Privacy policy
This Privacy Policy aims to inform Users of the website [www.ms-propertymanagement.com](http://www.ms-propertymanagement.com) (hereinafter the “Site”) about the processing carried out by MS PROPERTY MANAGEMENT (hereinafter the “Company”), as the Data Controller, in accordance with the provisions of Law No. 78-17 of January 6, 1978, relating to data processing, files and freedoms, as amended by Law No. 2018-493 of June 20, 2018, following the entry into force of the General Data Protection Regulation (hereinafter the “Law”).
Users of the Site are encouraged to read this Privacy Policy carefully.
ARTICLE 1. DEFINITIONS
Personal Data / Data
Refers to any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or to one or more elements specific to them. This may include, in particular, the User's first and last names, phone number, email and postal address, or gender (e.g., female, male).
Cookies
Cookies refer to automated tracking processes in the form of text files placed on a device (computer, tablet, smartphone) that record information during a visit to a website or when viewing an advertisement. Cookies can serve various purposes and retain information for a certain period.
Privacy policy
Refers to this privacy policy concerning the processing of User Data and the use of Cookies on the Site.
Data Controller
The company MS PROPERT MANAGEMENT, a SAS with a capital of 1000 euros, registered with the Paris Trade and Companies Register under number 938 374 659, with its registered office at 58 RUE DE MONCEAU 75008 PARIS, duly represented by its manager Mr. Melvin Lakhfif, who determines the purposes and means of the processing as defined herein.
Processing
Refers to any operation or set of operations relating to Data, such as the collection, recording, storage, consultation, communication, or even the erasure and destruction of personal Data.
User
This refers to any person accessing the Site, whether they are a client of the Company or not.
ARTICLE 2. GENERAL PROVISIONS
This Privacy Policy may be modified at any time by the Company, notably to comply with developments in Law, case law, technology, or the requirements of authorities. In the event of modification of the Privacy Policy, the Company will inform the User and/or seek their consent when necessary.
The latest version of the Privacy Policy is the one available on the Site.
Users are invited to consult the Privacy Policy before Browse the Site and to regularly review the Privacy Policy in order to be aware of any modifications and/or updates made by the Company.
For any questions regarding this, the User may contact the Company by email at the following address: contact@ms-propertymanagement.com; or by mail at the address: MS PROPERTY MANAGEMENT SAS, 58 RUE DE MONCEAU 75008 PARIS.
ARTICLE 3. DATA SUBJECTS
The individuals concerned by the Data Processing carried out by the Company are the Users of the Site, and notably:
– Users visiting the Site
– Users filling out the various forms on the Site (contact, property valuation, creation of a dedicated alert, sharing a property referenced on the Site by email).
ARTICLE 4. DATA COLLECTION
4.1 – During the use of the Site, the User's personal Data may be collected directly or automatically by the Company.
Personal Data is notably collected via forms during:
– Civil status (last name, first name)
– Address*
– Mail address*
– Phone number*
– Characteristics of the User's property (apartment, house, surface area m2, number of rooms, floor)
The information request sent by the User on the Site requiring the communication of the following personal Data:
To be contacted by email:
– Name
– Mail address*
Pour être rappelé par téléphone :
To be contacted by phone:
The creation of a dedicated email alert for a property search, requiring the communication of the following personal Data:
– Civil status (last name, first name)
– Mail address*
4.2 – Among the personal Data listed below, the communication of information marked with an asterisk " * " is essential for the corresponding processing. If the User does not wish to communicate the requested information, particularly that marked with an asterisk " * ", the Company will not be able to respond to their request. The communication of other personal Data being optional, it is left to the User's sole discretion.
The User may also communicate any other information they wish to bring to the Company's attention, it being understood that the provision of such information is not mandatory. If the User transmits personal Data in this context, the Company will process it under the conditions set out herein and in accordance with the Law.
4.3 – The User's personal Data may also be collected through Cookies, subject to the User's choices regarding these Cookies, which can be modified at any time (To learn more: see Article 10 of the Policy).
4.4 – The Company does not collect any sensitive Data on the Site within the meaning of the Law.
4.5 – The Company allows the User to send a link redirecting to a real estate listing on the Site to a person of their choice, via their own email address. The User who wishes to use this feature acknowledges that the sending of this email is done under their sole responsibility and ensures that they have obtained the consent of the person concerned in order to send them this email.
ARTICLE 5. LEGAL BASES AND PURPOSES OF PROCESSING
5.1 – Data is used by the Company in accordance with the Law. The processing of Data is thus lawful insofar as:
– It aims to respond to the requests/demands of the User concerned and/or;
– It aims to comply with the legal obligations to which the Company is subject and/or;
– The User has consented to the processing of their Data and/or;
– There is a legitimate interest pursued by the Company. The Company's legitimate interest is primarily based on commercial and financial reasons requiring personal Data to be processed by it.
5.2 – The Data referred to in Article 4 above are collected and processed for the following purposes:
– Management of responses to User requests concerning:
1) The valuation of a real estate property;
2) Various information requests;
3) The creation of a dedicated email alert for a real estate property search;
4) The sharing by email of a real estate property referenced on the Site.
– Sending information concerning promotional operations and other events as commercial communication;
– The execution of real estate operations;
– Management of requests for exercising rights;
– The development of commercial statistics;
– The establishment of means of proof necessary for the defense of the Company's rights.
ARTICLE 6. RETENTION PERIOD
6.1 – Personal Data will not be retained beyond the period strictly necessary for the purposes pursued as set forth in this Privacy Policy and in accordance with the Law.
6.2 – Personal Data collected for the purpose of responding to requests for property valuation or various information inquiries are retained until the Company provides a response to the User's request. Once the response has been sent by the Company to the User, the personal Data concerning them will be deleted.
Personal Data collected for the purpose of creating a dedicated email alert for a property search are retained until the User unsubscribes, which can be done at any time.
Personal Data collected for the purpose of sharing a real estate property referenced on the Site by email are retained until the Company has completed the email sharing of the said property.
Notwithstanding the foregoing, when the User has given their consent to receive commercial communications, the personal Data used may be retained for a period of three (3) years from their collection or the last contact from the prospect (whichever date is later). At the end of this period, the Company may re-establish contact with the User concerned to ascertain whether they wish to continue receiving commercial solicitations. In the absence of a positive response, the Company will delete the Data in accordance with the legislative and regulatory provisions in force.
Personal Data collected for the purpose of carrying out real estate operations are retained for the entire duration of the relationship between the User and the Company and for a period of ten (10) years following the last contact between the User and the Company. This retention period corresponds to the sales cycles of real estate properties and is justified by the nature of the Company's activity, the entrusted mission, and its obligations as a professional.
Data collected concerning the management of requests to exercise rights are retained for between one (1) year and six (6) years, depending on the right exercised.
Data collected for the purpose of generating commercial statistics are retained for a period of two (2) years from the last contact.
However, personal Data enabling proof of a right or a contract, or retained for the purpose of complying with a legal obligation, may be securely archived for a period not exceeding the time necessary for the purposes for which they are kept (including but not exclusively those provided for by the Commercial Code, the Civil Code, and the Consumer Code, as well as the accounting and tax provisions applicable to the Company).
Cookies, for their part, have a maximum lifespan of thirteen (13) months.
ARTICLE 7. DATA ACCESS
7.1 – All or part of the authorized personnel of the Company may have access to all or part of the personal Data. Individuals who can access personal Data are subject to a confidentiality obligation.
7.2 – Furthermore, the Company's partners and subcontractors may have access to the Data, particularly:
The processing carried out by the Company's service providers and partners is governed by a contract in which they commit to respecting the Law and all obligations placed upon them, particularly regarding data security and confidentiality.
– Commercial agents linked to the Company as part of their real estate negotiation, customer relationship management, and prospecting missions;
– The Company's service providers responsible for hosting the Site and the Data;
– The Company's service providers responsible for the development and maintenance of the Site;
– The Company's service providers responsible for managing analytics and audience measurement tools.
7.3 – Data may also be transmitted to judicial and supervisory authorities, as well as to legal auxiliaries and ministerial officers, as part of their debt collection missions and for the protection of the Company's interests.
ARTICLE 8. DATA TRANSFER
The User's Data is stored by the Company within the European Union.
However, insofar as certain service providers and subcontractors of the Company may be located in third countries, outside the European Union, the Company may transfer the User's Data to these third countries. In such a case, the Company ensures that this transfer is carried out in compliance with the Privacy Policy and with the Law, and also that the subcontractor/provider guarantees a sufficient level of protection of the User's privacy and fundamental rights.
ARTICLE 9. PROTECTION OF PERSONAL DATA
Considering the state of knowledge, the costs of implementation, and the nature of the Data concerned, the Company commits to implementing appropriate measures to preserve the security and confidentiality of the Data. The Company thus ensures that the Data is not distorted or damaged, and that unauthorized third parties do not have access to it.
The Company notably ensures:
– Raising awareness among Company employees who access Data about confidentiality requirements;
– Securing the access, sharing, and transfer of Data;
– The high degree of rigor in data protection when selecting the Company's subcontractors and partners.
However, the Company cannot be held to an obligation of result given the risks and difficulties inherent in the use of electronic networks.
ARTICLE 10. DATA BREACHES
10.1 – The Company makes every effort to protect Users' personal Data as effectively as possible, taking into account technological advancements.
Nevertheless, and notably due to the rapid evolution of security techniques, it is understood that no transmission or storage technology is infallible, despite the extent of the measures implemented.
10.2 – In the event of a personal Data breach likely to result in a high risk to the rights and freedoms of natural persons, the Company will communicate this breach to the Users concerned as soon as possible, except in the exceptional cases provided for by Law.
In the event of a personal Data breach, the Company will notify the National Commission for Information Technology and Liberties (CNIL) of the breach as soon as possible, and at the latest within the deadlines provided by Law, unless the breach is not likely to pose a risk to the rights and freedoms of individuals.
ARTICLE 11. USER RIGHTS
11.1 – The User has the right to access their personal Data and to request that it be rectified, completed, or updated. The User can also request the erasure of their personal Data or object to its processing. Furthermore, they can request the restriction of the processing of their personal Data.
For processing carried out based on the User's consent, the User can withdraw it at any time, and the Company commits to terminating the processing in question as soon as possible.
The User can request to exercise their right to data portability for their personal Data, meaning the right to receive the personal Data they have provided in a structured format, and the right to transmit this personal Data to a third party.
Notwithstanding the foregoing, the Company may retain certain personal Data concerning the User when applicable laws and regulations require it to do so or when it has a legitimate reason to do so.
The User can formulate directives regarding the retention, erasure, and communication of their personal Data after their death (retention, deletion, or communication to a designated third party).
11.2 – The User can exercise their rights with the Company by email at the following address: contact@ms-propertymanagement.com, or by mail at the following address: MS PROPERTY MANAGEMENT, 58 RUE DE MONCEAU 75008 PARIS.
The Company may verify the User's identity and/or ask them to provide a copy of their identity document to respond to their request. The Company will endeavor to respond to the User's request as soon as possible and, in any event, within the timeframes provided by Law.
Here's the translation: In case of a dispute regarding the exercise of their rights, the User can lodge a complaint with the National Commission for Information Technology and Liberties (CNIL): www.cnil.fr
ARTICLE 12. THIRD-PARTY WEBSITES
If the User uses the links present on the Site to consult third-party websites (including social media sites, YouTube, etc.), the Company strongly recommends that the User read the provisions of the privacy and cookie policies of the sites they consult.
– Accéder à la politique de confidentialité de Youtube
– Accéder à la politique de confidentialité d’Instagram
– Accéder à la politique de confidentialité de Facebook
The responsibility of the Company cannot be sought for Data Processing carried out by third-party websites.
The User is invited to consult the links to the privacy policies of the main third-party sites present on the Site. The User's attention is nevertheless drawn to the fact that this list is not exhaustive, as the Company may integrate new links to other third-party sites.