1. Objective and scope of the policy
The Florac group composed of the companies Florac, Florac Investissements, Florac Investissements 2, Caille and MJLD (hereinafter the” Group Florac”) attaches the greatest importance to the protection of privacy and personal data, as well as to compliance with the provisions of applicable legislation in this area.
This privacy policy (hereinafter the” Politics ”) aims to provide you with simple and clear information on the processing of personal data concerning you implemented by the companies of the Florac Group (i) as part of your navigation and your interaction with the contact form on the website http://www.florac.eu/fr/ and (ii) in the context of investment transactions, in particular real estate, equity investments and financial investments made by Florac Group companies.
All terms of this Policy beginning with a capital letter have the meaning given to them by 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 (hereinafter the” RGPD ”) some of which are reproduced below:
- 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, an identity card number, a salary, health records, bank account information, bank account information, driving or consumption habits, driving or consumption habits, in particular by reference to an identifier, location data, an online identifier, etc.
- Person concerned : an individual about whom Personal Data is processed and who can be identified or identifiable, directly or indirectly, thanks to his Personal Data.
- Data controller : natural or legal person who, individually or jointly, decides on the purposes and means for which Personal Data is collected and processed.
- Treatment : any operation or set of operations carried out or not carried out using automated processes and applied to Personal Data such as collection, access, registration, copying, transfer, conservation, storage, crossing, modification, structuring, structuring, structuring, structuring, structuring, structuring, providing, making available, providing, providing, providing, communicating, recording, destroying, whether automatically, semi-automatically or otherwise, this list is not exhaustive.
2. Data controllers
As part of your browsing and your interaction with the contact form on the site http://www.florac.eu/fr/, the companies Caille and Florac Investissements collect Personal Data about you.
As part of investment transactions, in particular real estate, equity investments and financial investments made by Florac Group companies, they may be required to process certain Personal Data concerning you. For this Processing of Personal Data, and within the framework of their respective activities, each of the companies of the Florac Group is Data Controller, namely:
- Florac, a simplified joint stock company, whose head office is located at 16 avenue Robert Schuman 75007 Paris, registered with the Paris Trade and Companies Register under number 500 808 761;
- Florac Investissements, a simplified joint stock company whose head office is located at 16 Avenue Robert Schuman, 75007 Paris - France, registered with the Paris Trade and Companies Register under number 823 269 477;
- Florac Investissements 2, a simplified joint stock company whose head office is located at 16 avenue Robert Schuman 75007 Paris, registered in the Trade and Companies Register under number 900 394 859;
- Caille, a simplified joint stock company whose head office is located at 16 avenue Robert Schuman 75007 Paris, registered with the Trade and Companies Register under number 498 295 021;
- MJLD, a simplified joint stock company whose head office is located at 16 avenue Robert Schuman 75007 Paris, registered with the Trade and Companies Register under number 517 959 144.
3. What Personal Data is collected?
The Personal Data processed about you varies according to the context in which your Personal Data is collected:
- Personal Data concerning you collected directly from you as part of your browsing or your interaction with the contact/recruitment form on the website http://www.florac.eu/fr/:
- Identity data : name, first name, company, email address, message.
- Navigation data : IP address, information relating to your browsing.
- Personal Data concerning you collected from third parties in the context of investment transactions, in particular real estate, equity investments and financial investments made by Florac Group companies:
- Identity data : name, first name, company, email address, identity document.
4. Why is your Personal Data collected?
We collect your Personal Data for specific purposes and on various legal grounds.
- As part of your navigation and your interaction with the contact form on the website http://www.florac.eu/fr/, the companies Caille and Florac Investissements process your Personal Data to facilitate your consultation of the website and to allow you to contact the company, in particular in the context of the recruitment of interns and employees by certain companies of the Florac Group. These Treatments are implemented to satisfy the legitimate interest of certain companies of the Florac Group in offering quality services, a simple and direct point of contact to users of its website and also to allow contact to be made in the context of a potential internship or job.
- In the context of investment transactions, in particular real estate, equity investments and financial investments made by Florac Group companies, they may be required to process Personal Data concerning you (in your capacity as employee, manager, client, service provider), in order to carry out verifications, Due Diligence and audits. These Treatments are implemented to satisfy the legitimate interest of Florac Group companies who wish to have a good knowledge of the companies with which they wish to proceed and/or make investments, participations or financial investments.
- As part of their activities, Florac Group companies can also carry out communication operations and organize events, and process your Personal Data to invite you there, in order to promote their activities, which is in their legitimate interest.
5. Is your Personal Data shared?
Your Data is processed primarily by the employees of the Data Controller identified in section 2 of the Policy, only if such Processing is necessary for the execution of their mission and in any event within the limits of their respective responsibilities.
Your Data may be transmitted to the following recipients:
- Florac Group entities in the context of an outsourcing of activity to another entity of the group;
- Service providers and subcontractors who are used in particular for the maintenance of IT tools or for the conduct of audits carried out in the context of investment transactions;
duly authorized public authorities (judicial, supervisory, etc.), within the framework of legal and regulatory obligations;
- Regulated professions (lawyers, bailiffs, etc...) who can intervene in the context of the implementation of guarantees, recovery or litigation.
6. Is your Personal Data transferred to countries located outside the European Economic Area?
We strive to keep your Personal Data within the European Economic Area (EEA).
However, it is possible that the Data that we collect when you use our website or in the course of our activities may be transferred to other countries located outside the EEA.
In the event of a transfer of this type, it will be carried out:
- To a country that provides an adequate level of protection, i.e. a level of protection equivalent to what European regulations require;
- In the framework of standard contractual clauses;
- Within the framework of internal corporate rules.
7. How long is your Personal Data stored for?
We keep your Personal Data only for as long as necessary to fulfill the purpose for which we hold the Data, or to fulfill our legal obligations.
Retention periods vary depending on several factors, such as:
- contractual requirements;
- legal obligations;
- Our proportionality analysis relating to our legitimate interests;
- The recommendations of the supervisory authorities.
8. What are your rights?
You have the following rights over your Personal Data:
- Right of access : the right to obtain a copy of the Personal Data that the Data Controller has about you.
- Right to rectification : the right to have Personal Data concerning you rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.
- Right to limitation of processing : the right, under certain conditions, to request that the Processing of Personal Data be temporarily suspended.
- Right to erasure : the right, under certain conditions, to have the Data erased or deleted.
- Right to object : the right to object to the Processing of your Personal Data, under certain conditions.
- Right to define post-mortem guidelines : when Personal Data has been collected from you, the right for the requester to define guidelines relating to the fate of the Personal Data after death.
To exercise your rights, you can contact the Data Protection Officer (DPO): dpo@florac.eu.
When you send us a request to exercise your right, you are asked to specify as much as possible the scope of the request, the type of right exercised, the Personal Data Processing concerned, and any other useful element, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to provide proof of your identity.
You also have the right to contact the Commission Nationale de l'Informatique et des Libertés http://www.cnil.fr/plaintes in the event of difficulties related to the management of your Personal Data by Florac Group companies.
9. Updating this Policy
The Florac Group reserves the right to make changes to this Privacy Policy at any time.
10. Language
This Privacy Policy is written in French.
In the event that it is translated into one or more foreign languages, only the French version will prevail in the event of a dispute.
