1. What Data About You is Collected
Personal Data Collected Directly From You:
- Through subscription forms;
- When you request contact;
- When you request documentation; and
- When you establish a business, contractual, or investment relationship with a Group company.
For more information on the types of Personal Data collected, please refer to Part 2 of this Policy.
If you choose not to provide this Personal Data, certain services and/or options available on the Site and/or related to our Products and Services may not be accessible.
Automatically Collected Data
Additionally, please note that, like most online services, each time you visit one of our Sites, we automatically collect certain data and information about you and/or your computer or electronic device through the use of “cookies.” This information includes:
- The IP address automatically assigned to your computer when you use the internet;
- The type of internet browser you use;
- The type of operating system and device you use to access the Site;
- The domain name of your internet service provider;
- The webpage you were referred from;
- Your country of residence and language;
- The pages and options you visit and access on our Site.
When you access, visit, and/or use one of our Sites, we may track your visit and collect certain data related to your use of the Products and Services and your activity on the Site. For more information on our use of cookies, please read our Cookie Policy, available at the following link: https://www.newalpha.com/en/cookie-policy/.
Personal Data Collected From Third Parties
We may obtain Personal Data about you from the Group’s partners.
For example, we may collect Personal Data from:
- Banks or financial advisors distributing our Products and Services;
- Property managers responsible for tenant tracking, etc.
2. How are your personal data used?
We process your Personal Data based on the following legal grounds: your consent (request for information or documentation), the performance of a contract we have entered into together (subscription form, registration to benefit from Products and Services), the fulfillment of our legal obligations, or in the case of prospects, when we pursue a legitimate interest. We believe that the risk associated with the Personal Data we process based on our legitimate interests is not excessive or too intrusive. We have implemented measures to protect your rights by applying appropriate retention periods and ensuring adequate security controls.
For more information on the purpose of the processing carried out, please read Part 2 of this Policy.
3. How long are your Personal Data kept for?
We store your personal data for a limited time, necessary for the purpose for which we process them and in any case for the duration necessary to meet a legal or regulatory obligation.
Personal data used to send you documentation.
We will keep your personal data as long as your subscription is active. You can unsubscribe at any time by clicking on the link provided in the email containing the documentation. If we do not hear from you for three years, we will delete your personal data.
Personal data used to send you commercial offers.
Your Personal Data will be kept for as long as you agree to receive our commercial offers. You can opt out at any time by unsubscribing using the link provided in the email offering you a commercial deal. In any case, if we do not hear from you for a period of three years, your Personal Data will be deleted.
Personal Data used in the context of a commercial, contractual, or investment relationship
We store this Personal Data for a limited and necessary period for the purpose for which we process it, i.e. for the entire duration of our contractual relationship and in any case for the duration necessary to comply with a legal or regulatory obligation.
For more information on the retention periods of Personal Data, please refer to section 11 “WHAT TO DO IF YOU HAVE OTHER QUESTIONS REGARDING THE PRIVACY POLICY?”.
4. How are your personal data shared?
The companies within the Group
We may share your Personal Data with the companies that make up the Group. For more information about the Group’s companies, please visit the page https://www.newalpha.com/en/regulatory-information/
Sharing with Service Providers
As part of our business, we may need to transfer your personal data to service providers not affiliated with the Group who act as subcontractors. These service providers use the personal data to help us provide products and services, make the website available, or assist us in managing our business.
For example, these service providers can include IT providers, logistics and marketing partners, our hosting provider, or providers helping us with data management, email distribution, information analysis, as well as property managers, property administrators, real estate agencies, banks, investment advisors, tax advisors, auditors, lawyers, or other external professional advisors. We only share the Personal Data with our service providers that they need to provide their services and work with them to respect and protect your Personal Data. We may also need to transfer your personal data to companies for which we provide services, but only to fulfill our contractual obligations to them and in compliance with applicable laws. We do not share any Personal Data with companies for their own marketing or commercial purposes. However, we may share your Personal Data with our business partners only to provide you with the Products or Services or similar products or services that may interest you.
Legal obligations
We may need to disclose Personal Data at the request of an administrative authority (tax administration, CNIL, etc.) and/or judicial (response to a judgment, order, injunction from a court), upon simple request or if required by law, in order to protect our rights, property, and/or our safety and/or that of third parties. We can share Personal Data with companies helping to combat fraud and investigate it. We may also share your personal data as part of the fight against money laundering and terrorist financing, with the implementation of monitoring of contracts and/or transactions that may lead to the filing of a suspicion report or asset freezing measures.
Other
Unless otherwise stated in this Privacy Policy or with your prior consent, we will not sell, market, or lend Personal Data to other companies in the normal course of our business activities. However, in the event of a reorganization of the companies within the Group (acquisition, merger, partial asset transfer, or similar operation), your Personal Data may be disclosed to another company, but this disclosure will be subject to the current Privacy Policy.
5. Are our products and services intended for minors?
Our Products and Services are not targeted and not intended for children. By using any of the Group’s Sites, you certify that you are over 15 years old, otherwise please do not use a Group Site without prior parental permission.
6. How can I know if your personal data is being kept securely?
We have a variety of security measures in place to prevent the loss, misuse, or unauthorized access of the personal data you have provided to us. In order to ensure the security of the data you communicate online during transmission, we use encryption, authentication, flow analysis devices, and conduct security checks on hosting environments.
7. How can the links on the website that refer to other sites outside of the group impact us?
Each site may contain various hyperlinks to other sites within the group.
In addition, each website may contain hyperlinks to other websites and applications operated by companies that are not part of the Group. These links are intended to facilitate your navigation and provide you with as much information as possible. We have no control over these websites and applications, which are independent of the Group and have their own distinct privacy protection policies. Therefore, the Group cannot be held responsible for any reason, especially regarding the accuracy, relevance, availability, reliability of the information, products, and services offered on these sites, compliance with copyright, legality, or decency of the material contained in these third-party websites and applications accessible via our site. We encourage you to review the privacy protection conditions and policies of any third-party website and application before using them. When you leave our site, please be aware that our Privacy Protection Policy no longer applies.
Furthermore, the Group is not responsible for the hyperlinks directing to its own sites, which third-party websites may integrate into their own sites even if the Group has authorized the third-party publisher of said site to place such a link.
Finally, the Group prohibits anyone from placing a hyperlink directing to one or more pages of its Sites without its prior express authorization.
8. How can you refuse/unsubscribe from receiving emails, SMS?
If you no longer want to receive emails from the Group informing you about events, new products or services, similar products or services, or containing other commercial communications, simply click on the “Unsubscribe” link at the bottom of each email and follow the indicated procedure.
If you no longer want to receive SMS, you can send “STOP” to the indicated number if the option is available, otherwise, contact your usual contact person.
9. What are your rights regarding your personal data?
According to the legal and regulatory framework for the protection of personal data and privacy, you have the right to access, rectify, object, delete, limit processing, and the right to data portability for your personal data, except where prohibited by law.
These rights are not absolute and each of them is subject to certain conditions according to French law (in particular by Law 78-17 of January 6, 1978 on information technology, files and freedoms, as amended, but also any applicable legislation to the Group in banking and financial matters), the recommendations of the CNIL, as well as the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”).
Similarly, if we have collected and processed your Personal Data with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing based on the consent given before its withdrawal.
You also have the right to define the guidelines for the fate of your Personal Data after your death.
You can contact Groupe La Française at any time by mail at the following address: Groupe La Française – Data Protection Officer – 128, boulevard Raspail – 75006 PARIS, or by email at dpo@la-francaise.com.
Before evaluating your request, we may ask you for additional information to identify you. If you do not provide the requested information and as a result, we are unable to identify you, we may refuse to proceed with your request.
Finally, you have the right to file a complaint regarding the collection and use of your personal data with your local data protection authority, the CNIL (in France, it is the CNIL: www.cnil.fr).
10. What should you do if you have any other questions regarding the privacy policy?
If you have any questions or concerns about this Privacy Policy, you can contact the Data Protection Officer by email at dpo@la-francaise.com or by sending a letter to Groupe La Française – Data Protection Officer – 128, boulevard Raspail – 75006 PARIS.
11. Which legislation applies to this privacy protection policy?
This Privacy Policy is governed by French law, particularly by Law 78-17 of January 6, 1978 relating to information technology, files and freedoms, as amended, the recommendations of the CNIL and the GDPR.
Please note that this policy may change to accommodate regulatory changes.
