DATA PROTECTION POLICY AND MANAGEMENT OF THE USE OF COOKIES

1. General provisions

The following provisions concern all processing of personal data carried out by the EVORIEL group including all its subsidiaries unless otherwise stated in the specific provisions, namely

• LAMY,
• LACROIX IMMOBILIER,
• BELIER ASSURANCES,
• IMMOBILIER GESTION CONSULTANT,
• BAUDRY IMMOBILIERE,
• RICHARDIERE,
• ORALIA PARTENAIRES and its branches:
  • A AXEL IMMOBILIER
  • ADMINISTRATION D’IMMEUBLES P. ROSIER ET A. MODICA
  • ADMINISTRATION D’IMMEUBLES PITANCE
  • AGENCE IMMOBILIERE MOZART
  • CABINET CAZALIERES
  • CABINET DESPORT
  • CABINET GARRAUD MAILLET
  • CABINET LECASBLE ET MAUGEE
  • CABINET LESCALLIER
  • CABINET MAURY SCHWOB (GROUPE IMMOBILIER JOUFFROY, PGI PATRMOINE GESTION IMMOBILIER)
  • CABINET NICOLAS & CIE
  • CABINET PIERRE PLISSON
  • FAURE IMMOBILIER
  • FAY & CIE
  • GERANCE LITTRE
  • GIGNOUX LEMAIRE
  • HENRAT ET GARIN
  • HILDE
  • JEAN COUTURIER
  • ILE VERTE IMMOBILIER
  • LAPIERRE DES DEUX RIVES
  • LEPINAY MALET
  • ORALIA ASSURANCES
  • PIERRE ET GESTION
  • R.L. MEILLANT & F. BOURDELEAU
  • REGIE BAGNERES ET LEPINE
  • REGIE DE L’OPERA
  • REGIE GELAS ET CHOMIENNE (REGIE GINON, IMI GERANCE IMMOBILIER)
  • REGIE IMMOBILIERE PONDEVAUX
  • IGS
  • CAPRIM
  • SICOV
  • SOCIETE DE GESTION DES LOGEMENTS MODERNES
  • SOCIETE GRIFFATON ET MONTREUIL
  • SOGIMAT
  • SULLY GESTION

 

The purpose of this document is to inform you of how the EVORIEL group uses and protects personal data, as well as the reasons why it processes this data. It applies uniformly to all products and services of the EVORIEL group, it being specified that additional information may be communicated, if justified, because it concerns a particular product or service.

 

2. Legal framework

All personal data processing implemented as part of the distribution of products and services offered by the EVORIEL group complies with the applicable regulations on the protection of personal data.
In carrying out its activities, the EVORIEL group is required to process personal data. This data is that of its employees as well as that of third parties, customers, partners, suppliers and any other organization in relation with the EVORIEL group. This processing is carried out in accordance with the legislation in force and in particular the provisions of:

• Law No. 78-17 of 6 January 1978, as amended, relating to information technology, files and freedoms,
• The Charter of Fundamental Rights of the European Union, in particular Chapter 2,
• EU Convention 108 on the protection of individuals with regard to automated processing of personal data and its additional protocol,
• General Data Protection Regulation (Regulation EU2016/679 of 27 April 2016) on the protection of individuals with regard to the processing of personal data and on the free movement of such data, referred to as “GDPR”

 

3. Compliance Commitment

The EVORIEL group is committed to ensuring a high level of protection of the personal data of any person whose data it processes. The EVORIEL group is committed in particular to respecting the following principles:

• personal data are processed lawfully, fairly and transparently;
• personal data are collected for specific, explicit and legitimate purposes, and are not further processed in a manner incompatible with the initial purposes;
• personal data are stored adequately, relevantly and are limited to what is necessary in relation to the purposes for which they are processed
• personal data are accurate, kept up to date and all reasonable measures are taken to ensure that inaccurate data, in relation to the purposes for which they are processed, are deleted or rectified without delay. The EVORIEL Group implements appropriate technical and organizational measures in order to:
• respond as quickly as possible and in the best conditions to the persons concerned who wish to exercise their rights;
• guarantee a level of security adapted to the risks inherent in its processing operations;
• meet regulatory requirements and protect the rights of data subjects;
• offer its employees, customers and partners products and services that respect privacy from the design stage and by default. The EVORIEL group contractually imposes the same level of commitment and protection of personal data on its subcontractors (service providers, suppliers, etc.).

Finally, the EVORIEL group undertakes to respect any other principle imposed with regard to the regulations applicable to the protection of personal data, and more specifically concerning the rights granted to the persons concerned, the retention periods of personal data as well as the obligations relating to cross-border transfers of personal data.

 

4. Compliance and data governance

Data governance within the EVORIEL group is organized around the following operational departments:

• General Management (DG)
• DPO Service and Operational Legal Department (DJO)
• IT Department – including systems security

 

5. Definitions

For the purposes hereof, the terms in capital letters have the following meaning:
“Subsidiaries“: means the companies belonging to the EVORIEL group within the meaning of Article L 233-1 of the French Commercial Code.
“Server“: means a computer hosting an application service and having a large amount of disk space where files are stored.
“Website Server“: means the hosting servers of the Website on which the Services made available to the User by the Company are installed and provided.
“Services“: means all services accessible via the Site.
“Sites” or “Websites“: means the interactive electronic services published and operated by the Company, accessible in particular at the address www.EVORIEL.fr.
“Company“: means the company EVORIEL, publisher and owner of the Website.
“User“: means any natural person who accesses the Website for strictly private use.

“Personal Account“: refers to the individual account opened by a User on mon-espace-immo-particulier, by giving his/her name, first name and email and choosing a password.
EVORIEL undertakes to strictly comply with the legislation in force concerning the respect of the privacy of users of its Website, and has appointed a Data Protection Officer (DPO) for this purpose. Thus EVORIEL has appointed their DPO with the National Commission for Information Technology and Civil Liberties, and keeps in accordance with the legislation in force an up-to-date register of the processing implemented as well as the completion of the formalities relating to the collection and processing of personal data under this website.

 

6. Purpose and nature of the data collected

EVORIEL, in its capacity as data controller, implements personal data processing for the management of its relations with its customers, employees, prospects, partners.
These treatments are made necessary:
• For the use and management of the various information forms and are based on the basis of your prior consent.
• For the execution and monitoring of contracts concluded with EVORIEL subsidiaries and are based on the basis of our contractual and legal obligations,

The data collected is intended for the relevant departments of EVORIEL and its subsidiaries, and, where applicable, its subcontractors and service providers.
The subcontractors and service providers in question are subject to an obligation of confidentiality and may only use your data in accordance with our contractual provisions and applicable legislation.
The term “Personal Data” refers to all nominative or non-nominative information that allows an individual to be directly or indirectly identified.

This may include:
• that which a third party has voluntarily communicated to EVORIEL as part of a request for information, or a pre-contractual or contractual relationship
• that which the User has voluntarily provided to EVORIEL when opening their Personal Account on the private customer area mon-espace-immo-particulier, that which the User will be required to transmit to EVORIEL subsequently as part of the use of their Personal Account, or that which comes from contact forms;
• that which EVORIEL and/or its subsidiaries may have collected when browsing the websites of the EVORIEL group and its Subsidiaries and more particularly on the website (www.EVORIEL.fr)
The term “processing” means any operation or set of operations carried out or not using automated processes and applied to data or sets of personal data.

 

7. Identifiers and passwords of the Personal Account

The identifiers and passwords, as defined by the User when registering, or as may be subsequently modified by the User, are personal to the User. This information is strictly confidential. The User undertakes not to communicate them to third parties, and if necessary, remains the sole master and responsible for the use that may be made of them.
EVORIEL and its Subsidiaries cannot be held liable for the use of these identifiers by a third party.
In the event of loss, misappropriation or unauthorized use of their identifiers and passwords, the User must immediately inform EVORIEL (or one of its Subsidiaries) who may block access to the Personal Account and/or give a new password in order to reconfigure access.

 

8. Retention period – Exercising rights

Personal data may be retained for:

• a period not exceeding 3 years from the last contact from you via a contact form.
• the entire duration of the contractual relationship, then a period not exceeding 5 years from the end date of the contractual relationship.

In the context of opening a private customer area, the data may be retained for the entire duration of the direct or indirect commercial relationship with EVORIEL or one of its subsidiaries, then for a period of 5 years from the end of the commercial relationship.
You have the possibility to exercise your rights to access, rectify, erase your data, limit their processing, oppose them and request their portability. You can also define guidelines relating to the retention, erasure and communication of your personal data after your death.

For EVORIEL: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/lamy/formulaire-rgpd or by postal mail to the following address: LAMY, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services

For LAMY: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/evoriel/formulaire-rgpd or by postal mail to the address EVORIEL, 21 avenue Kleber – 75116 Paris; accompanied by a copy of an identity document, if this has been previously requested by our services.

For RICHARDIERE: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/richardiere/formulaire-rgpd or by post to the address RICHARDIERE, 22 rue Georges Picquart – 75017 PARIS; accompanied by a copy of an identity document, if this has been previously requested by our services.

For IGC: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/immobilier-gestion-consultant/formulaire-rgpd by post to the address IGC, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services.

For BAUDRY: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/baudry-immobilier/formulaire-rgpd by post to the address BAUDRY, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services.

For LACROIX: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/societe-lacroix-immobilier/formulaire-rgpd by post to the address LACROIX, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services.

For all ORALIA structures: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/ORALIA/formulaire-rgpd by post to the address ORALIA, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services.

You can also submit a complaint to the Commission Nationale de l’Informatique et des Libertés – 3 place de Fontenoy – TSA 80715 – 75334 PARIS Cedex 07.
In addition, if your telephone contact details have been collected by the data controller, you can register on the list of opposition to telephone canvassing provided for consumers by article L. 223-1 of the Consumer Code.

 

Recruitment
As part of an application for a job offer (including internship, work-study contract, etc.), the personal data of candidates is kept for a period not exceeding 3 years from the date of creation of the application.
You have the possibility to exercise your rights to access, rectify, erase your data, limit their processing, oppose it and request the portability of these. You can also define guidelines relating to the conservation, erasure and communication of your personal data after your death.
For EVORIEL: These rights are exercised either by following the procedure provided on the following link https://app.witik.io/fr/form/evoriel/formulaire-rgpd-rh by post to the following address: LAMY, 19 rue de Vienne – 75801 PARIS Cedex 08; accompanied by a copy of an identity document, if this has been previously requested by our services

 

9. Organizational structure of the EVORIEL group

If you have agreed to receive commercial offers from the EVORIEL group, we inform you that we may share your information with the operational subsidiaries of the EVORIEL group, for their own marketing activities. The information we share includes information collected when using our Services and information we collect on our websites, about you, by means of cookies, trackers, and similar technologies. Thus, your contact data and various information may be transmitted to the subsidiaries for commercial prospecting purposes by:

• Sending emails and SMS
• Telephone calls and mail

The operational subsidiaries of the EVORIEL group are the companies defined in Article 1 hereof.

 

10. Commercial partnerships

If you have consented, we share your information with third-party partners, real estate developers, mortgage brokerage firms, for their own marketing activities. The information we share includes information collected when using our Services and information we collect on our websites, about you, using cookies and similar technologies. Prior to this use, you will be informed by email of our intention and you can object to it by the procedure described in Article 8 hereof. Thus, your contact data and various information may be transmitted to advertising agencies or commercial partners for commercial prospecting purposes.

• Sending emails and SMS: prospecting by email and SMS by partners is not carried out without your consent.
• Telephone call and mail: concerning postal or telephone prospecting by partners, you can object to it at any time by notifying us or by registering on the BLOCTEL opposition list.

 

CGU – MANAGEMENT OF COOKIES AND OTHER TRACKERS
This charter is an integral part of the CGU, General Conditions of Use of the sites and applications of the EVORIEL group, and its subsidiaries.
The purpose of this Charter is to inform you of the reasons and conditions for the processing of information relating to your browsing on the Site and Applications that may be recorded on your terminal in files called “cookies or trackers” or similar tools (for the sake of simplicity, we will refer to these cookies and similar tools by the single term “Cookies”).
Some of this information from Cookies allows you to be identified, and is therefore considered personal data and other information does not allow this and therefore does not constitute Personal Data.
Regardless of the nature of the cookies, this charter complies with the CNIL guidelines – Deliberation No. 2020-091 of September 17, 2020 on the use of cookies and other trackers.

The processing of your personal data from Cookies is carried out in accordance with the applicable regulations, in particular the European Regulation known as “GDPR” (No. 2016-679 relating to the protection of individuals with regard to the processing of personal data and the free movement of such data) and the Law known as “Informatique et Libertés” (Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, as amended, and any regulations that supplement or replace them (hereinafter “Informatique et Libertés Regulations”). With regard to the use of this data, the publisher of the site or application is qualified as the controller of the processing carried out for the Cookies that it places itself as well as for the Cookies of third parties who are authorized to do so within the framework of an existing contractual relationship. The publisher does not market the advertising space on its sites and applications. The publisher therefore has full control over the use of Cookies on its sites and applications.

 

1) WHAT IS A COOKIE?
A Cookie is a text file placed by the servers of the Sites and Applications consulted or by third-party servers, in a dedicated space on the hard drive of your terminal (computer, tablet, mobile phone or any other device optimized for the Internet), when consulting content or using a service. Your internet browser records information relating to your internet browsing in these files.
This Cookie file can only be read by its issuer, who, during its period of validity, can recognize the terminal concerned each time this terminal accesses digital content containing Cookies from said issuer. The Cookie does not identify you personally, but only the browser of your terminal.
In the case of a computer consulted by several people, for example several members of a family on the same browser, the cookie is assigned to the browsing information of all the people who have used the same terminal, without distinguishing them.
The Cookie thus makes it possible to collect additional non-directly identifying information on your behavior within the Services and Applications.

2) WHO USES COOKIES?
Cookies may be placed by the Publisher, by its technical service providers or by its partners or by third parties. Only the operator of the Cookie, i.e. the legal entity on whose behalf it is issued, whether or not it is the issuer, is responsible for its use and the Data it collects through it.

3) WHY ARE COOKIES PRESENT ON THE PUBLISHER’S SITE AND APPLICATIONS?
Cookies allow the Site and Applications to function efficiently, and to remember your preferences, to provide the Publisher and its partners with information for statistical or advertising purposes. Below you will find the main purposes of the Cookies issued on behalf of the Publisher and in the configuration interface provided for this purpose, on the site and in the applications.

4) CATEGORIES OF COOKIES USED BY THE PUBLISHER
SESSION COOKIES
Session cookies are strictly necessary for browsing the Sites and Applications. The requested services, such as contact forms, could not be provided without cookies.
Session cookies are temporary and expire as soon as you leave the site.

BROWSING COOKIES
These Cookies are necessary for your proper browsing on the Site and for the proper functioning of the Applications, they are used in particular to:
• Adapt the presentation of the Site to the display preferences of your viewing terminal (language used, display resolution, operating system used, etc.)
• Memorize information relating to your login credentials
• Offer you access to your account or any other reserved space using your credentials
• Implement security measures, for example when you are asked to log in again to content or a Service after a certain period of time has elapsed.
Browsing cookies are permanent. They are saved on your hard drive. They expire automatically 13 months after the creation date.

 

AUDIENCE MEASUREMENT STATISTICAL COOKIES
Audience measurement cookies help to establish statistics on the attendance and use of the various elements making up the Site (sections and content visited, paths), allowing the Publisher in particular to improve the interest and ergonomics of the Services.
Audience measurement cookies are permanent. They are saved on your hard drive. They expire automatically 13 months after the creation date.
Session, navigation and audience measurement cookies are considered by the publisher to be strictly necessary for the normal use of the site or application. You are informed that they are saved on your terminal, because the legal basis for the processing is the legitimate interest of the publisher, your consent is therefore not required. You can change this setting at any time by going to the settings interface provided for this purpose.

TARGETED COOKIES OR THIRD-PARTY ADVERTISING COOKIES
These Cookies collect information about your Internet browsing habits in order to offer you advertisements that are tailored to you and correspond to your interests when you visit other sites. These Cookies also help us evaluate the effectiveness of our advertising campaigns. The information may be collected and shared with third parties, partners of the Publisher, to offer audience targeting and optimization solutions for advertisers. An individual cannot be directly identified via the data collected.
The Publisher does not place cookies that include personal data that can directly identify an individual, such as their name, email address, or telephone number.

CONSENT ON COOKIES
Cookies other than Cookies strictly necessary for browsing cannot be saved without your consent. By clicking on the “I accept” icon on the information banner visible when you first connect to the Site and Applications, you communicate your consent to us and we record it.
If you accept via your browser software the saving of Cookies in your terminal, the Cookies integrated into the pages and content that you have consulted may be temporarily stored in a dedicated space on your terminal. They will be readable there only by their issuer.
The agreement that you give is only valid for a period of thirteen (13) months from the first deposit in the equipment of your terminal, following the expression of your consent.

EXERCISE YOUR PREFERENCES
You can exercise your preferences by going to the settings interface provided for this purpose.

– OTHER WAYS TO EXERCISE YOUR PREFERENCES

• VIA YOUR ONLINE CHOICES:
  You can connect to the Youronlinechoices.com website, offered by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France. You will thus be able to find out which companies are registered on this platform and which offer the possibility of refusing or accepting the Cookies used by these companies to adapt the advertisements likely to be displayed on your terminal: http://www.youronlinechoices.com/fr/controler-ses-cookies/

 

• VIA ABOUTADS:
  This site published in English also allows you to express your choice online via the following link: http://www.aboutads.info/choices/.

 

• VIA BROWSER CONFIGURATION:
  For the management of Cookies, the configuration of each browser is different. It is described in the browser’s help menu, which will allow you to know how to modify your wishes regarding Cookies:
  For Internet Explorer™: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
  For Safari™: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
  For Chrome™: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
  For Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies
  For Opera™: https://www.accepterlescookies.com/comment-accepter-les-cookies-sur-opera.html