For transparency, Céline Sauvier has established this General Data Protection Policy so that anyone can, at any time, be aware of the commitments made and practices applied by Céline Sauvier regarding the personal data collected.

Céline Sauvier undertakes to process all collected data in compliance with the current regulations applicable to the processing of personal data, and in particular, the General Data Protection Regulation (Law No. 78-17 on information technology, files, and freedoms of January 6, 1978, as amended, and General Data Protection Regulation (GDPR) No. (EU) 2016/679 of April 27, 2016), these two texts being hereinafter referred to as the “Regulation”.

Definitions

“Personal Data” refers to information relating to an identified or identifiable natural person.

“Processing” refers to an operation or a set of organized operations performed on personal data (collection, structuring, storage, modification, communication…).

“Data Controller” refers to the natural or legal person who determines the purposes and means of the processing. In this case, the data controller for user data is Céline Sauvier.

“Data Subjects” refers to the individuals whose collected data is subject to processing.

“Personal Data Breach” refers to any incident resulting in the destruction, loss, alteration, or unauthorized disclosure of personal data.

Processing of Personal Data

The personal data of data subjects is collected and processed fairly and lawfully during their interactions with Céline Sauvier, including:

• Directly by a Céline Sauvier real estate agent
• During their browsing and/or entry of information in data collection forms and alerts found on:
  • The Céline Sauvier Patrimoine website – celinesauvier-patrimoine.com
  • Céline Sauvier’s partner websites
  • Céline Sauvier’s contracts and agreements
  • Via other potential sources such as online listing sites, real estate websites, business introducers, or so-called “public” information

Data Protection Officer (DPO)

Céline Sauvier can be reached at the following contact details:

Postal address: 883 chemin du Rigoulier, 83340 Le Thoronet
Email: contact@celinesauvier-patrimoine.com

Data Collected

In the course of its activities, Céline Sauvier may collect personal data belonging to the following categories:

• Data enabling prospecting, customer loyalty, studies, surveys, and improvement of the online experience on the Céline Sauvier website, including:
  • Traffic and browsing history (cookies) including information related to action traceability, location data (e.g., IP address), device data, and tracking data for actions related to emails that Céline Sauvier may send to data subjects (opens, clicks,…). The Céline Sauvier Patrimoine website allows data subjects to consult the cookie policy and save their preferences.
  • Data related to data subjects’ interactions with Céline Sauvier, including contact requests, estimates, inquiries, or documentation, and any exchanged correspondence
  • Data enabling marketing or telemarketing campaigns, such as email or phone number
  • Data related to satisfaction surveys
• Data enabling the exercise of real estate transaction activities (monitoring mandates and sales), including:
  • Identification data such as title, first and last name, KBis (if Company), contact details (phone number, email, postal address), date and place of birth, photocopy of identity card when necessary
  • Data related to the sale, purchase, or rental project
  • Data related to the characteristics of the property subject to the sale, purchase, or rental project, such as the number of rooms, surface area, location
  • Data related to the family, personal, or even professional situation of the individuals involved in the project
  • Data enabling personalized and qualitative client follow-up, such as visit reports
  • In the context of a sales mandate, data related to the mandate and legally required supporting documents (such as the DPE, title deed, copy of property tax) as well as photos and/or videos of the property concerned
  • In the context of a search mandate, data related to the mandate and proof of the buyer(s)’ solvency
  • In the context of a preliminary sales agreement, legally required supporting documents (such as the site plan, invoices, and various taxes)
  • Client testimonials on service quality and satisfaction surveys
• Data enabling the management of business introducers (also referred to as “referral partners”) or sponsors, including:
  • Identification data such as first and last name, information related to the Company or Association where applicable, contact details
  • Data related to sale or purchase projects provided by the individuals concerned through their personal action and after obtaining consent from their seller or buyer contacts
  • Data enabling their administrative, accounting & financial monitoring
  • Data enabling community engagement, such as email or phone number, contact preferences

The mandatory nature of personal data collection is indicated on the collection forms by an asterisk next to the relevant field(s). In the absence of an asterisk, the requested information is optional.
Failure to provide mandatory information may result in the request related to this data collection (e.g., inquiry, application) not being processed or its processing being delayed.

Purposes of Collection

Céline Sauvier undertakes that the processing implemented serves an explicit, legitimate, and determined purpose.
Depending on the case, Céline Sauvier processes the data collected via the aforementioned collection points, in whole or in part, for the following main purposes:

Execution of prospecting, customer loyalty, study, survey, and online experience improvement actions on the Céline Sauvier Patrimoine website:
• Management and processing of requests from website users, and more generally, Céline Sauvier’s contacts
  • Access to and benefit from online features and services, such as free valuation
  • Management and execution of marketing, tele-prospecting, and personalized communication operations
  • Analysis of website usage and user browsing behavior for optimization purposes
  • Conducting studies, analyses, reporting, and statistics
• Exercise of real estate transaction activities (monitoring mandates and sales):
  • Management and execution of prospecting and commercial solicitation operations
  • Execution of the contract between Céline Sauvier and its end clients (sellers, buyers)
  • Compliance with legal and regulatory obligations resulting, in particular, from the activity of a real estate agent
  • Solicitation of service providers or partners in connection with end clients’ projects
  • Monitoring of service quality, reputation, and client satisfaction with Céline Sauvier Patrimoine

Data Recipients

Clients’ personal data is intended for Céline Sauvier, as well as, depending on the case, its partners or service providers in connection with end clients’ projects, including real estate listing sites, real estate photography providers, brokerage professionals, concierge services, printers, and communication providers.

Furthermore, the data may be communicated to any authority legally authorized to access it, particularly in the event of a request from judicial, police, or administrative authorities.

It is specified that the recipients mentioned above do not receive all of the data subjects’ data, but only that which is necessary for the purpose requiring such communication.

Data Retention

Generally, data is retained for the period necessary to achieve the aforementioned purposes, subject to obligations to retain certain data in accordance with legal or regulatory provisions (e.g., accounting and legal retention periods), dispute resolution, and to assert, exercise, and/or defend Céline Sauvier’s rights.

For example, it has been set at 14 months for connection, browsing, and traffic data (cookies); a maximum of 5 years for commercial prospecting; 10 years for mandate contracts and associated supporting documents, due to real estate regulations; a maximum of 10 years for applications for the position of real estate agent.

It is specified that all of this data may, however, be retained longer than the aforementioned periods after obtaining the data subject’s consent.

The aforementioned retention periods have been defined to allow Céline Sauvier to process mandate contracts, various requests (inquiry, contact, online valuation…), and/or to carry out its commercial, communication, marketing, and recruitment operations, while respecting the principle of proportionality according to which personal data should not be retained longer than necessary for the purpose for which it was collected.

User Rights

In accordance with the aforementioned legal and regulatory provisions, data subjects have a right to inquire about, access, and port their personal data.

They also have a right to object to their data being used for prospecting purposes, particularly commercial prospecting. A link is also provided at the bottom of mailings to allow data subjects to easily unsubscribe.

They also benefit from a right to rectification and erasure of their data processing to a certain extent.

They have the right to define general and/or specific directives regarding the fate of their personal data and how they wish their rights to be exercised after their death. In this regard, should Céline Sauvier be informed of a death, their data will be deleted, unless retention is necessary for a determined period due to legal and regulatory obligations and/or Céline Sauvier’s statutory limitation periods, and after, if applicable, having been communicated to a third party potentially designated by them.

All requests for the exercise of these rights, as well as all requests for information concerning the protection of personal data, must be made to the Data Protection Officer (DPO) at the following contact details with the mention “GDPR” in the subject line:

Postal address: 883 chemin du Rigoulier, 83340 Le Thoronet
Email: contact@celinesauvier-patrimoine.com

A response will be provided within a maximum period of one month from the date of receipt of the request, in accordance with current regulations. For confidentiality and personal data protection purposes, Céline Sauvier must verify the identity of the data subjects before responding to such requests. Therefore, any request for the exercise of these rights must be accompanied by a copy of a signed identity document.

Data subjects always have the possibility to lodge a complaint with a national authority responsible for personal data protection (in France, this is the Commission Nationale de l’Informatique et des Libertés or “CNIL”) if they believe that the processing of their data is not carried out in accordance with applicable provisions.
Security

Concerned with ensuring the security of personal data, Céline Sauvier takes all useful and appropriate precautions and measures, whether physical, logical, technical, functional, administrative, or organizational, considering the state of knowledge, implementation costs, and the nature, scope, context, and purposes of the processing, as well as the risks, whose degree of probability and severity varies, for the rights and freedoms of natural persons, to preserve the security and confidentiality of data and ensure a level of security adapted to the risk, and in particular to prevent them from being distorted, damaged, or accessed by unauthorized third parties.

In the event of difficulties, Céline Sauvier will make its best efforts to mitigate the risks and will take all appropriate measures, in accordance with their legal and regulatory obligations (corrective actions, informing the national authority responsible for personal data protection and, where applicable, the data subjects, …).

In the event of subcontracting part or all of a personal data processing operation, Céline Sauvier contractually imposes security guarantees on its subcontractors, particularly regarding the confidentiality of the personal data to which they may have access (appropriate technical and organizational measures for the protection of this data).

It is specified that Céline Sauvier may connect data subjects with real estate agencies, companies, artisans, or third-party websites external to Céline Sauvier. In this regard, their personal data protection policies may differ from those of Céline Sauvier. Therefore, it is recommended, in all cases, to review their personal data protection policy. In any event, Céline Sauvier cannot be held liable if the data processing implemented by these third parties contravenes applicable legal and regulatory provisions.