Privacy Policy

(updated: November 14, 2024)

1. INTRODUCTION

The operator of Nestflow.com, Nestflow B.V. (“Nestflow”), is focused on ensuring confidentiality and respect for your private life. Our mission is to offer simple, fair equity-release products to homeowners, connecting them with investors interested in buying their home equity for a just price.

As part of the transactions resulting from our services, we are required to process information concerning you (for example, when your data is used to receive an initial quotation or proposal for one of our products). Overall, when you use our Website and/or access our services, you send us information, some of which is likely to identify you (hereinafter "Personal Data" ).

Nestflow is committed to protecting your Personal Data and using it in accordance with your wishes. The purpose of this Privacy statement is to inform you of the way in which we process your Personal Data, the situations in which we may communicate your Personal Data to third parties, and your rights and the options available to you to control your personal information and protect your privacy.

Please read these terms and conditions carefully.

2) TERMS OF USE AND PRIVACY POLICY

When you use our Website, you are deemed to have read and accepted this Privacy Policy and Terms of Use. Your continued use of the Website signifies your understanding and acceptance of any changes to this Privacy Policy and Terms of Use, which Nestflow reserves the right to modify at any time.

When changes are made, Nestflow will make a new copy of this Privacy Policy and Terms of Use available on our Website. We will also update the "Updated" date at the top of this page. Any changes are effective immediately for new users of the Website and/or our services, and will be effective thirty (30) days after the posting of notice of such changes on the Website. Nestflow may require you to consent in some way to the updated Privacy Policy and Terms of Use before further use of the Website is permitted. If you do not agree to any change(s) after receiving notice of such change(s), you must stop using the Websites and/or our services. Otherwise, your continued use of the Websites and/or our services will constitute your acceptance of such change(s). PLEASE CHECK THE WEB SITE PERIODICALLY TO REVIEW THE THEN CURRENT TERMS OF USE.

Information

Nestflow is committed to providing accurate, reliable and current information through its website. However, errors or omissions may occur. You are therefore invited to review the information on the Website with judgment and critical thinking and, if necessary, report any inaccurate, outdated or erroneous content at the following email address: info@nestflow.com. Nestflow is not responsible for your use of the information on the Website, and for any direct or indirect damages that may result.

Children

Nestflow's website and services are not designed for or directed to children under the age of 16, and Nestflow does not knowingly collect Personal Data from anyone under the age of 16. If Nestflow discovers that it has inadvertently collected Personal Data from someone under the age of 16, we will take steps to remove that user's Personal Data from our databases and prevent the user from using our services. If you are under the age of 16, please do not register an account or send any personal information about yourself to us, including your name, address, phone number or email address. If you believe that we have collected personal information from a person under the age of 16, please contact us at info@nestflow.com.

Hyperlinks

Our website may contain content or links to other platforms that are not owned or controlled by us. We do not control, monitor and are not responsible for the privacy practices of, or the content displayed on, such other platforms. When you click on any such link, you will leave our Website and go to another platform. During this process, another entity may collect personal information or anonymous information from you. Please read the privacy policy of each new platform you visit.

In addition, Nestflow content (such as, but not limited to, advertisements) may be included on web pages and websites or platforms that are not affiliated with Nestflow and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags or other technology, independently collect information or request personal information, and may have the ability to track your use of their platforms, websites and services. Nestflow is not responsible for the privacy policies or content of third parties.

Accessibility of our Website

Access to our Website is free and generally available 24/7. However, due to the nature and complexity of the Internet, Nestflow cannot guarantee absolute accessibility or availability of the Website and is not responsible for any inaccessibility thereof.

In addition, Nestflow reserves the right, without prior notice or compensation, to close the Website temporarily or permanently, for example (but not limited to) in case of maintenance work or modifications to the servers. Nestflow is not responsible for damages of any kind that may result from these modifications or from the temporary unavailability or permanent closure of all or part of the Website or related services.

Intellectual property

All content on this website, including but not limited to databases, graphics, images, text, videos, photos, animations, sounds, logos, gifs and icons, as well as their formatting, are the exclusive property of Nestflow (or its suppliers or licensors). with the exception of third-party trademarks, logos or content.

Any reproduction, distribution, modification, adaptation, retransmission or publication, even in part, of these various elements comprising this Website is strictly prohibited without the express written consent of Nestflow. All intellectual property rights, including copyrights, patents, trademarks and trade secrets, in the Website and the content made available through this Website are owned by Nestflow and/or its suppliers and licensors. No right or license to use these elements is granted by implication, estoppel or otherwise. Neither these Terms of Use nor your use of the Website grants you or any third party any right, title or interest in or to such intellectual property rights, except for the limited access rights expressly set forth below. Nestflow and its suppliers and licensors reserve all rights not granted in these Terms of Use. No implied licenses are granted under these Terms of Use. You may not remove, alter or obscure any copyright, trademark, service mark or other proprietary rights notices contained in or accompanying the Website.

Subject to these Terms of Use, Nestflow grants you a non-transferable, non-exclusive, revocable, limited license to use and access the Website and to reproduce portions of the Website or information collected therefrom, all solely for your personal or internal purposes. business purposes.

Creating a user account

In order to use certain features of the Website and/or our services, you may need to register for an account and provide the required registration information. Nestflow , in its sole discretion, may not accept user account registration and may suspend or terminate your account at any time and for any reason. You agree that neither Nestflow nor its subsidiaries, suppliers or licensors shall be liable to you or any third party for any refusal to register your account, suspension or termination of your account or any refusal to use any of the Website and/or services thereon.

The truth and accuracy of data provided by users is an essential requirement for maintaining your account. One person is prohibited from having more than one account. If Nestflow detects duplicate accounts through the data verification system, both accounts will be permanently disabled. Account registration must be completed with accurate and truthful information, assuming you update your account information when a change occurs. Nestflow disclaims responsibility for the truth and accuracy of data entered by its users. In any event, you warrant and are responsible for the truthfulness and accuracy of your registration information. Nestflow reserves the right to use all valid and possible means to identify its users, and to request additional data and documents it deems relevant to verify the registration data.

You agree to access your account via email and password and agree not to share this information with third parties. You are fully responsible for any use made of your account. You agree to notify Nestflow immediately, by secure means, of any unauthorized use of your account, as well as any unauthorized access to it by third parties. You are solely responsible for all activities that occur under your account. The transfer, sale, rental or any other form of account transfer is not permitted under any circumstances. Also, you are not permitted to maintain more than one account for the same person, or to create new accounts for people whose original accounts have been deleted.

Content you send or transmit

You acknowledge and agree that you are responsible for all text, graphics, photographs, data, information or other material provided or uploaded by you to our Website or otherwise transmitted to us ("User Generated Content"), whether publicly posted or privately transmitted. You, and not Nestflow , are solely responsible for all User-Generated Content associated with your account. For each piece of user-generated content that you submit, you represent and warrant that: (i) you have the right to submit user-generated content to us and to grant the licenses required for our receipt and use of such user-generated content; (ii) Nestflow is not required to obtain licenses from third parties or pay royalties to third parties to use such user-generated content; (iii) user-generated content does not violate, infringe or misappropriate the rights of third parties, including any copyrights, trademarks or other intellectual property and privacy rights; and (iv) user-generated content complies with these Terms of Use and all applicable laws.

You acknowledge and agree that Nestflow may access, preserve and disclose account information and/or user-generated content provided by you if Nestflow is required to do so by applicable law or if we believe in good faith that such access, preservation or disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce these Terms of Use, (iii) respond to claims that user-generated content violates the rights of third parties, (iv) respond to your requests for customer service, or (v ) protect the rights, property or personal safety of Nestflow, our employees, directors or officers, partners and agents, or members of the public.

You agree not to upload any user-generated content that is or contains material that: (i) is offensive, abusive, defamatory, pornographic or obscene, (ii) is illegal or promotes an illegal act of any kind, including violations of Nestflow's or any third party's intellectual property rights, privacy or proprietary rights, (iii) contains or is intended to solicit personal information from third parties, (iv) contains malicious content, such as malware, Trojans or viruses or otherwise interferes with the proper functioning thereof functioning of our Website and/or services, or with a user's access thereto, (v) is intended to harass or bully anyone, (vi) mimics or misrepresents your identity or your relationship with another user, person or entity , or is otherwise fraudulent, false, deceptive or misleading (in which case Nestflow may, at any time and in its sole discretion, reclaim your username), (vii) uses automated means to artificially promote content, (viii) includes the transmission of unsolicited mass mailings ("spam"), junk mail, chain letters or similar communications, (ix) involves commercial or sales activities such as advertising, contests, sweepstakes or pyramid schemes, (x) disrupts or interferes with the Website and/or our services, tampers with or attempts to scan or test for vulnerabilities in the Website or Nestflow's computer systems or network, or breaches Nestflow's security, encryption or authentication measures, (xi) harms or exploits people under age 18 (or such other age as determined by applicable law), or (xii) violates these Terms of Use, in each case as determined by Nestflow.

Disputes

These Terms of Use are governed by Dutch law. Any dispute or controversy arising out of the interpretation or performance of these Terms of Use shall be subject to the exclusive jurisdiction of the Dutch courts. The reference language for the resolution of any disputes shall be Dutch.

Personal data and cookies

The purpose of this Policy is to inform you about the processing of your personal data and the use of cookies during your navigation on our Website (the "Site").

Through this privacy policy, we want you to understand the nature of the personal information we collect, how we use it, with whom we share it, how we strive to protect it, how to exercise your rights and, finally, how to contact us.

The purpose of this document is also to provide you with all the information required by Article 32 of the Data Protection Act and by Article 13 of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("AVG").

Section 1 - Data Manager(s).

Personal information collected on the Site is subject to computer data processing by Nest Egg Europe B.V., whose headquarters are located at 't Braassemhof 2, 2371BL, Roelofarendsveen, The Netherlands.

Section 2 - Collection of personal data

The term "personal data" means any information relating to an identified or identifiable natural person.

In accordance with the minimization principle, Nestflow ensures that it collects only personal data that is strictly necessary for the processing performed to provide our Site and all services requested by you.

When you browse the Site or as a result of your actions, Nestflow, in its capacity as data controller, may collect personal information about you.

Action 1: When browsing the site

The personal data collected are the following: browsing data such as IP address and communication data made available through the use of your computer. This data is collected (i) automatically, (ii) or after obtaining your consent. Please note that some data collected is necessary to provide you with information, services or to process your request(s).

In addition, statistical data may be collected and used during your visit (number of pages viewed, number of site visits, etc.). For more information about the data collected as part of the use of cookies, see the "Cookies" section below and/or the cookie consent module when you first visit the Site.

Action 2: When you decide to receive information from us, such as newsletters and/or commercial proposals/offers

When you subscribe to the newsletter or agree to receive proposals/offers, you provide your identifying and contact information to:

  • Newsletters from Nestflow, and/or
  • Commercial offers from Nestflow

Action 3: When you decide to contact us for your real estate equity release needs

Personal data collected may include the following:

  • information related to your assets (address of your property,title deed or other land registry information of the property,characteristics of your property, bank accounts, investments)
  • data regarding your obligations (existing mortgages, loans or other debts, tax situation)
  • information relating to your identity and/or the identity of your beneficiaries (such as passport or other identity documents, utility bills or other proof of residence)
  • contact information (mailing address, e-mail address, phone number, etc.) that you provide to us

Action 4: When you decide to contact us to join Nestflow

On our site, you may be able to apply for jobs with Nestflow (as an employee) or apply to become a partner for Nestflow's services.

In this case, the personal data collected are as follows:

  • information regarding the desired position (nature of position, dates of availability, desired location, etc.)
  • information related to your professional training (diploma, professional experience, CV, etc.)
  • information relating to your identity and/or contact information.

Action 5: If you decide to contact us for any other reason

The personal data collected are as follows:

  • information related to your identity (e.g., name)
  • contact information (e-mail address, phone number)
  • information related to your contact request

Section 3 - Purposes and legal bases for processing personal data

The purposes and legal bases of the data processing performed through the Site are as follows:

  • Actions
    • Purposes
    • Legal basis

  • Action 1: When on the site
    • See "Cookie Consent"
    • Consent or legitimate interest.

  • Action 2: When you decide to subscribe to the newsletter
    • Keep in touch with you through monthly email newsletters.
    • Nestflow's legitimate interest when you register through our newsletter sign-up form, or otherwise subscribe to our newsletter.

  • Action 3: When you decide to contact us for your equity release needs in real estate
    • Consider your need for release of equity from your property.
    • Implementation of pre-contractual measures requested by you.

  • Action 4: When you decide to contact us to work with Nestflow
    • Keep in mind your desire to work with Nestflow.
    • Performance of pre-contractual measures requested by you and Nestflow's legitimate interest in managing its recruitment processes.

  • Action 5: When you decide to contact us
    • Being able to take into account your contact request with Nestflow.
    • Nestflow's legitimate interest in responding to commercial inquiries.

Your data may also be processed for the following purposes and legal grounds:

  • Respond to your requests to exercise rights (right to access, rectification, deletion, opposition, portability, etc.).
  • Legal obligation of Nestflow.
  • If applicable, be able to demonstrate compliance with our legal and regulatory obligations.
  • Legal obligation of Nestflow.

Section 4 - Recipients or categories of recipients of personal data

Receiver(s): Nestflow

Your personal information is intended for Nestflow to respond to the various services offered by the Site, for administrative and commercial management purposes.

Recipients from subcontractors:

Your personal information, where applicable, may be disclosed to subcontractors that Nestflow may use as part of the performance of the services provided by the Site. Nestflow will ensure compliance with data protection requirements for all of its subcontractors.

Judicial, public or government agencies:

Where applicable, Nestflow may be required to disclose your personal information, namely when necessary to:

  • Comply with the law (or a subpoena or court order).
  • Comply with lawful requests from public and government agencies.
  • Prevent a crime or conduct an investigation, such as fraud or identity theft.
  • Protect the rights, property or safety of Nestflow, Nestflow users or employees or partners, or third parties.

Data transfer outside the European Union

As part of this policy, Nestflow informs you that your personal information will not be transferred outside the European Union.

Section 5 - Appointment of a data protection officer

Nestflow has appointed a Data Protection Officer ("DPO") who is responsible for ensuring compliance with personal data protection regulations. The contact details can be found below. If you wish to exercise your rights, as defined in the article "Rights of individuals" below, please contact Nestflow directly by mail or email.

Contact by mail:

Nest Egg Europe B.V.

Attn: DPO

't Braassemhof 2,

2371BL, Roelofarendsveen

Netherlands

Electronic contact: dpo@nestflow.com

Section 6 - Rights of individuals

Data protection rights

You have the right to access, rectify, delete and transfer your personal data. You may also request that the processing of data relating to you be restricted or object to such processing. You have the right to pass on your instructions regarding your personal data to Nestflow in the event of your death.

You can exercise your rights with Nestflow's Data Protection Officer, whose contact details are listed above.

To protect your privacy and ensure your security, we will also take reasonable steps to verify your identity before granting you access to, correcting, modifying or deleting your personal information.

If your rights are not respected, you can file a complaint with the Personal Data Authority (https://www.autoriteitpersoonsgegevens.nl/).

Rights related to receiving email communications

You can unsubscribe from the sending of commercial offers and/or unsubscribe from our newsletter free of charge at any time:

  • By emailing Nestflow at dpo@nestflow.com
  • By clicking the unsubscribe link at the bottom of every email Nestlow  sends (where applicable)

Rights regarding cold calling

When you contact Nestflow through any of the forms available on the Site, Nestflow may contact you by telephone to make service offers to you.

Nestflow will only call you in response to your request for contact or information. However, if you believe Nestflow is contacting you without your consent, please notify us at info@nestflow.com. You should also know that several countries offer "do not call" lists (against telephone acquisition/unsolicited calls), which you can register for here:

Section 7 - Data security and confidentiality

Nestflow implements organizational and technical security measures designed to ensure the confidentiality and integrity of your personal information. Our administrative, organizational, technical and physical safeguards are designed to protect your personal information from loss, theft, unauthorized access, unauthorized transfer, alteration or destruction.

In all cases, Nestflow will implement security measures appropriate to the nature of the data collected.

The data collected is stored confidentially and protected at a high level of security. The servers where this data is stored meet current security standards. They are protected against digital attacks and physical attacks. The personal data collected by Nestflow is hosted in Europe.

All pages of the Site that require you to submit personal information are secured using https.

Article 8 - Retention periods of personal data

Nestflow retains your personal information only as long as necessary for the activities for which it was collected, and in accordance with applicable regulations.

In general, depending on your situation, the following retention periods may apply (each following the date of our last contact with you):

  • Data categories
    • Shelf life
    • internet users

  • Identification and contact information used for commercial prospecting purposes (newsletter subscription)
    • 3 years

  • Data related to the use of cookies
    • See "Cookie Consent"

  • Potential customers of Nestflow
    • Data collected as part of your request to investigate the release of equity from your real estate assets
    • 3 years or, if a contractual relationship is subsequently established (you become a customer), for Nestflow customers, retention periods apply as specified in the final contract.

  • Applicants for commercial partners of Nestflow
    • Data collected and processed for analysis if you apply to become a Nestflow commercial partner
    • Duration required for recruitment management and professional experience needs (3 years)

  • Candidates for Nestflow employment
    • Data collected and processed for recruitment purposes if you apply to become an employee of Nestflow
    • 2 years

  • Other contact requests
    • Data collected and processed to respond to contact requests
    • Duration of relationships with request issuer.

Certain data may be retained for an additional period of time to manage complaints and/or litigation, as well as to comply with our legal or regulatory obligations, or to respond to requests from competent authorities.

Section 9 - Use of cookies

What is a cookie?

A cookie is a small text file stored in a special place on the hard drive of your terminal when you consult an online service with your browser. It allows the publisher to identify the terminal on which the cookie is stored, during the cookie's validity or registration period.

How may cookies be used on the Site?

Cookies used on the Site are used for the purposes defined in our consent management solution (or "CMP"). They may enable Nestflow to personalize the content of the Site, offer functionalities related to social networks and analyze your traffic.

The Site also uses "functional" cookies, which are necessary for its proper functioning. These cookies are set automatically as soon as you arrive on the Site.

For all other types of cookies that are not exempt from consent, they can only be placed after obtaining your consent to their use through our CMP.

How do you use our CMP?

During your first visit to the Site, our permission management solution appears to inform you about the different cookies used, their purpose(s), their supplier and their validity period/registration on your terminal.

This manager allows you to:

  • To accept all cookies ("OK!").
  • Refusing the use of all cookies except those required for the proper functioning of the site ("No thanks")
  • To select which cookies you want to accept ("I want to choose")

After your initial choice is made, you will find all the information about your consent in the cookie window that can be accessed through the oval "hand" icon at the bottom of each page of the site.

You will then have the opportunity to change your choices and/or withdraw your consent at any time.

Specific case of third-party applications integrated into the Site

Certain third-party applications may be integrated into the Site (e.g., social networking applications). These applications allow you to share content from our Site with third parties, share your review or opinion of our Site via social networking, etc.

The social network that provides an application button is likely to identify you using this button, even if you have not used it during your consultation of our Site, if your account on this social network is active on your terminal (open session).

We have no control over the use and collection of data related to your browsing by social networks.

We invite you to consult the data protection policies of these social networks so that you are aware of the uses, especially advertising, of the information they may collect through these application buttons.