Property Management Policy

Article 1 – Property Management Regulatory Framework – G Card Delegation

1.1 Partnership and Subcontracting

In accordance with French Law n° 70-9 of January 2, 1970 (known as the "Hoguet Law") and its implementing Decree n° 72-678 of July 20, 1972, AE RÉSEAUX, operating under the trade name "ADOPTE UNE CONCIERGERIE", operates within a subcontracting framework for activities requiring a professional property management card (G card).

1.2 Professional Card Holder

1.3 Authorized Activities

The professional card authorizes the following activities:

• Real estate and business transactions: intermediation for purchase, sale, or rental of real estate
• Property management: administration of real estate on behalf of third parties, including rent collection, lease monitoring, and day-to-day property management

1.4 Financial Guarantee

In accordance with Articles 3 and following of the Hoguet Law, UNLOCKER REAL ESTATE holds a financial guarantee from:

Article 2 – Listing and Fund Management

2.1 Listing Publication

All listings relating to properties under rental management are published and distributed within the subcontracting framework above. Distribution occurs on:

• Online booking portals (Airbnb, Booking.com, Abritel, etc.)
• Proprietary and partner websites
• Professional social networks
• Any other communication channel agreed with property owners

2.2 Exclusive Fund Management

Important: All funds received for rentals (rent, deposits, charges) are exclusively managed by UNLOCKER REAL ESTATE, holder of the professional card and corresponding financial guarantee.

AE RÉSEAUX never collects rental funds on behalf of property owners. This strict separation ensures regulatory compliance and financial protection for principals.

Article 3 – Insurance Coverage

3.1 Professional Liability Insurance

AE RÉSEAUX holds Professional Liability Insurance (PLI) from:

Article 4 – Payment Methods and Financial Security

4.1 Accepted Payment Methods

For transparency, traceability, and compliance with anti-money laundering (AML-CFT) obligations, AE RÉSEAUX requires the following payment methods:

• SEPA bank transfer: preferred payment method for all transactions
• Credit/debit card payment: via secure terminals or approved online payment platforms
• SEPA direct debit: with prior customer authorization for recurring payments

4.2 Cash Payment Exclusion

Formal prohibition: In accordance with its internal compliance policy and TRACFIN recommendations, AE RÉSEAUX categorically refuses all cash payments, regardless of amount.

This measure ensures complete traceability of financial flows and prevents any money laundering risk. No exceptions will be granted.

Article 5 – Contractual Framework and Party Obligations

5.1 Service Contracts

All AE RÉSEAUX interventions are governed by written service contracts defining:

• Nature and scope of services
• Respective obligations of parties
• Pricing conditions and payment terms
• Contract duration and termination conditions
• Liability and insurance clauses

5.2 Non-Solicitation Clause

All contracts with AE RÉSEAUX include a non-solicitation clause prohibiting the client, during the contract and for twelve (12) months after termination, from hiring or soliciting any AE RÉSEAUX employee, collaborator, or subcontractor who participated in service delivery.

5.3 Prohibition of Illegal Activities

AE RÉSEAUX clients and partners expressly commit not to use properties or services provided for activities:

• Contrary to French legislation or applicable regulations
• Harmful to public order, morality, or human dignity
• Within criminal scope (trafficking, prostitution, etc.)
• Likely to harm third parties or AE RÉSEAUX reputation

Article 6 – Right of Refusal and Acceptance Policy

6.1 Free Acceptance Principle

Under the principle of contractual freedom, AE RÉSEAUX reserves the right to refuse any assignment, service request, or accommodation access without justification, including for internal policy, client confidentiality, quality, security, or regulatory compliance reasons.

Article 7 – Personal Data Protection

AE RÉSEAUX acts as data controller for personal data collected in the course of its activities, under GDPR Regulation (EU) 2016/679 and French Law n° 78-17 of January 6, 1978.

Article 8 – Confidentiality

AE RÉSEAUX and all its collaborators are bound by strict confidentiality regarding client and owner personal information, property characteristics and locations, financial and commercial conditions, and any information identifying occupants. This confidentiality obligation continues for five (5) years after contractual relationships end.

Article 9 – Intellectual Property

"ADOPTE UNE CONCIERGERIE" and "LES GRAINES NOBLES" are registered trademarks protected by INPI. Any unauthorized reproduction or exploitation constitutes counterfeiting.

Article 10 – Anti-Money Laundering and Counter-Terrorism Financing

In accordance with the French Monetary and Financial Code regarding AML-CFT, AE RÉSEAUX implements vigilance procedures including client and beneficial owner identification, business relationship knowledge, operation monitoring, and suspicious activity reporting to TRACFIN.

Article 11 – Mediation and Dispute Resolution

11.1 Complaints

All complaints should first be addressed to AE RÉSEAUX customer service by email at [email protected]. A response will be provided within fifteen (15) business days.

11.2 Jurisdiction

Article 12 – Effective Date and Updates

This policy takes effect upon publication on the company website and may be modified at any time for regulatory changes or company organizational changes. The applicable version is that in force at order date or contract signature.