DATA PROTECTION POLICY
In accordance with Law No. 78-17 of 6 January 1978, as amended, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, the "GDPR" (hereinafter collectively referred to as the "regulations"), SAS CIMALPES acts as the data controller (hereinafter referred to as "Cimalpes" or "we"), and attaches great importance to the protection and respect of your privacy.
This data protection policy (hereinafter referred to as the "Policy") aims to inform you about our practices regarding the collection, use, and sharing of information that you may provide to us through our website as well as our agencies.
The Policy aims to inform you about the categories of personal data that we may collect or hold about you, how we use them, with whom we share them, how we protect them, and the rights you have over your personal data in accordance with applicable regulations.
2. PURPOSE OF DATA COLLECTION AND USE/WHY CIMALPES PROCESSES YOUR DATA
Cimalpes collects and processes personal data for the following purposes:
- Management of relationships with clients and prospects: Information about you allows us to get to know you, establish a personalised relationship, follow up on your requests, and provide the expected services.
- Management of real estate transactions: The information you provide allows us to establish a mandate, fulfil our obligations as an agent, and the obligations associated with such a real estate transaction.
- Management and follow-up of requests for information about our services: You have the opportunity to contact us through various means to make inquiries about the services offered. We collect and use some of your data to manage and respond to these requests.
- Management of rental and property valuations: We offer to estimate your property’s potential rental income , should you wish to rent it out, or to estimate its resale value, should you wish to sell it.
- Improvement of the quality of our services: We use your personal data to establish and develop our services, including for the purpose of customising commercial offers proposed by Cimalpes.
- Human resources management: You may choose to submit your application using our website.
- Compliance with legal and regulatory obligations: Your data may be collected to meet legal obligations, such as combating money laundering and the financing of terrorism.
- Understanding your behaviour, preferences, and thus meeting your needs and expectations: Based on your consent, we use data related to how you use our website and our social networks, including:
- Understanding your behaviour and preferences, such as how you search for and find our services.
- Understanding the best ways to organise and present our offers and services on our websites and in our agencies.
- Behaviour analysis and profile qualification: Based on your browsing on our website, as well as on our social networks, and your interactions with our advertisements, including sponsored links on partner sites, we establish a scoring and qualify your profile. This analysis allows us to distinguish casual visitors from those showing a more pronounced interest in our services, in order to better tailor our communications and offers.
In the context of these purposes, Cimalpes only processes relevant and necessary data for the intended objective.
3. WHAT DATA IS PROCESSED ?
By using our website or during your visits to our agency, you may provide us with information, some of which is capable of identifying you and therefore constitutes personal data within the meaning of the GDPR (hereinafter referred to as "data").
This is particularly the case when you wish to:
- Contact us for any inquiry, especially to learn more about our activities.
- Subscribe to one of our services.
- Receive communications.
- Register for online services (e.g., creating a client account (owner), managing favourites and alerts).
- Receive our newsletters.
- Participate in our contests and other promotional activities.
- Have a property estimated.
- Entrust the management of a property.
- Contact one of our agencies.
- Share a real property listing with a third party.
- Provide feedback on our services.
- Work at Cimalpes.
The personal data collected by Cimalpes is grouped into the following categories :
|Categories of Data
|Main Data Processed
|First name, last name, gender, place and date of birth, nationality
Postal or email address, landline or mobile phone numbers
Ocupation, sector of activity, CV, education, professional training, distinctions, etc.
Legal protection measures, power of attorney, signature
Client identification (number), username
|Connection and browsing data
Date, time of connection and/or browsing, browser type, browser language, IP address
|Economic and financial data
Financial identification, economic, fiscal and accounting data, payment history
|Customer expectations data
Data on customer expectations regarding resquested services (examples : property or destination search criteria)
|Property ownership data
Address, property description, mandatory diagnostics, property and rental values
|Profile, scores, and customer segmentation
Marketing score and segmentation, customer satisfaction indicator
During the data collection process, you will be informed whether certain data must be provided or if it is optional. Data identified by an asterisk (*) within the collection form is mandatory. Failure to provide this data may result in the restriction of precessing your request.
4. USE OF DATA
Cimalpes uses personal data only for the purposes for which it was collected. We are committed to not selling, exchanging, or transferring data to third parties without the explicit consent of the individuals concerned, except where required by law.
5. HOW LONG DO WE RETAIN YOUR DATA ?
Cimalpes will retain personal data for as long as necessary to achieve the purposes for which it was collected, in accordance with legal retention periods and industry best practices in the real estate sector.
Your data will not be retained beyond the strictly necessary duration for the purposes stated in the Policy, in accordance with applicable regulations.
In this regard:
- Data used to respond to your request will be retained for the time necessary for processing your request, then archived in accordance with applicable legal limitation periods.
- Data used to provide you with the requested service will be retained for the duration of the contractual relationship, then archived in accordance with limitation periods, which is five (5) years.
- Data used for commercial prospecting purposes will be retained for three (3) years from the last contact from the prospect or client.
- Data collected for verification purposes in the context of combating money laundering and terrorism financing will be retained for ten (10) years from the end of each real estate transaction.
- Data used for recruitment purposes will be retained for two (2) years from the last contact with the unsuccessful candidate, unless consent is given for longer retention.
- Technical data for website management and to better understand your behaviour and preferences will be retained for thirteen (13) months from the consent of the internet user.
Your data will be deleted when the retention periods expire. However, your data may be archived beyond the specified periods for the purpose of research, detection, and prosecution of criminal offenses, solely to enable, if necessary, the provision of your data to the judicial authority.
Archiving implies that your data will no longer be accessible online but will be extracted and stored on a separate and secure medium.
6. IS YOUR DATA TRANSFERRED, HOW, AND WHERE ?
Secure hosting within the European Union: We want to inform you that your personal data is primarily hosted securely in data centres located within the territory of the European Union. This location ensures a level of protection and security that complies with the regulatory requirements of the Union.
In certain circumstances, Cimalpes may transfer personal data outside the European Economic Area (EEA). In such cases, we will ensure that transfers are made in accordance with legal requirements by implementing appropriate safeguards to protect the confidentiality and security of personal data.
Use of Third-Party Communication Services and Transfers Outside the EU: Furthermore, if you choose to use third-party communication services, such as the WhatsApp app to communicate with us, it is important to note that these communications may be subject to the data processing practices of the third-party company providing the service. In the case of WhatsApp, a subsidiary of the American company Meta Platforms, Inc., this implies that the content of your exchanges may be collected and processed by Meta, and may be subject to data transfers to the United States. By decision of 10 July, the European Commission finds that the United States ensures a level of protection of personal data equivalent to that of the European Union. Data transfers from the EU to certain US entities can now take place freely, without specific oversight.
7. WHO ARE THE RECIPIENTS OF THE DATA ?
The data collected is intended for the commercial, technical, and administrative teams of Cimalpes and its service providers.
In the context of legal procedures, the processed data may also be transmitted to the competent authorities.
8. DATA SECURITY
Cimalpes implements appropriate technical and organisational measures to ensure the security and confidentiality of personal data, including protection against unauthorised access, alteration, disclosure, or destruction of data.
9. CONFIDENTIALITY AND EMPLOYEE TRAINING
Cimalpes is committed to ensuring the confidentiality of personal data by ensuring that all employees and partners adhere to the principles and obligations outlined in this Data Protection Policy.
To ensure compliance and raise awareness of data protection, Cimalpes provides regular training to its employees and partners on current regulations and best practices in data protection. Employees and partners with access to personal data are required to sign a confidentiality agreement committing them to respect the confidentiality and security of data.
10. RESTRICTED ACCESS TO DATA
Access to personal data is limited to employees and partners of Cimalpes who need to access it to perform their professional duties. Cimalpes implements access controls to ensure that only authorized individuals can access personal data.
Subject to your consent, whenever you visit our website and use our online services, we collect data and information related to your browsing. This data and information is stored in "Cookie" files installed on your device.
This data enable us to improve the user experience, analyse website usage, and personalise content and advertisements.
12. LINKS TO THIRD-PARTY WEBSITES
Our website may contain links to third-party websites. Cimalpes is not responsible for the privacy practices and data protection of these third-party sites. Users are encouraged to review the privacy policies of third-party sites before providing personal data.
13. RIGHTS OF THE INDIVIDUALS CONCERNED
Individuals whose personal data is processed by Cimalpes have various rights under applicable regulations, including the right to access, rectify, erase, restrict processing, data portability, and object to processing.
To exercise these rights, individuals concerned can contact our Data Protection Officer (DPO) at the following email address: firstname.lastname@example.org
If you still believe, after contacting us, that your rights are not being respected, you have the right to lodge a complaint with a competent European supervisory authority: the Commission Nationale de l'Informatique et des Libertés (CNIL) for France.
15. MODIFICATIONS TO THE DATA PROTECTION POLICY
Cimalpes reserves the right to modify this Data Protection Policy at any time. Any changes will be posted on our website and, if applicable, communicated to the individuals concerned.
For any questions regarding this Data Protection Policy, please contact our Data Protection Officer (DPO) at the following email address: email@example.com
By providing personal data to Cimalpes, individuals consent to their data being processed in accordance with this Data Protection Policy. Where applicable, explicit consent will be requested for specific processing activities, such as receiving marketing communications.
Last updated: 02/13/2024
In the event of any discrepancies between the French version and any other translated version of this policy, the French version shall prevail.
1. WHAT IS A COOKIE ?
A cookie is a text file added to an internet user's browser during their visit to websites. They ensure proper functioning, improve navigation, and provide certain information to the owners of these sites. This information allows Cimalpes to improve the performance of the website and offer the user content tailored to their interests. However, the information collected through cookies does not allow for the identification of the user by name, nor for sending them advertising messages by email or postal mail.
2. WHAT TYPES OF COOKIES ARE USED ON OUR WEBSITE ?
There are two different types of cookie issuers:
- First-party cookies are those deposited by the website visited by the internet user, specifically on the domain of the website.
Necessary: They contribute to making the website usable by enabling basic functions such as browsing and access to secure areas of the website. The latter cannot function properly without these cookies. Cimalpes does not share any of this data with third parties, does not reuse it for other purposes, does not combine it with other processing including customer files, and does not retain it in any way for a period longer than 13 months. The providers are:
- cimalpes.com / Opinionsystem
Statistics: They help the owners of the website, through the collection and communication of information anonymously, to understand how visitors interact with the website. Several tools allow for measuring this:
Marketing: They allow tracking of visitors across the website. The purpose is to display relevant and interesting advertisements for the individual user and therefore more valuable for third-party publishers and advertisers. The providers are:
- Meta Platforms, Inc.
Social media: These cookies allow the user to interact from our website on social media, notably through share buttons redirecting to the following applications: Instagram, Facebook, LinkedIn, YouTube, or Pinterest.
In accordance with the recommendations of the Commission Nationale de l’Informatique et des libertés (CNIL), certain cookies are exempt from the requirement for prior consent to the extent that they are strictly necessary for the operation of the website or have the exclusive purpose of allowing or facilitating electronic communication. These are necessary cookies because they are essential for the operation of the website.
However, cookies issued by third parties require prior consent. These include statistical, marketing, and social media cookies.
Website users therefore have the option to:
- Allow only necessary cookies
- Allow all cookies
- Customize by choosing the type(s) of cookies they wish to allow to be used
You have various means to manage cookies:
- Firstly, during your first connection to the website through the cookie banner that appears.
- Then, during your subsequent connections to the website, you can access the cookie manager at the bottom of the page, accessible at any time.
- Alternatively, by configuring your internet browser:
- For Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
- For Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies
- For Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- You can also find additional information on the website of the Commission Nationale de l’Informatique et des Libertés (CNIL): https://www.cnil.fr/.
If you have any questions, you can contact the Data Protection Officer (DPO) at the following email address: firstname.lastname@example.org