Privacy Policy

1. Data Controller

The data controller for the processing described in this policy is:

• Aloha Immo Services SARLU — Real Estate and Services Agency
• Manager: WALTZINGER Benjamin, Loretto
• Headquarters: Opposite Air Madagascar, Rue Henri Martin, Tuléar Centre, Toliara 601, Madagascar
• RCS Toliara: 2022B00004 — NIF: 4011668067 — STAT: 68101 51 2022 0 00019
• Share capital: 2,000,000 MGA
• Email: contact@alohaimmoservices.com
• Telephone numbers: +261 38 18 257 37 / +261 34 13 154 30

The website currently accessible at dev.alohaimmoservices.com constitutes the development/pre-production environment. After final launch, the primary domain will be alohaimmoservices.com. This policy applies to both environments when operated by Aloha Immo Services.

2. Legal framework

Aloha Immo Services processes personal data in accordance with applicable Malagasy law, in particular Law No. 2014-038 of 9 January 2015 relating to the protection of personal data and its implementing texts.

The Malagasy system notably includes the involvement of the Malagasy Commission for Information Technology and Freedoms (CMIL). Decree No. 2023-1541 of December 6, 2023, defines its responsibilities, organization, and operation, as well as the framework applicable to certain data processing activities. Official texts are published by the competent Malagasy authorities.

When specific obligations arise from a real estate transaction, particularly in tax, land, notarial, accounting, judicial matters or in the fight against money laundering and the financing of terrorism, Aloha Immo Services may process and retain the data necessary to comply with these obligations.

3. Data that may be collected

Depending on the relationship with the agency and the services used, Aloha Immo Services may collect, in particular:

• Identity: name, surname, title; ;
• Contact details: email address, telephone number, postal address; ;
• information relating to a property search: type of property, area sought, budget, criteria, schedule and preferences; ;
• information relating to a property: address or location, characteristics, documents, photographs, information relating to the owner or the principal; ;
• information necessary for a transaction or rental: identity, contractual situation, supporting documents, administrative, tax, banking or financial information when its collection is necessary and legally justified; ;
• data relating to visits, inquiries, mandates, offers, negotiations and transactions carried out; ;
• communication data: content of emails, messages, requests and exchanges with the agency; ;
• Technical data: IP address, browser, device, connection data and information necessary for the security and operation of the Site; ;
• data relating to communication preferences when the user agrees to receive commercial information.

Aloha Immo Services does not, as a matter of principle, request sensitive data that is not necessary for its services. If particularly sensitive data is exceptionally required, its processing is carried out only under the conditions provided for by applicable legislation.

4. How is the data collected?

Data may be collected directly from the person concerned, particularly when that person:

• fills out a contact form; ;
• requests a visit; ;
• requests a property valuation or search; ;
• request for information about a property; ;
• communicates with the agency by email, telephone or messaging; ;
• provides documents in connection with a sale, rental, management or other service; ;
• enters into a mandate, lease, contract or other document with the agency.

Some data may also be obtained indirectly from owners, principals, purchasers, tenants, representatives, partners, administrations or professionals involved in a transaction, when this collection is legitimate and necessary.

5. Purposes of the processing

The data may be processed in particular for:

• respond to contact and information requests; ;
• identify the people with whom the agency communicates; ;
• organize and monitor the visits; ;
• to offer properties that meet the communicated criteria; ;
• to conduct tailored real estate searches; ;
• managing relationships with sellers, buyers, landlords, tenants, owners and principals; ;
• prepare, execute and monitor mandates and contracts; ;
• to facilitate sales, rental, transfer or management operations; ;
• to carry out the necessary administrative, land, tax, notarial or contractual procedures; ;
• verify certain documents and information as part of the agency's legal obligations; ;
• comply with due diligence obligations, particularly in the fight against money laundering and terrorist financing; ;
• to handle invoicing, accounting and debt collection; ;
• to ensure the security of the Site and prevent abuse, fraud and incidents; ;
• improve the content, presentation and functionality of the Site; ;
• send commercial information when permitted and, when required, after consent; ;
• retain the elements necessary for the defense of the agency's rights and for proving its operations.

6. Basis and justification of the processing

Depending on the processing involved, Aloha Immo Services processes data because it is necessary:

• to the execution of a request or a contract; ;
• to the preparation of a contractual relationship at the request of the person; ;
• to comply with a legal or regulatory obligation; ;
• in pursuit of the agency's legitimate interests, including the management of its business, security, fraud prevention and the defense of its rights; ;
• or, where required, with the consent of the person concerned.

When processing is based on consent, this consent may be withdrawn under the conditions provided by law. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7. Website Forms

The form fields are intended to allow the agency to process the corresponding request.

The required information is that which is necessary to process the request. Without this information, Aloha Immo Services may not be able to respond, arrange a viewing, or provide the requested service.

The user agrees to provide accurate information and not to transmit data concerning a third party without having a legal basis or authorization allowing such transmission.

8. Data relating to owners and properties

As part of its real estate activities, Aloha Immo Services may process information concerning owners, principals or holders of rights to properties.

This information may include documents relating to the property, titles or land references, plans, cadastral information, administrative documents, contact details and elements necessary for the marketing or completion of the transaction.

When certain information needs to be communicated to a buyer, tenant, notary, administration or other professional, Aloha Immo Services limits, as far as possible, the communication to the data necessary for the transaction.

The precise location of a property may intentionally not be published on the Site in order to protect the safety and confidentiality of the owner and the property.

9. Data relating to buyers and tenants

In the context of a sale or rental, Aloha Immo Services may request information and supporting documents necessary for the review of the file, the drafting or execution of contractual documents and compliance with legal obligations.

Depending on the transaction, this may include proof of identity, contact details, professional status, financial information, proof of address or documents required by the owner, landlord, notary, administration or applicable regulations.

The documents requested must be proportionate to the operation and the intended purpose.

10. Data sharing and recipients

Aloha Immo Services does not sell the personal data of its clients or prospects.

The data may be disclosed, when necessary and to the extent relevant, to:

• employees or authorized representatives of Aloha Immo Services; ;
• owners, principals, purchasers or tenants when the transaction justifies it; ;
• notaries, lawyers, surveyors, experts, banks, insurers or other professionals involved in the transaction; ;
• competent public administrations and authorities when communication is legally required or necessary; ;
• technical service providers involved in hosting, website, email, security, backup or IT tools for the agency; ;
• accounting or administrative service providers when necessary.

Each recipient only has access to the information necessary for their mission, subject to applicable legal and contractual obligations.

11. Subcontractors and technology services

The operation of the Site may require the use of technical service providers, in particular for hosting, email, forms, maintenance, security, backups, statistics or management tools.

When these service providers process data on behalf of Aloha Immo Services, the agency ensures, to the extent required by applicable regulations, that these processing operations are regulated and that access to data is limited to the needs of the service.

Some technical service providers may be located outside of Madagascar. When data is transferred or made accessible abroad, Aloha Immo Services implements the measures and verifications required by applicable law.

12. Website Hosting

The Site is hosted by a hosting provider chosen by Aloha Immo Services. Hosting, security, and technical operations may involve the processing of technical and connection data.

The exact contact details of the hosting provider and the necessary technical information may be specified or updated in the Legal Notices of the Site.

13. Cookies and trackers

The Site may use cookies or similar technologies necessary for its operation, security, display of content, audience measurement or certain functionalities.

Cookies strictly necessary for the operation of the Site may be used where permitted by law. Non-essential cookies, including certain analytical, advertising, or personalization cookies, are used only under the conditions stipulated by applicable regulations and, where required, with consent.

A cookie policy or management module may specify the categories used, their purpose, their duration, and the means of managing preferences.

14. Data retention

Aloha Immo Services retains data for a period proportionate to its purpose.

Simple requests for contact or information may be kept for the time necessary for processing and then for a reasonable period allowing for the monitoring of the relationship.

Data related to a contractual relationship, a real estate transaction, invoicing, accounting, a legal obligation or litigation may be kept for the periods imposed or permitted by applicable laws and for the period necessary to defend the rights of the agency.

Upon expiry of the applicable period, the data is deleted, anonymized or archived when archiving is legally justified.

15. Security and confidentiality

Aloha Immo Services implements reasonable security measures adapted to the nature of the data and the risks: access control, limitation of authorizations, protection of equipment and accounts, backups and technical and organizational security measures when necessary.

However, no computer system or internet transmission can be guaranteed to be completely secure. Therefore, the agency cannot guarantee absolute security against any incident, attack, or event reasonably beyond its control.

16. Data Breaches

In the event of a security incident likely to affect personal data, Aloha Immo Services will take the reasonable steps necessary to contain, analyze and remedy the incident and will, where required by law, make appropriate notifications or communications to the competent authorities and/or the persons concerned.

17. Rights of the persons concerned

Subject to the conditions and limits provided for by Malagasy legislation, the persons concerned may in particular have rights relating to their data, such as the right of access, rectification and, where the legal conditions are met, erasure, objection, limitation or other rights provided for by the applicable texts.

When processing is based on consent, the person may withdraw it under the applicable conditions.

Aloha Immo Services may request reasonable proof of identity before proceeding with a request in order to avoid any disclosure of data to an unauthorized person.

18. Exercising rights and contact data

Any request relating to personal data can be addressed to:

Aloha Immo Services SARLU — Opposite Air Madagascar, Rue Henri Martin, Tuléar Centre, Toliara 601, Madagascar

Email: contact@alohaimmoservices.com

Telephone: +261 38 18 257 37 / +261 34 13 154 30

The request should, as far as possible, specify the right exercised, the data or processing concerned and the elements enabling the person to be identified.

Aloha Immo Services responds within the conditions and timeframes stipulated by applicable regulations. When a request cannot be fulfilled, the agency provides, to the extent required, the reason for its refusal.

19. Complaint to the competent authority

When a person believes that their rights relating to their personal data are not being respected, they can, after contacting Aloha Immo Services when appropriate, exercise the legal remedies or contact the competent Malagasy data protection authority, in particular the Malagasy Commission for Information Technology and Freedoms (CMIL), according to the procedures provided for by the applicable regulations.

20. Prospecting and commercial communications

Aloha Immo Services may send information relating to its goods, services or news when permitted by applicable regulations or when the person has given their consent when required.

Every commercial communication must, where required by law, allow its recipient to opt out of receiving further communications of this nature.

Withdrawal of consent or objection to commercial prospecting does not prevent the agency from retaining and processing data necessary for the performance of a contract, compliance with a legal obligation or the defense of its rights.

21. Data on minors

The Site and services of Aloha Immo Services are not intended to voluntarily collect data from minors for commercial purposes.

When a real estate transaction involves a minor or information concerning him/her, processing is carried out only when necessary for the transaction and in accordance with applicable legal rules, with the involvement of his/her legal representative when required.

22. Data transmitted by a user concerning a third party

When a user provides Aloha Immo Services with the data of a third party, it is their responsibility to ensure that they have the necessary right or authorization to carry out this transmission.

In the context of real estate transactions, this may include the contact details of a spouse, co-owner, representative, principal, buyer or tenant.

23. International Transfers

As part of its IT tools or certain services used by the agency, data may be hosted or processed outside of Madagascar.

Aloha Immo Services ensures that these transfers are carried out in accordance with the requirements of applicable Malagasy law and the guarantees that may be required depending on the destination and the service provider concerned.

24. Links to third-party services

The Site may contain links to third-party platforms or services. This policy does not govern the processing carried out by these third parties on their own platforms.

Users should consult the privacy policies of the relevant services before transmitting personal data to them.

25. Policy Update

This Privacy Policy may be modified to reflect changes in services, technologies or regulations.

The version published on the Site is the current version. In the event of a substantial modification, Aloha Immo Services may, where appropriate, inform the persons concerned by a suitable means.

26. Version and effective date

Version: 1.0

Date of update: October 2026

Effective date: from the date of publication on the Site.

This policy is intended to be published on dev.alohaimmoservices.com during the development phase and then on alohaimmoservices.com after final online publication.

Appendix — Main reference texts

• Law No. 2014-038 of 9 January 2015 relating to the protection of personal data.
• Decree No. 2023-1541 of December 6, 2023 concerning the powers, organization and operation of the Malagasy Commission for Information Technology and Freedoms (CMIL) and the processing of personal data.
• Other Malagasy texts applicable depending on the nature of the treatments and real estate transactions.

This policy must be interpreted in conjunction with the Legal Notices, the Terms and Conditions of Use and, where necessary, the Site's cookie policy.

Document prepared for publication on the Aloha Immo Services SARLU website. Final legal validation recommended before publication.