PERSONAL DATA PROTECTION POLICY
1. PURPOSE
This Personal Data Protection Policy (hereinafter referred to as the “Policy”) applies without restriction or reservation between the User and the Company in its capacity as Data Controller.
Its purpose is to provide information on how the Data Controller may collect and process the User’s Personal Data in accordance with applicable legislation, particularly European Regulation No. 2016/679 and Law No. 78-17 (hereinafter referred to as the “Legislation”), within the framework of using the Site.
This Policy also outlines the rights Users have regarding their Personal Data under the Legislation.
2. DEFINITIONS
The words and phrases used in this Policy, with their first letter capitalized, have the meanings assigned to them below, whether used in the singular or plural.
– “Personal Data” : Any information related to the User.
– “Partners” : Any natural or legal person, including real estate sites/portals, real estate agencies, agency networks, craftsmen, notaries, property managers, insurance firms, or banks with whom the Company may collaborate and who may receive communication of Personal Data.
– “Data Controller” : The Company, which alone or jointly with others determines the purposes and means of Processing.
– “Site” : The infrastructure consisting of various types of data, including texts, sounds, still or animated images, videos, and databases, intended to be accessed by the User at 183 avenue Charles de Gaulle, 92200 NEUILLY SUR SEINE.
– “Company” : Sextant Properties, with a capital of €142,871.00, registered under company number 522 780 014, headquartered at 183 avenue Charles de Gaulle, 92200 NEUILLY SUR SEINE, acting as the Data Controller.
– “Processor” : Any natural or legal person, public authority, service, or other entity that processes Personal Data on behalf of the Data Controller.
– “Third Party” : Any natural or legal person, public authority, or entity other than the Company, its potential Processors and Partners, and those under their direct authority who are authorized to process Personal Data.
– “Processing” : Any operation or set of operations performed on Personal Data, whether automated or not, such as collection, recording, organization, structuring, storage, adaptation, modification, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.
– “User” : Any natural person, whether or not they have an account, using the services or browsing the Company’s Site as a client or a visitor, who can be identified directly or indirectly, especially via an identifier such as a name, identification number, location data, online identifier, or other elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
3. PRINCIPLES OF PROCESSING
In compliance with Legislation, the collection and processing of Client data adhere to the following principles:
– Lawfulness, fairness, and transparency : Personal Data may only be collected and processed with the Client’s consent, as they are the sole owner of their Personal Data. At each collection of Personal Data, Clients will be informed about the data being collected and the purposes for which they will be used.
– Purpose limitation : Data collection and processing are carried out to achieve one or more specific objectives.
– Data minimization : Only the necessary Personal Data required for the intended purposes and in the interest of the Client are collected.
– Data retention : Personal Data is stored for a limited period, which the Client is informed about. If it cannot be provided at the time of collection, it will be communicated later. The Company is committed to providing the criteria used to determine retention periods.
– Integrity and confidentiality : The Company ensures the integrity and confidentiality of collected data.
Users are informed, in advance, that the collection and Processing of Personal Data are subject to one of the following legal bases:
– The Client has expressly consented to the Processing.
– The Processing is necessary for the performance of a contract.
– The Processing is required to fulfill a legal obligation.
– The Processing is necessary to safeguard vital interests.
– The Processing is part of a public interest mission.
– The Processing serves the legitimate interests pursued by the Data Controller.
4. PROCESSED PERSONAL DATA
The Company processes the Personal Data of Users browsing, consulting, or entering personal information on the Site, particularly:
– Identification data : Name, surname, email address, phone number, message, project details, and property characteristics.
– Financial data
– Technical data : IP address, browsing data
5. DATA COLLECTION AND PROCESSING METHODS
The User’s Personal Data may be collected and processed in different ways, including when the User:
– Browses the Site and reads articles.
– Creates an account.
– Subscribes to newsletters or alerts.
– Writes a comment or review on the Site.
– Shares an opinion via email from a property listing.
– Shares an opinion through Facebook, Google+, Twitter, LinkedIn, Instagram, Pinterest, or from an article page.
– Fills in an information or correspondence form on the Site.
6. PURPOSE AND RETENTION OF PERSONAL DATA
Personal Data is collected for the following purposes:
| Purpose | Data Concerned | Legal Basis | Retention Period |
|---|---|---|---|
| Account creation and management | Name, email, phone number, address, project details | User’s consent | 3 years from last login or upon account deletion request |
| Commercial prospecting | Name, email, phone number, project details | User’s consent | 3 years from last contact |
| Business relations management | Name, email, phone number, project details | User’s consent | 3 years from last contact |
| Site security and improvement | IP address, browsing data | Legitimate interest | 13 months |
| Site statistics and marketing research | IP address, browsing data | User’s consent | 6 months |
| Content personalization, targeted advertising | IP address, browsing data | User’s consent | 6 months |
| Managing personal data rights requests | Email, phone, ID copy | User’s consent | 3 years from last contact |
The Company reserves the right to anonymize data before deletion.
7. DATA RECIPIENTS
Personal Data is processed only by the Company, its Processors, and Partners for necessary services like database maintenance, security, and fraud prevention. Third-party sharing is done only when legally required or with User consent.
8. INTERNATIONAL DATA TRANSFERS
All Personal Data is stored on secure servers within the EU. No transfer outside the EU occurs without prior explicit User consent.
9. USER RIGHTS OVER PERSONAL DATA
Users have rights under the Legislation, including:
– Right of access, rectification, and erasure
– Right to restrict Processing
– Right to data portability
– Right to withdraw consent
– Right to set directives on post-mortem data handling
– Right to object to Processing
– Right to opt-out of telemarketing
Requests can be made via email at [email protected]. The Company will respond within one month, extendable if necessary.
10. COOKIES
Cookies used on the Site are anonymous and do not collect personal data. They are stored for 13 months unless consent is renewed. Users can configure their browser settings to disable cookies.
11. SOCIAL MEDIA PLUGINS
The Site integrates Facebook, Twitter, and LinkedIn plugins. Users should review each platform’s privacy policies before interacting.
12. DATA SECURITY
The Company implements security measures to prevent data breaches, unauthorized access, and misuse.
13. POLICY CHANGES
The Company may update this Policy. Users will be informed of substantial changes and should regularly check for updates.