DATA PROTECTION POLICY
Last updated: February 2023
WHY HAVE WE ADOPTED A DATA PROTECTION POLICY?
The company VENTOUX IMMOBILIER (or « the company ») attaches great importance to the protection of your data and does everything possible to protect it.
VENTOUX IMMOBILIER acts with full transparency and in compliance with the applicable regulations, in particular the 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 (hereinafter « GDPR ») and the French Law no. 78-17 of 6 January 1978 on information technology, files and civil liberties.
This Privacy Policy (hereinafter also « the Policy ») applies to the processing of personal data carried out by the company as part of its customer relationship. It is in no way responsible for the collection and the processing of data carried out by the customer with their own end customers.
In the case of « Cloud software » (or « SAAS ») solutions, the company is a processor within the meaning of the GDPR on behalf of the customer and must apply the measures necessary to maintain the security, confidentiality, integrity and availability of the data entrusted to it by the customer through the « Cloud software ».
We reserve the right to amend this Policy at any time, in particular to take account of any regulatory, legislative, case-law or service developments. As far as possible, we will inform you by any means of the substantial changes made to this Policy. We encourage you to consult this Policy regularly in order to keep up to date on the way we process your data.
WHO IS CONCERNED BY THE PROCESSING OF PERSONAL DATA?
The persons concerned (hereinafter also referred to as « you ») by the processing carried out by the company are all the persons whose personal data is processed as part of the contracting of the software solution.
The personal data of the « end customers » may be subject to automatic processing such as sending email but only after the customer has managed consent.
The personal data of end customers is only accessed with the customer's agreement and solely for maintenance purposes and by duly authorised staff.
INFORMATION ABOUT OUR PROCESSING OF YOUR DATA
WHO IS THE DATA CONTROLLER?
The data controller is VENTOUX IMMOBILIER, a company incorporated under French law, with a share capital of 0 euros, registered in the Trade and Companies Register under the number 531535045, VAT number and whose registered office is located at 18 AVENUE DE VERDUN 84340 MALAUCENE (article 4.7 GDPR).
APPOINTMENT OF AN EXTERNAL DATA PROTECTION OFFICER (HEREINAFTER « DPO »)
The DPO of VENTOUX IMMOBILIER is Mr Stéphane TABARDON, he can be contacted by email at the address contact@ventoux-immobilier.fr.
WHICH CATEGORIES OF DATA DO WE PROCESS AND WHY?
Below we detail the personal data that we process according to the purposes we pursue as well as how it is collected. We only process the following data when it is relevant and strictly necessary for the processing.
Operations related to the management of our relationships with our prospects
Legal bases
Art. 6.1.b): Performance of pre-contractual measures
Art. 6.1.f): Legitimate interest of the company
Purposes
- Provision, on request, of demonstrations of tools and solutions to our prospects.
- Management of the relationship with prospects showing an interest in the tools and solutions.
- Provision of advice, information or answers to questions of any kind sent by prospects.
Source and categories of data processed
From you, via our forms, by telephone or by email:- Personal identification data (surname, first name, telephone number, email address);
- Professional data (agency, company and business address);
- Any other information you may have provided to us.
Operations related to the management of our relationships with our customers
Legal bases
Art. 6.1.b): performance of the contract
Purposes
Customer service on request by telephone, email and any other means of communication following your request.Source and categories of data processed
From you, via our forms, by telephone or by email:- Personal identification data (surname, first name, telephone number, email address);
- Professional data (agency, company and business address);
- Any other information you may have provided to us.
Operations related to the management of our relationships with our (potential) partners
Legal bases
Art. 6.1.b): performance of pre-contractual or contractual measures
Purposes
- Management of the selection procedures for our potential partners.
- Management of our agreements with our partners.
- Carrying out joint projects.
Source and categories of data processed
From you, by email:- Personal identification data (email);
- Professional data (agency);
- Any other information you may have provided to us.
Management of the general mailbox
Legal bases
Art. 6.1.f): Legitimate interest
Purposes
- Management of the messages received.
Source and categories of data processed
From you:- Personal identification data (surname, first name, email);
- Any other data you may have provided to us.
Other operations related to the use of the software
Legal bases
Art. 6.1.a): consent
Art. 6.1.f): Legitimate interest of the company
Purposes
- Improvement of our services through the analysis of the use of the site. This analysis allows us to improve the appeal and usability of our services.
- Ensure the security and proper functioning of the site
Source and categories of data processed
From you:- Electronic identification data collected by our cookies (IP address, connection logs, location, connection dates and times and other metadata).
Operations related to requests to exercise rights, disputes and litigation
Legal bases
Art. 6.1.c): compliance with a legal obligation
Art. 6.1.f): Legitimate interest of the company
Purposes
- Management of the requests to exercise rights received by electronic or postal means.
Source and categories of data processed
From you or from a third party:- Personal identification data (surname, first name, email, copy of the identity card);
- Any other information relating to your request;
- In the context of purpose 24.: any other information arising from the dispute or litigation surrounding it.
We do not use decision-making techniques based on automated processing producing legal effects concerning the data subject or significantly affecting them.
HOW LONG DO WE KEEP YOUR DATA?
Your personal data is kept only for the time necessary to achieve the purpose for which we hold it. We ensure that the retention periods are relevant and comply with the legal deadlines.
Regarding the specific retention periods of the data, we have defined the following periods:
The time necessary for the processing for:
- The data or images collected in the context of a contract, which are kept for the period set out in the framework that binds us to you;
- The messages received in the general email inbox which are, in principle, kept for the time necessary to respond to them. They are then deleted.
The retention periods for your data collected through cookies are detailed in our #Cookie policy#.
At the end of the retention periods mentioned above, the personal data will be deleted or we will proceed with its anonymisation.
TO WHOM IS YOUR DATA DISCLOSED?
As part of the provision of our services, we may share your data. In all circumstances, we ensure a high level of protection of your data.
Recipients internal to the data controller
We give access to your personal data only to the internal persons whose function requires it. We regularly monitor this access and secure the information disclosed, as far as possible.
Recipients external to the data controller
Processors, joint controller and separate controller
In accordance with article 28 of the GDPR, the access of our processors to your data is based on signed contracts mentioning the obligations incumbent on them regarding the protection of the security and the confidentiality of the data.
As part of our activities, we may share your data with the following recipients:
- Providers of Cloud file storage and sharing services;
- Customer and prospect relationship management tool (CRM);
- Service providers handling part of the software maintenance
Third parties
Within the limits of their remit, various actors of justice and public authorities may have access to the personal data, such as courts and tribunals, administrative authorities, judicial officers, on legal request only.
SECURITY MEASURES PUT IN PLACE AROUND YOUR DATA
As the data controller, we take all useful precautions to preserve the security and confidentiality of your data. This includes the physical security of the buildings housing our systems and the security of the computer system to prevent external access to your data. Access to your data is limited to only the persons who need to know it.
WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
In application of articles 15 to 22 of the GDPR, any natural person using the service has the option of exercising the following rights:
HOW CAN YOU EXERCISE YOUR RIGHTS?
CONTACT US?
If you have a suggestion or a question about the way we process your data or regarding our Policy, do not hesitate to get in touch with us!
Our contact details are available on the legal notice page of the site.
DO YOU WISH TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY?
If you consider that your rights are not respected, you can also lodge a complaint with the French Data Protection Authority (hereinafter the « CNIL »), whose contact details are as follows:
- On the CNIL website via the online complaint service;
- By postal mail:
- CNIL
Service de Plaintes
3 Place de Fontenoy
TSA 8071
75334 Paris Cedex 07
- CNIL
You always also have the possibility of bringing legal proceedings.