Politique de confidentialité et de protection des données personnelles

last updated: 1 December 2022_

_In the event of any apparent discrepancy between the English and French versions, the French version shall prevail. _

Pariscabane is committed to respecting your privacy and protecting your personal data is a priority.

This policy demonstrates our commitment to protecting all your personal information, acting in accordance with your rights and with data protection regulations.

To ensure that your personal data is used responsibly, appropriate technical and organisational measures are implemented during its collection and use.

pariscabane therefore undertakes to comply with all its obligations arising from the regulations applicable to the processing of personal data, and in particular :

the French Data Protection Act no. 78-17 of 6 January 1978 as amended;
the European Data Protection Regulation (RGPD) n° 2016/679 of 27/04/2016 applicable since 25/05/2018;
the opinions and recommendations of the European Data Protection Committee.

Your personal data is first and foremost protected by the professional secrecy to which we are bound.

1. Definitions

Personal data" or "personal data"_: means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;

processing of personal data"_: means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

controller"_: means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing;

processor"_: means the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

consent"_: means any freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject signifies his or her agreement, either by a declaration or by a clearly defined act, to personal data relating to him or her being processed;

2. What personal data do we collect?

The personal data that we collect and/or hold about you is strictly necessary for our business to enable us to offer you suitable products and/or services. We apply the principle of minimisation, which requires us to collect only the minimum amount of personal data necessary for the intended purpose.

We may collect data :

your identity
relating to your contact details
identification and authentication details
relating to your family situation
relating to your professional situation
banking, financial and property information,
relating to your property search or purchase
relating to our browsing on our sites.

Data may be collected directly from you or from external sources such as, but not limited to

property advertising websites
websites, search engines
social networks concerning data that you have made public
publications or databases (Journal Officiel, RCS, etc.)
anti-fraud organisations
sponsorship
use of prospect files.

Finally, we may have access to the personal data of non-customers such as, but not limited to

prospective customers
guarantors and/or sureties
legal representatives of legal entities or individuals
agents
persons carrying out transactions with our customers or on their behalf (notaries, lawyers, chartered accountants, etc.).

3. For what purposes is your personal data collected?

pariscabane processes personal data for specific, explicit and legitimate purposes.

In particular, your data may be processed in order to :

provide you with suitable products and services
send you information about these products and services, in particular by e-mail, post, text message or telephone call. You may inform us at any time that you no longer wish to receive commercial communications. If you ask us to stop receiving communications or if you wish to receive them again, we will keep an electronic record of these requests as proof.
manage the commercial relationship
manage and perform our services in respect of the products and services you have subscribed to
collect guarantees
collect our debts
carry out canvassing, sales promotion, profiling and segmentation, and statistical studies
to comply with legal and regulatory obligations, particularly in terms of knowing our customers, combating money laundering and the financing of terrorism, risk assessment and fraud prevention, combating tax fraud, etc.
to record and store certain conversations and communications that we may have with you, regardless of the medium, in particular for the purposes of improving telephone reception, training and complying with legal and regulatory obligations.

4. On what legal grounds do we collect your personal data?

We ensure that each of our processing operations is carried out in compliance with its legal basis, whether this involves :

the performance of a contract concluded or to be concluded with you or the provision of pre-contractual information
meeting our legal and regulatory obligations
to meet our legitimate interests
obtaining your consent for specific processing.

5. With whom may we share your data?

**We never sell your personal data to third parties. However, it may be communicated to authorised and specified recipients, within the limits necessary to achieve the purposes described above.

Such recipients may include :

our establishment as data controller
our authorised staff and sales agents with whom we have a contractual relationship
guarantors
brokers and insurers
property diagnosticians and trustees
duly authorised judicial and/or administrative authorities
regulated professions (notaries, lawyers, bailiffs, accountants)
service providers and subcontractors performing services on our behalf, such as, but not limited to, the following
Cloud storage service providers, in particular to store documents relating to our contractual relationship.
Payment service providers, which we use to process your payments.
Financial service providers, to whom we entrust the recovery of unpaid debts.
IT service providers, which we use to record information relating to the management of our relations with our customers or prospects, or to send you invoices or communications from us, or to enable the electronic signature of documents or to collect your feedback online following your response to our satisfaction surveys.
Professional service providers such as marketing agencies, advertising partners and website hosts who help us run our business.
Social networking platforms

Furthermore, in the event that all or part of the assets of one of the pariscabane agencies are acquired by a third party, the list of prospects or customers may be included in the assets transferred.

6. How is your personal data stored?

For the duration of the relationship and for as long as you use our products and services, your data is kept securely in France (as a priority) or in the European Economic Area, which has laws equivalent to those of France concerning your information.

It may be kept beyond the end of the relationship, in particular to comply with applicable regulations, to defend our interests or to assert our rights. Your data may be archived for a longer period for the management of complaints and/or disputes, to meet our regulatory obligations (in particular with regard to statutes of limitation), or to satisfy the request of duly authorised judicial or administrative authorities.

Data relating to customers may be kept for up to ten (10) years after the end of the relationship or transaction, depending on the applicable regulations. In the case of prospective customers, data may be kept for a period of 3 (three) months from the date of collection or from the date of our last contact. We do not keep your personal data for longer than is necessary, but only for as long as is necessary to fulfil the purposes for which it is collected and processed. When we no longer need it, we will destroy it securely or make it anonymous. Please note that we retain your personal data until the longest retention or archiving period has elapsed if it has been collected for more than one purpose.

7. Transfer of data outside the European Union

Your personal data may be transferred, in limited cases and for strictly defined purposes, to a country outside the European Union. We will ensure that your personal data is protected by an adequacy decision issued by the European Commission, which recognises that the recipient country has an adequate level of protection. If the level of protection has not been recognised as equivalent by the European Commission, we will rely on the implementation of appropriate safeguards such as standard contractual clauses approved by the European Commission. In all cases, we will require that your information is processed and protected under conditions similar to our own.

8. How do we ensure the security of your data?

We implement technical and organisational measures to protect your data, in particular by putting in place appropriate physical, logical and organisational security, encryption and anonymisation measures to guarantee the confidentiality and integrity of your data and to prevent any unauthorised access (accidental or unlawful), disclosure or alteration, loss or destruction of your personal data. In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorised access resulting in the risks identified above, we undertake to :

Notify you of the incident as soon as possible;
Examine the causes of the incident and inform you;
To take the necessary measures within reasonable limits in order to reduce the negative effects and prejudices that may result from the said incident. Under no circumstances may the three commitments defined above be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

9. What rights do I have?

You have rights concerning the collection and processing of your personal data, which may be exercised under the conditions laid down by the regulations in force. We would like to point out that the exercise of some of these rights may, on a case-by-case basis, make it impossible for pariscabane to provide the service.

Your rights are as follows:

the right to be informed in a simple, comprehensible and accessible manner about the processing of your data
the right to access your data
the right to rectify any inaccurate or incomplete data and have it amended
the right to erasure of your data, unless we have legal or legitimate grounds to retain it
the right to object to processing where this is based on the legitimate interests of the controller
the right to object, at any time and free of charge, without having to justify your request, to your data being used for commercial prospecting purposes
the right to limit the processing of your personal data
the right to the portability of your data where processing is based on consent or the performance of contracts and where processing is carried out using automated processes
the right to withdraw your consent at any time where the processing of your personal data is based on your consent
the right to give instructions concerning the retention, erasure and disclosure of your personal data, applicable after your death
the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) 3 Place de Fontenoy TSA 80715 75334 PARISCEDEX 07 or at www.cnil.fr/fr/plaintes.

If regulatory provisions oblige us to retain your data or if we have a legitimate interest in doing so, we may be justified in continuing to process your personal data despite the exercise of your right to erase, limit or object to the processing of your data.

In the event of a dispute or query regarding the processing of personal data or to exercise any of the rights listed above, you can contact us at the following address: pariscabane - DPO 75, rue Oberkampf 75011 Paris 01 70 22 47 85 rgpd@pariscabane.fr

To exercise your rights, please enclose a copy of your identity document, signed and certified by yourself. If you have a complaint or concern about the way in which we use your personal data, please contact us first and we will try to resolve the problem as soon as possible.

10. Cookies

The word "cookie" refers to a piece of text, pixels, invisible GIF files, log files, web beacons or any other tracking and tracing file and any similar technology that is stored on your device. Depending on the settings you have selected, your browser adds the cookie to your device in the form of a small file.

**Good news! We do not use Google Analytics and its cookies collecting personal data to track your activity on our site **.

When our site includes links to other websites, these websites apply their own confidentiality and cookie management rules and policies. We invite you to read these policies as pariscabane cannot be held responsible for their practices in this respect.

11. Updating of the personal data protection policy

This personal data protection policy was updated on 1 July 2022. We reserve the right to modify it at any time, in particular to take account of changes in legislation, regulations or our activity.