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PERSONAL DATA PROTECTION CHARTER

Last updated, 09/30/2018

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VALEURS ET PATRIMOINE (hereinafter "VALEURS ET PATRIMOINE") attaches great importance to the protection and respect for the privacy and personal data ("Personal Data") of the users of its website (hereinafter the "Site ").

VALEURS ET PATRIMOINE undertakes to implement appropriate measures for the protection, confidentiality and security of Personal Data in accordance with the regulations in force in France and in the European Union, in particular the General Data Protection Regulations. Personal EU 2016/679 of April 27, 2016 and the rules of national law adopted for its application.

Users are informed by this charter (the "Charter") of the practices and processing inherent in the collection and use of Personal Data by VALEURS ET PATRIMOINE as data controller.

Consequently, VALEURS ET PATRIMOINE invites users to carefully read this document in order to know and understand the processing operations relating to Personal Data.

It is specified that by browsing the Site, users accept this Charter as well as the general conditions of use.

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ARTICLE 1. PERSONAL DATA COLLECTED

Users are required to provide their Personal Data in digital format when using the Site.

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1.1 Principles applicable to the collection of Personal Data

In general, users can browse the Site without necessarily having to communicate Personal Data to VALEURS ET PATRIMOINE.

VALEURS ET PATRIMOINE only collects the Personal Data necessary for carrying out the processing operations it implements (“privacy by design”) and ensures a high level of protection (“privacy by default”). As such, the processing operations requiring data collection are as follows:

  • Respond to requests for information (contact forms for requests for visits, estimates, information and / or additional photos of a property);

  • Execute a mandate entrusted by the users;

  • Participate in surveys to improve the relationship and customer experience VALEURS ET PATRIMOINE;

  • Send newsletters, informative or commercial alert emails;

  • Apply for job vacancies.

In this case, the personal information collected from users is at least: (i) Last name (s), (ii) First name (s), (iii) E-mail address, (iv) Telephone number, (v) Address postal, (vi) Country.

This Personal Data is then kept for the time necessary to fulfill the users' request. In the absence of concrete implementation, they are deleted within the time limits recommended by the CNIL, i.e. after three years from their collection by the Site, subject to the possibilities and legal obligations in terms of archiving, retention obligations of certain data and / or anonymization.

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1.2 Browsing information for users of the Site

When using the Site or certain services linked to the Site, certain data is collected automatically such as: (i) IP address, (ii) reference of the navigation software used, (iii) navigation data (date, time, content viewed, search terms used, etc.), (iv) operating system references.

Among the technologies used to collect this information, VALEURS ET PATRIMOINE may use "php" sessions which store the data of each user using a unique session identifier. These php sessions keep data in memory only for user browsing time.

The data collected during browsing is thus deleted when the user's browser closes, or, where applicable, within a maximum period of thirteen months from their collection.

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ARTICLE 2. LEGAL BASIS FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA

Personal Data is processed by VALEURS ET PATRIMOINE in the cases authorized by the regulations in force and under the following conditions:

  • Obtaining free, specific, informed and unambiguous consent from users to the processing of their Personal Data (it is specified that for minors under 18 years of age, consent must be given by the legal representative);

  • Collection of Personal Data necessary for the execution of user requests;

  • Compliance with legal and / or regulatory obligations imposed on VALEURS ET PATRIMOINE (such as the fight against fraud and corruption);

  • Protection of the legitimate interests of VALEURS ET PATRIMOINE (such as the protection of the security of its computer network).

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ARTICLE 3. RECIPIENTS OF PERSONAL DATA COLLECTED

Only authorized staff of the group and of VALEURS ET PATRIMOINE service providers may have access to the Personal Data collected and be required to process them, without prejudice to their possible transmission to the bodies responsible for a control or inspection mission in accordance with the legislation. and / or the regulations in force or for the purposes of responding to a judicial or administrative decision.

Authorized personnel are subject to an obligation of discretion.

VALEURS ET PATRIMOINE undertakes not to sell the Personal Data collected to third parties.

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ARTICLE 4. TRANSFER OF PERSONAL DATA

Personal Data collected from users of the Site is kept exclusively in France and is not transferred outside the European Union.

In the event that affiliates or service providers located outside the European Union are used, VALEURS ET PATRIMOINE undertakes to verify that appropriate measures have been put in place so that the Personal Data of users benefit from a level of adequate protection.

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ARTICLE 5. DATA SECURITY

VALEURS ET PATRIMOINE collects and processes users' Personal Data with the utmost confidentiality and in compliance with applicable laws. Users are protected against unauthorized access, modification, disclosure or destruction of their Personal Data.

When the disclosure of Personal Data to third parties is necessary and authorized, VALEURS ET PATRIMOINE ensures that these third parties guarantee the Personal Data concerned the same level of protection as that offered to them by VALEURS ET PATRIMOINE, and requires contractual guarantees so that Personal Data are processed exclusively for the purposes accepted by users, with the required confidentiality and security (in particular through standard clauses of the European Commission, Internal Company Rules ("BCR") or the Privacy Shield data set up between the European Union and the United States of America).

VALEURS ET PATRIMOINE implements technical and organizational measures to ensure that the retention of Personal Data is secure for the period necessary for the exercise of the purposes pursued.

The attention of users is drawn to the fact that no transmission or storage technology is completely foolproof.

Also, in the event of a proven breach of Personal Data likely to create a high risk for the rights and freedoms of users, VALEURS ET PATRIMOINE will inform the competent supervisory authority of this breach in accordance with the procedures provided for by the applicable regulations.

It is up to users to exercise caution to prevent unauthorized access to their Personal Data and in particular to their computer and digital terminals (computer, smartphone, tablet in particular).

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ARTICLE 6. LINKS TO OTHER WEBSITES

The Site may occasionally contain links to the sites of partners or third-party companies which have their own data protection charter.

VALEURS ET PATRIMOINE has no control over the content of these sites and declines any responsibility for the use made of the information collected when users click on these links.

VALEURS ET PATRIMOINE therefore invites users to familiarize themselves with the data protection policies implemented by the publishers of these sites before sending them any personal information concerning them.

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ARTICLE 7. RIGHTS OF USERS

It is recalled that users have the following rights, subject to the limitations provided for by the legislation in force:

 

7.1. Right to information on the processing of Personal Data

VALEURS ET PATRIMOINE undertakes to use its best efforts to provide concise, transparent and accessible information on the conditions for processing users' Personal Data.

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7.2. Right of access to Personal Data

Each user can access Personal Data processed by VALEURS ET PATRIMOINE and has the right to receive a copy in electronic form (for any additional copy, VALEURS ET PATRIMOINE will be entitled to demand payment of fees based on administrative costs incurred).

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7.3. Right to erasure ("right to be forgotten") and rectification of Personal Data

Each user has the right to request the deletion and / or rectification of Personal Data concerning them when they are incorrect or obsolete.

It is specified that VALEURS ET PATRIMOINE may retain certain Personal Data when required by law or in the event of a legitimate reason.

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7.4. Right of opposition

Users can object at any time for legitimate reasons:

  • the use of their Personal Data for direct marketing purposes or

  • to the reuse of their Personal Data for processing other than those granted, except in the event of performance by VALEURS ET PATRIMOINE of one of its legal obligations.

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7.5. Right to limit the processing of Personal Data

Users have the right to request that the processing carried out on their Personal Data be limited to what is necessary. This right is applicable only:

  • if the user disputes the accuracy of his Personal Data;

  • if the user can establish that the processing of his Personal Data is unlawful and requests a limitation of their use rather than erasure;

  • if VALEURS ET PATRIMOINE no longer needs the user's Personal Data but these are still necessary for the user for the establishment, exercise or defense of legal claims;

  • if the user objects to the processing based on the legitimate interest of the controller, while verifying whether the legitimate reasons pursued by the controller prevail over those of the user.

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7.6. Right to complain to a supervisory authority

If users consider that the efforts made by VALEURS ET PATRIMOINE to preserve the confidentiality of Personal Data do not guarantee respect for their rights, they have the possibility of lodging a complaint with the competent supervisory authority (CNIL or any other authority mentioned on the list available from the European Commission).

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7.7. Right to the portability of Personal Data

Users have a right to the portability of their data, authorizing them to obtain their Personal Data from VALUES AND HERITAGE in a structured, commonly used and machine-readable format and to request that this Personal Data be transmitted to another controller.

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7.8. Right to decide the fate of Personal Data after death

Users also have the right to organize the fate of their Personal Data after their death by adopting general or specific directives that VALEURS ET PATRIMOINE undertakes to respect.

In the absence of such directives, VALEURS ET PATRIMOINE recognizes that heirs may exercise certain rights, in particular the right of access if it is necessary for the settlement of the estate of the deceased and the right of opposition.

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7.9. Conditions for exercising rights

To exercise their rights, users are invited to contact the VALEURS ET PATRIMOINE Personal Data Protection Officer in accordance with the procedures described in Article 10.

It is specified that to help them in the exercise of their rights, the CNIL makes available to them on its website models of letters (www.cnil.fr).

Before processing user request (s), VALEURS ET PATRIMOINE may verify their identity by asking them for proof of identity.

The Personal Data Protection Officer will respond to their request (s) as soon as possible and in any event one (1) month from proof of identity.

If necessary, this period may be extended by two (2) additional months given the complexity and number of requests, VALEURS ET PATRIMOINE then undertaking to inform users of the extension and the reasons for the postponement.

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ARTICLE 8. MODIFICATION OF THE PERSONAL DATA PROTECTION CHARTER

VALEURS ET PATRIMOINE reserves the right to make changes to this Personal Data Protection Charter at any time in order to comply with legislative and regulatory changes and / or improve its policy for processing and protecting Personal Data. .

In case of modification, a new version will be updated and put online with the date of "Last update".

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ARTICLE 9. APPLICABLE LAW AND COMPETENT COURT

This Charter is subject to French law, including the provisions applicable to the rules of private international law.

Failing a friendly agreement, JURISDICTION IS GIVEN TO THE COURTS OF THE JURISDICTION OF THE COURT OF APPEAL OF PARIS NOTWITHSTANDING PLURALITY OF DEFENDANTS AND / OR APPEAL IN GUARANTEE TO KNOW ANY DISPUTE RELATING TO THE USE OF THE SITE AND / OR THE VALIDITY, EXECUTION AND INTERPRETATION OF THESE T & Cs.

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ARTICLE 10. CONTACT

For any questions relating to this Policy for the purposes of rectification, supplementation or updating, users are invited to contact VALEURS ET PATRIMOINE:

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VALEURS ET PATRIMOINE

91, rue du Faubourg Saint-Honoré 75008 PARIS

09 70 44 77 79

contact@valeurs-et-patrimoine.com

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