1/ Object of the policy
BOAN IMMOBILIER attaches great importance to the respect of privacy. This is one of the reasons why we have adopted a specific policy on confidentiality and protection of personal data.
We are committed to protecting your privacy rights and ensuring that your personal data is protected.
This personal data management policy (the “Policy”) details the types of personal data we collect, how we process it and how we protect it in connection with the services we provide. This includes information collected offline or through our Customer Service Department and online through our websites, applications (including mobile applications) and third party platforms (“Sites”). It also reminds you of your rights and how to exercise them with us.
We maintain adequate technical and organizational measures to protect the personal data you provide to us from accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access to your personal data.
This External Privacy and Data Protection Policy is published by BOAN IMMOBILIER represented by Emmanuel BOAN as the data controller.
2/ Your rights and how to use them ?
The law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, as well as the general European regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and to the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) supplementing Law No. 78-17, grants you specific rights such as the right to obtain consent, the right to access, to object to personal data concerning you as well as to rectify or delete incomplete or inaccurate information concerning you.
You may also choose to give us instructions regarding the retention, deletion and disclosure of your personal data after your death.
If you believe that the way we have processed your personal data violates data protection laws, you may submit a complaint to the competent supervisory authorities (CNIL: https://www.cnil.fr/fr/plaintes), in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.
You can exercise each of these rights:
- By sending us an e-mail to the address : email@example.com
- By contacting us via the various online contact forms on our websites
- By contacting us by mail : Agence BOAN IMMOBILIER – 40, Rue Ambroise Martin – 74120 Megève
- By following the instructions on the CNIL website at this address : https://www.cnil.fr/agir
3/ Personal data
Personal data refers to information that can directly or indirectly identify you (“Personal Data”). Personal Information generally includes information such as your name, postal address, e-mail address, telephone number, and other information such as your IP address, product views, login information and browsing data.
We collect your personal information directly in a variety of ways, such as when you provide us with your information when you contact us or when you browse our site.
When you provide us with your personal data, we process it in accordance with this Policy. If you do not want us to process your personal data in this way, please do not provide us with any personal information.
We process your personal data in order to provide you with our services, as detailed below. In some cases, we will only process your personal data if you have expressly given us your consent. In other cases, we may rely on other legal grounds to process your personal data, such as the performance of your contract with us or a legitimate interest.
Where we process your personal data based on your consent, we will explicitly ask for your consent, and only for a particular purpose.
Please see the following section for details on the different types of personal data we may collect, the purposes involved and the legal basis for such processing.
4/ Processing of personal data
4.1/ Which data are collected ?
We collect and process in particular your name, first name, address, email address, password, telephone number, IP address, connection data and navigation data, preferences and interests, products consulted, complaints.
The compulsory or optional nature of the data is indicated at the time of collection by an asterisk. Some data are collected automatically because of your actions on the site.
4.2/ When are the data collected ?
We collect the information you provide to us when, among other things:
- You browse our sites and apps and view products featured on our site
- You contact us through the contact forms
- You contact us by email, phone or mail
- You download documentation from our sites
- You consult our advertisements
4.3/ Why is data collected ?
We use your personal data mainly for the following purposes :
- Management of the commercial relationship
We need information about you to process your requests and to manage the commercial relationship, including for prospecting activities.
- The personalization of our services and the messages we send you
The data concerning you allows us to improve and personalize the services we offer you and the communications we send you.
- Commercial prospecting by third parties
The data concerning you can be transmitted to commercial partners and in particular to marketing and advertising agencies. The prospecting by emails and sms by partners are not made without your consent. Concerning the postal or telephone prospecting by partners you can oppose it at any time by informing us.
- The security of our site
- Customer knowledge and statistics and performance of our site
We may use data to better understand our customers or for statistical purposes to analyze our site activity and improve our services. We measure audience, for example, the number of page views, the number of visits to the site, and the activity of visitors to the site and the frequency with which they return.
5/ Communications and informations
Your contact information and any personal information we have may be used to send you the following information:
If you are a customer and if you have not objected, you may receive information and offers from BOAN IMMOBILIER by electronic communication (email…). These newsletters allow us to keep you informed of news and advantages that you can benefit from on products similar to those you have already purchased or consulted. We measure the opening rate of our electronic mailings in order to adapt them to your needs.
If you are not a customer and have consented, you may receive the same type of communication.
- Contact by phone
If you have not objected, you may be contacted with offers and services related to those you have purchased or viewed.
6/ Legal basis and retention periods
The processing of your personal data is justified by different lawfulness (legal basis) depending on the use we make of the personal data. You will find below the legal bases and retention periods that we apply to our main processing operations.
6.1.1/ Legal basis for processing
Among the applicable legal bases:
- Legitimate interest: BOAN IMMOBILIER has a commercial interest in processing your data that is justified, balanced and does not infringe your privacy. With some exceptions, you can object to processing based on legitimate interest at any time by notifying us.
- Consent: you agree to the processing of your personal data by means of an express consent (check box, click ….). You can withdraw this consent at any time.
- Contract: the processing of personal data is necessary for the performance of the contract to which you have consented.
- Legal obligation: the processing of your personal data is made compulsory by a legal text.
6.1.2/ Data retention period
Most data (e.g., your customer account information and order history) is kept for as long as you are an “active” customer and for a period of 5 years after your last activity.
Your data is then archived with restricted access for an additional period of time for limited reasons authorized by law (payment, warranty, disputes …).
After this period, they are deleted.
|Purpose of the processing||Legal basis||Data retention in active base||Archiving||Useful observations|
|Customer management||Contrat||5 years from last activity||5 to 10 years|
|Electronic prospecting||Legitimate interest||3 years from last activity||You can object at any time by contacting us|
|Phone prospecting||Legitimate interest||3 years from last activity||You can object at any time by contacting us|
|Electronic prospecting by third parties||Consent||3 years from last activity||You can withdraw your consent at any time by contacting us|
|Managing the exercise of I&L rights||Legal obligation||1 year|
The data we collect may be passed on to technical service providers (subcontractors) that BOAN IMMOBILIER uses to perform its services for the purposes mentioned above, for example for marketing purposes.
We require these processors to comply with strict requirements in accordance with current data protection legislation, according to which they may only process your personal data on our behalf and must comply with high standards of IT security.
Please note that we never share your personal data with social networking platforms. If there are changes in the future and we need to share your personal data with a social networking platform, we will ask for your consent.
Please note that we may share your personal data with law enforcement or other agencies when we are legally required to do so or in the event of a subpoena, summons or court order requiring us to disclose your personal data.
You are informed that your data may be transferred for the purposes mentioned above to companies located in countries outside the European Union which have a lower level of data protection than the European Union. Prior to the transfer outside the European Union, BOAN IMMOBILIER will take all necessary measures and guarantees to secure such transfers.
8/ Data relating to minors
Our services are not intended for minors and consequently BOAN IMMOBILIER does not process data specifically concerning minors.
9/ Publicity and policy updates
This policy is effective May 25, 2018
This procedure may be updated at any time.