VAP SYSTEMS is committed to making its best efforts to ensure its personal data processing activities comply with applicable data protection legislation, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the "GDPR") and Law No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (the "Data Protection Laws").
The purpose of this policy is to explain what personal data we collect and how we use it (the "Policy"). It concerns users of our website, our clients and prospects ("you", "your") and applies to any processing by our Company and its affiliated entities of your personal data.
The processing of your personal data is the responsibility of VAP SYSTEMS registered at the Trade and Companies Register of Nanterre under number 842966988 with its registered office at 34 rue Guynemer, 92130 Issy-les-Moulineaux, as data controller (hereinafter the "Company" or "we").
We process personal data that you provide to us or that we obtain directly from you in the context of your relationship with us. We process the following categories of personal data directly from you via the property valuation form on our website, in particular for the purposes described in Article 3 of this Policy - Identification data: title, surname and first name, contact details (postal and email address, mobile and landline telephone number), - Data relating to your financial situation; - Data relating to the property concerned: property type, surface area, floor, condition, annexes, location; - Data necessary for loyalty, prospecting, study and survey activities to improve the quality of our services.
We also collect your data indirectly when you browse our website through the use of cookies. In this context, we collect data relating to your traffic and browsing history on the site, as well as location data (such as IP address), device data, and data tracking email actions (such as opens, clicks).
Data will only be collected and processed by the Company if an appropriate and relevant legal basis permits it. The Company may therefore use your data for the following purposes: - For managing your requests and providing our services, including the valuation of your property or the performance of mandate contracts you have entered into with us, on the basis of contract performance (Article 6-1(b) of the GDPR); - To manage our commercial relationship with you, and support you in managing your property projects, to offer you our services, on the basis of the legitimate interest of our Company to develop its business and clientele (Article 6-1(f) of the GDPR); - To contact you by email or telephone to offer you our services, on the basis of the legitimate interest of our Company to develop its business and clientele (Article 6-1(f) of the GDPR) or on the basis of your consent when you are not users of our services (Article 6-1(a) of the GDPR); - To carry out studies and surveys with our clients and prospects to better understand their level of satisfaction, on the basis of the Company's legitimate interest in improving its business and services (Article 6-1(f) of the GDPR); - For statistical purposes, on the basis of the Company's legitimate interest in improving its business and services (Article 6-1(f) of the GDPR); - To comply with our legal and regulatory obligations (Article 6-1(c) of the GDPR).
The Company does not subject you to decisions based solely on automated processing producing legal effects concerning you or similarly significantly affecting you.
When personal data is disclosed within the Company, we take measures to ensure that this personal data is accessible only to employees who need it, our sales department and our management.
In the course of our business or for the performance of your contract, we share your data with third parties, subcontractors or authorised agents, our IT service providers, for data hosting and information systems maintenance purposes.
When we share your data with third parties, we take appropriate measures to ensure that our subcontractors process your personal data in accordance with Data Protection Laws.
The Company may also share your data with: - representatives of law enforcement, judicial or administrative authorities or other authorised third parties in response to an information request from a competent authority, if Avest considers that the disclosure of such information is lawful or required by law, applicable regulation or in the context of legal proceedings; - our legal advisors and/or lawyers; - in the case of a restructuring, disposal or merger-acquisition operation (including reorganisation), we may transfer your personal data to a third party involved in the operation (for example, a buyer) in accordance with Data Protection Laws.
Your data is hosted on servers located in the European Economic Area ("EEA").
In principle, your personal data will not be transferred to a third country or international organisation outside the EEA. Our IT service providers periodically transfer your personal data outside the European Economic Area ("EEA") for IT maintenance purposes. These service providers are bound by a contract that guarantees a high level of confidentiality protection and requires them in particular to act only on the Company's instructions and to implement all necessary technical measures to maintain the security of your personal data. The Company has framed its transfers through the implementation of the European Commission's Standard Contractual Clauses. To obtain a copy of the contractual guarantees implemented by the Company, you may send your request to the contacts designated in this Policy.
Your data will be retained for a period that does not exceed what is necessary for the purposes set out in this Policy, in particular: - Data collected via the valuation form is retained for 3 years from collection or your last contact with us; - Data relating to contracts entered into with us will be retained for the duration of our contractual relationship, then for 5 years.
If the data collected by the Company is no longer necessary for the purposes set out in this Policy, it will be regularly deleted unless it is necessary to retain it longer (i) to ensure compliance with legal, accounting and tax retention obligations (ii) for the preservation of evidence during applicable limitation periods, (iii) for the exercise of the Company's rights in the event of litigation or legal proceedings during the entire period of the proceedings or investigation.
In accordance with Data Protection Laws, you have the rights of access, rectification and erasure of your personal data, the rights to object to or restrict the processing of your personal data, the right to data portability and the right to define directives regarding the fate of your personal data after your death. - The right of access. You have the right to obtain a copy of your personal data. - The right to rectification. You have the right to obtain the rectification of your personal data if it is inaccurate or incomplete. - The right to erasure (the "right to be forgotten"). You have the right to obtain the erasure of your personal data. However, the right to erasure (or the "right to be forgotten") is not absolute and is subject to specific conditions. We may retain your personal data within the limits permitted by applicable law and regulations, in particular when processing remains necessary for compliance with a legal obligation to which the Company is subject or for the establishment, exercise or defence of legal claims. - The right to restriction of processing. You have the right to obtain restriction of processing in certain circumstances (for example, when the Company no longer needs your personal data for certain processing but it is still necessary for the establishment, exercise or defence of legal claims). - The right to data portability. You have the right, in certain circumstances, to receive the personal data concerning you that you have provided to the Company in a structured, commonly used and machine-readable format and to transmit it to another data controller. - Right to object to processing. You have the right to object, on grounds relating to your particular situation, to certain types of processing (for example, when processing is based on the Company's legitimate interests). - The right to withdraw consent. If you have given your consent to processing by the Company of your personal data, you have the right to withdraw it at any time. - The right to define directives regarding the fate of your data after your death. You may define directives regarding the retention, erasure and communication of your personal data after your death.
You also have the right to object to telephone marketing by registering your number on the Bloctel list: www.bloctel.gouv.fr. VAP SYSTEMS reminds you that this right of objection does not apply to telephone calls and other contacts necessary for the performance of services.
In the context of our relationship, you are required to provide certain personal data necessary for us to provide you with certain services such as the online valuation of your property or where the collection of such data is required by law.
In the absence of such data, we will generally not be able to provide you with the services concerned.