

For your information, the cookies we use are :

Section 10.1 - Operating cookies

These cookies are necessary for the operation of the Site and for your navigation on the Site. As these cookies are essential, they cannot be deactivated in our systems. They are generally only set in response to actions you perform that correspond to a request for services, such as setting your privacy preferences, logging in, authenticating or entering forms. They do not store any personal data.

You can set your terminal (computer, tablet, mobile) to accept or refuse certain cookies. You are informed that by refusing the deposit of cookies, some elements of the Site will not work or will not work optimally.


Section 10.2 - Targeted and advertising cookies

These cookies may be set on our Site by our advertising partners. Marketing cookies are used to track visitors across websites. They may be used by these companies to profile your interests and show you relevant ads on other sites. The goal is to display ads that are relevant and appealing to the individual user and thus more valuable to third-party publishers and advertisers.

They do not store personal information directly, but are based on the unique identification of your browser and Internet device. If you do not allow these cookies, you will see fewer targeted ads.

Section 10.3 - Performance Cookies

These cookies are generally referred to as statistical cookies and allow us to count visits, traffic sources so that we can measure and improve the performance of our Site. They help us to know which pages are most popular and least popular and to see how visitors move through the Site.

All information collected by these cookies is aggregated and anonymized. If you do not allow these cookies, we will not know when you have visited our Site and we will not be able to monitor its performance.

Section 10.4 - Social Network and Video Cookies

If you accept cookies from social networks and videos, they allow you to share content from our Site with your contacts or to inform them of your visit or opinion on our Site when you click on the sharing buttons. They also allow us to create and display certain personalized advertisements related to our publications and offers.

To facilitate the understanding of the use of your data by social networks, we invite you to consult their privacy policy.

We have no control over the process used by social networks to collect information about your browsing on our Site and associated with your personal data they have.

Section 10.5 - Setting Cookies:

To manage cookies and other trackers, you have several options. When you first visit the Site, you will be informed of their presence and will be able to choose whether to accept them. If you change your mind later, you can change your browser settings to accept or decline them, or choose to accept only certain types of cookies.

You can also regularly delete cookies from your device through your browser. However, if you choose to decline cookies, some features of the Site may not be available.

Remember to set all of your browsers to delete or accept cookies. We recommend that you configure your consent from our cookie management module.


Article 11 - The user's rights regarding data collection and processing

You have the right to inform us not to process your personal information for marketing purposes. You can exercise your right and prevent us from processing such information by checking or unchecking certain boxes on the forms we use to collect your Data.

Data Subjects who have provided proof of their identity have the following rights (subject to the conditions, limitations and legal exceptions set forth in Chapter 3 art. 12 to 23 of the GDPR):

Right of access to your collected Data, of which you may obtain a copy.

Right to rectify any inaccurate or incomplete Data.

Right to object to the processing of your Data for legitimate reasons, except where legally required, and right to object without a legitimate reason to any use for prospecting purposes, particularly commercial.

Right to be forgotten and to have your Data erased in the cases provided for by the applicable law (withdrawal of consent, opposition, unlawful processing, data no longer required for the purpose of processing, etc.).

Right to the limitation of the processing of your Data in the cases provided for by the applicable law (when the accuracy of the Data is contested, when the processing is unlawful, when the Data is no longer necessary for the data controller but remains necessary for the Data Subject in order to assert his/her rights, etc.).

Right to the portability of your Data, allowing you to obtain the processed Data in a structured, commonly used and machine-readable format, and to transmit it or have it transmitted to another data controller.

Right to notification of any rectification, erasure of Data and restriction of processing by the data controller.

The right to refuse to allow your Data to be the subject of a decision based exclusively on automated processing, including profiling.

The right to define directives allowing access to your Data in the event of your death.


In particular, with respect to telephone conversations with Versity's sales or customer service, the Data Subject has the right to object to the recording of the conversation. If he or she does not object, he or she may exercise the rights mentioned above and obtain, upon request, a copy of the recording made.

Section 11.1 - Asserting your rights.

To exercise his or her rights, the Data Subject may contact us:

By email at the following address: [email protected]

By mail at the following address VERSITY - SERVICE CLIENTS - 25 AVENUE JEAN MÉDECIN - 06000 NICE

The Person Concerned will have to specify the object of the request (right aimed at) and by joining any documentary evidence allowing to attest of his identity (if necessary) or of the mandate in case of representation.

We undertake to process the request as soon as possible and to keep the person informed of the steps taken.

If these steps seem unsatisfactory, and in any case, he/she has the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL). For more information, you can consult the CNIL website (Address: Commission Nationale de l'Informatique et des Libertés - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 / Telephone: +33 (0)1 53 73 22 22).


Article 12 - Data controller and delegate for the protection of Personal Data

Section 12.1 - The person in charge of processing Personal Data is :

The Company VERSITY, SA (hereinafter the "Company")

25, avenue Jean Médecin - 06000 NICE

Trade and Companies Register (RCS): SIREN 878 379 940 RCS Nice

Intracommunity VAT number: FR 02878379940

Director of publication : Mr. Claude LI, President of the SA


Please note that the Company may also act as co-processor, sub-processor, or even as a subsequent sub-processor on behalf of other data controllers with whom the Company is contractually involved.


Section 12.2 - The Company's Data Protection Officer is :

Mathieu Avril - [email protected]


Section 13 - Modification of the Privacy Policy


We will update this Privacy Policy from time to time to incorporate any changes or proposed changes in our use of personal data or to comply with changes in applicable laws or regulatory requirements.

The user is encouraged to review this Policy each time he or she uses our services, without the need for formal notice.

If this Policy is updated, the effective date will be noted at the top of the page.