1. INTRODUCTION

In accordance with Law No. 78-17 of January 6, 1978, as amended, and Regulation No. 2016-679 of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, the “GDPR” (hereinafter collectively referred to as the “regulation”), SAS SAMAK IMO acts as the data controller (hereinafter referred to as “SAMAK IMO” or “we”) and places great importance on protecting and respecting your privacy.

This data protection policy (hereinafter referred to as “the Policy”) aims to inform you of our practices regarding the collection, use, and sharing of the information you may provide to us through our website (hereinafter referred to as the “site”), as well as through our agencies. The Policy is intended to inform you about the categories of personal data we may collect or hold about you, how we use it, with whom we share it, how we protect it, and the rights you have regarding your personal data in accordance with current regulations.

2. PURPOSES OF DATA COLLECTION AND USE / WHY DOES SAMAK IMO PROCESS YOUR DATA?

SAMAK IMO collects and processes personal data for the following purposes:

• Customer and prospect relationship management: Information about you allows us to get to know you, establish a personalized relationship, track your requests, and provide the services you expect.
• Real estate transaction management: The information you provide allows us to establish a mandate, fulfill our obligations as an agent, and meet the obligations related to such real estate operations.
• Management and follow-up of inquiries about our services: You have the option to contact us through various means to request information about the services offered. We collect and use some of your data to manage and respond to these requests.
• Management of rental and real estate appraisals: We offer to assess the rental value of your property in case of a rental or to estimate the real estate value of your property in case of sale.
• Improvement of our services: We use your personal data to implement and develop our services, including for the purpose of personalizing the commercial offers provided by Samak imo.
• Human resources management: You have the option to submit your application using our website.
• Compliance with legal and regulatory obligations: Your data may be collected to comply with legal obligations, such as anti-money laundering and counter-terrorism financing measures.
• Understanding your behavior and preferences: Based on your consent, we use data related to how you use our site and social networks, particularly to:
  • Understand your behavior and preferences, such as how you search for and find our services.
  • Determine the best ways to organize and present our offers and services on our websites and in our agencies.
• Behavioral analysis and profile qualification: Based on your browsing on our website and social networks, and your interactions with our ads, including sponsored links on partner websites, we conduct profiling and scoring. This analysis helps us distinguish occasional visitors from those with a more marked interest in our services, allowing us to tailor our communications and offers.

For these purposes, Samak imo only processes data that is relevant and necessary to achieve the intended purpose.

3. WHAT DATA IS PROCESSED?

When using our website or visiting our agencies, you may provide us with information, some of which can identify you and thus constitute personal data under the GDPR (hereinafter referred to as “data”). This includes situations where you:

• Contact us for any request, particularly to learn more about our activities.
• Subscribe to one of our services.
• Receive communications.
• Register for online services (e.g., creating a client space for owners, managing favorites and alerts).
• Receive our newsletters.
• Participate in contests and other promotional activities.
• Request a real estate appraisal.
• Entrust property management to us.
• Contact one of our agencies.
• Share a property listing with a third party.
• Provide feedback on our services.
• Apply for a job at Samak Imo.

The personal data collected by Samak Imo is grouped into the following categories:

During data collection, you will be informed if some of the data must be provided (marked with an asterisk on the collection form) or if it is optional. Failure to provide the mandatory data may limit the fulfillment of your request.

4. USE OF DATA

Samak Imo uses personal data only for the purposes for which it was collected. We commit to not selling, exchanging, or transferring data to third parties without the explicit consent of the individuals concerned, except where required by law.

5. HOW LONG DO WE RETAIN YOUR DATA?

Samak Imo will retain personal data for as long as necessary to achieve the purposes for which it was collected, in compliance with legal retention periods and best practices in the real estate sector. Your data will not be retained beyond the time strictly necessary for the purposes outlined in the Policy, and in accordance with current regulations.

In this respect, data used to respond to your request is kept for the time necessary to process your request, then archived according to the applicable legal statute of limitations. Data used to allow you to receive the requested service is retained for the duration of the contractual relationship and then archived in accordance with the statute of limitations, which is five (5) years.

Data used for commercial prospecting purposes is kept for three (3) years from the last contact with the prospect or client. Data collected for verification purposes in the context of anti-money laundering and anti-terrorist financing measures is retained for ten (10) years from the end of each real estate transaction.

Data used for recruitment purposes is kept for two (2) years from the last contact with the non-hired candidate, unless consent is given for a longer retention period. Technical data used for site management and to better understand your behavior and preferences is retained for thirteen (13) months from the user’s consent.

Your data is deleted when the retention periods expire. However, your data may be archived beyond the scheduled retention periods for the purposes of research, detection, and prosecution of criminal offenses, solely to make your data available to the judicial authorities if necessary. Archiving means that your data will no longer be available online but will be extracted and stored on a separate, secure medium.

6. ARE YOUR DATA TRANSFERRED, AND IF SO, HOW AND WHERE?

Secure hosting within the European Union:
We want to inform you that your personal data is primarily hosted securely in data centers located within the European Union. This ensures a level of protection and security that complies with the regulatory requirements of the Union.

In certain circumstances, Samak Imo may transfer personal data outside the European Economic Area (EEA). In such cases, we ensure that transfers are carried out in compliance with legal requirements by implementing appropriate safeguards to protect the confidentiality and security of personal data.

Use of Third-Party Communication Services and Transfers Outside the EU:
Moreover, if you choose to use third-party communication services, such as the WhatsApp application to communicate with us, it is important to note that these communications may be subject to the data processing practices of the third-party company providing the service. In the case of WhatsApp, a subsidiary of the American company Meta Platforms, Inc., this means that the content of your exchanges may be collected and processed by Meta and could be subject to data transfers to the United States.

As of a decision on July 10, the European Commission recognizes that the United States provides a level of personal data protection equivalent to that of the European Union. Transfers of personal data from the EU to certain U.S. organizations can now take place freely, without specific oversight.

7. WHO ARE THE RECIPIENTS OF THE DATA?

The collected data is intended for Samak Imo’s commercial, technical, and administrative teams, as well as its service providers. In the context of legal proceedings, processed data may also be transmitted to competent authorities.

8. DATA SECURITY

Samak Imo implements appropriate technical and organizational measures to ensure the security and confidentiality of personal data, particularly by protecting it against unauthorized access, modification, disclosure, or destruction.

9. EMPLOYEE CONFIDENTIALITY AND TRAINING

Samak Imo is committed to ensuring the confidentiality of personal data by ensuring that all employees and partners adhere to the principles and obligations outlined in this Data Protection Policy. To ensure compliance and raise awareness about data protection, Samak Imo provides its employees and partners with regular training on current regulations and best practices in data protection. Employees and partners with access to personal data are required to sign a confidentiality agreement, obligating them to maintain the confidentiality and security of the data.

10. RESTRICTED ACCESS TO DATA

Access to personal data is limited to Samak Imo employees and partners who need access to carry out their professional duties. Samak Imo implements access controls to ensure that only authorized individuals can access personal data.

11. USE OF COOKIES

Subject to your consent, each time you visit our website and use our online services, we collect data and information related to your browsing. This data and information are stored in “Cookies” files installed on your device. This data allows us to improve the user experience, analyze site usage, and personalize content and advertisements. Users can control the use of cookies by modifying their browser settings. For more information about our use of cookies, please consult our Cookie Policy.

12. LINKS TO THIRD-PARTY SITES

Our website may contain links to third-party websites. Samak Imo is not responsible for the privacy and data protection practices of these third-party sites. Users are encouraged to review the privacy policies of these third-party websites before providing any personal data.

13. RIGHTS OF DATA SUBJECTS

Individuals whose personal data is processed by Samak Imo have various rights under the applicable regulations, including the right to access, rectify, delete, limit processing, and the right to data portability and objection to processing. To exercise these rights, individuals may contact our Data Protection Officer (DPO) at the following email address: samakimo1850@gmail.com

14. COMPLAINTS

If, after contacting us, you believe that your rights are still not being respected, you may file a complaint with a competent European supervisory authority, such as the National Commission on Informatics and Liberty (CNIL) for France.

15. CHANGES TO THE DATA PROTECTION POLICY

Samak Imo reserves the right to modify this Data Protection Policy at any time. The changes will be posted on our website and, where applicable, communicated to the relevant individuals.

16. CONTACT

For any questions related to this Data Protection Policy, please contact our Data Protection Officer (DPO) at the following email address: samakimo1850@gmail.com

17. CONSENT

By providing personal data to Samak Imo, the individuals concerned consent to the processing of their data in accordance with this Data Protection Policy. Where applicable, explicit consent will be requested for specific processing, such as the receipt of marketing communications.

Last updated: 01/09/2024
In the event of any discrepancy between the French version and any other translated version of this policy, the French version shall prevail.