Privacy policy

 1.    Purpose and scope of the Policy
The Florac group, composed of the companies Florac, Florac Investissements, Florac Investissements 2, Caille and MJLD (hereinafter the “Florac Group”) attaches the greatest importance and care to the protection of privacy and personal data, as well as to the compliance with the provisions of the applicable legislation.

This privacy policy (hereinafter the "Policy") aims to provide you with simple and clear information on the processing of personal data about you carried out by the companies of the Florac Group in the course of your browsing and your interaction with the contact form on the website http://www.florac.eu/en/ and in the course of investment operations, particularly real estate investment, equity investments and financial investments carried out by the Florac Group.

All terms in this Policy beginning with a capital letter shall have the same meaning as in the General Data Protection Regulation (EU) 2016/679 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 (hereinafter the "GDPR") some of which are listed below:

-          Controller: the natural or legal person which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data;

-          Data subject: a natural person about whom the Processing of Personal Data is performed and who can be identified, directly or indirectly, by reference to that Personal Data;

-          Personal Data: any information relating to an identified or identifiable Data subject, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, etc.;

-          Processing: any operation or set of operations which is performed on Personal Data, whether or not by automated means such as collection, access, recording, copy, transfer, retention, storage, intersection, modification, structuration, disclosure, communication, registration, destruction whether automatic, semi-automatic or other, this list is not exhaustive.

2.    Controllers
In the course of your browsing and your interaction with the contact form on the website http://www.florac.eu/en/, the companies Caille and Florac Investissements collect Personal Data about you.

In the course of investment operations, particularly real estate investment, equity investments and financial investments carried out by the companies of the Florac Group, those companies may process certain Personal Data about you. For this Processing of Personal Data, and in the course of their respective activities, each company of the Florac Group is a Controller, namely:

-          Florac, a Société par Actions Simplifiée organized under the laws of France, whose registered office is at 16 avenue Robert Schuman 75007 Paris (France), and registered with the trade and company registry of Paris (France) under number 500 808 761;

-          Florac Investissements, a Société par Actions Simplifiée organized under the laws of France, whose registered office is at 16 Avenue Robert Schuman, 75007 Paris (France), and registered with the trade and company registry of Paris (France) under number 823 269 477;

-          Florac Investissements 2, a Société par Actions Simplifiée organized under the laws of France, whose registered office is at 16 avenue Robert Schuman 75007 Paris (France), and registered with the trade and company registry under number 900 394 859;

-          Caille, a Société par Actions Simplifiée organized under the laws of France, whose registered office is at 16 avenue Robert Schuman 75007 Paris (France) and registered with the trade and company registry under number 498 295 021;

-          MJLD, a Société par Actions Simplifiée organized under the laws of France, whose registered office is at 16 avenue Robert Schuman 75007 Paris (France), and registered with the trade and company registry under number 517 959 144.

3.    What Personal Data is collected?
The Personal Data processed about you will vary depending on the context in which your Personal Data is collected:

-          Personal Data about you collected directly from you in the course of your browsing or your interaction with the contact form on the website http://www.florac.eu/en/:

o   Identification Data: name, first name, company, email address, message.

o   Browsing information: IP address, information about your browsing.

 -          Personal data about you collected from third parties in the course of investment operations, particularly real estate investments, equity investments and financial investments carried out by the companies of the Florac Group:

o   Identification Data: name, first name, company, e-mail address, ID card.

4.    Why is your Personal Data collected?
We collect your Personal Data for specific purposes and on different legal grounds.

-          In the course of your browsing and of your interaction with the contact form on the website, http://www.florac.eu/en/, the companies Caille and Florac Investissements process your Personal Data to enhance your visit of the website and to enable you to contact the company, in particular in the context of the recruitment of interns and employees by certain companies of the Florac Group. This Processing is carried out to satisfy the legitimate interest of certain companies of the Florac Group to offer quality services, a simple and direct point of contact to the users of its website and also to establish contact in the context of a potential internship or employment.

-          In the course of investment operations, particularly real estate investments, equity investments and financial investments carried out by companies of the Florac Group, these companies may process Personal Data about you (in your capacity as an employee, manager, client or service provider) in order to carry out verifications, due diligence and audits. This Processing is carried out to satisfy the legitimate interest of Florac Group companies wishing to have a proper understanding of the companies in which they intend to carry out and/or are carrying out investments, equity investments or financial investments.

-          In the course of their activities, the companies of the Florac Group can also carry out communication operations and organize events, and process your Personal Data for the purpose of inviting you to such events, in order to promote their activities, which is in their legitimate interest.

5.    Is your Personal Data shared?
Your Personal Data is processed primarily by the employees of the Controller identified in Section 2 of the Policy, only if such Processing is necessary for the conduct of their missions and in any case within the limits of their respective attributions.

Your Personal Data may be transmitted to the following recipients:

-          Entities of the Florac Group in the course of outsourcing an activity to another entity of the group;

-          Service providers and subcontractors used to carry out the maintenance of IT systems or for the conduct of audits initiated in the context of investment operations;

-          Duly authorized public authorities (judicial, regulatory...), in the framework of our legal and regulatory obligations;

-          Regulated professions (lawyers, bailiffs, etc...) who may intervene in the context of the implementation of guarantees, recovery process or litigation.

6.    Is your Personal Data transferred to countries located outside the EEA?
We strive to keep your Personal Data within the European Economic Area (EEA).

However, it is possible that the Personal Data we collect when you use our website or in the course of our activities is transferred to another country located outside the EEA.

In the event of such a transfer, it will be carried out:

-          To a country ensuring an adequate level of protection, i.e. a level of protection equivalent to what the European regulations require;

-          Within the framework of standard contractual clauses;

-          Within the framework of internal company rules.

7.    How long is your Personal Data retained for?
We retain your Personal Data only for the time required to fulfill the purpose for which we hold the Personal Data or to meet our legal obligations.

Retention times vary depending on several factors, such as:

-          Contractual requirements;

-          Legal requirements;

-          Our proportionality assessment in relation to our legitimate interests;

-          Recommendations from regulatory authorities.

8.    What are your rights?
You are entitled to the following rights with respect to your Personal Data:

1.       Right of access: the right to obtain a copy of the Personal Data that the Controller holds about you.

2.       Right to rectification: the right to have the Personal Data relating to you rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.

3.       Right to restriction of Processing: the right, under certain conditions, to request that the Processing of Personal Data be temporarily suspended. 

4.       Right to erasure: the right, under certain conditions, to have the Personal Data erased or deleted.

5.       Right of opposition: the right to object to the Processing of Personal Data under certain conditions.

6.       Right to define post-mortem directives: where the Personal Data has been collected from you, the right for the applicant to define directives concerning the fate of his/her Personal Data after his/her death.

To exercise your rights, you may contact the Data Protection Officer (DPO): dpo@florac.eu.

When you send us a request to exercise a right, you are asked to specify as far as possible the scope of the request, the type of right being exercised, the Personal Data Processing concerned, and any other useful information, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be requested to prove your identity.

You are also entitled to the right to lodge a complaint with the French supervisory authority (CNIL) http://www.cnil.fr/plaintes in the event of issues relating to the management of your Personal Data by the companies of the Florac Group.

9.    Update of this Policy
This Policy may be updated from time to time to reflect changes in the Personal Data regulations.

Date of last update 11/22/2022