GDPR
INTRODUCTION
In accordance with French Law No. 78-17 of January 6, 1978, as amended, and Regulation (EU) No. 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter jointly referred to as the “Regulation”), SAS BO-HOUSE acts as the data controller (hereinafter referred to as “Bo-House” or “we”) and places great importance on the protection and respect of your privacy.
This Privacy Policy (hereinafter referred to as the “Policy”) is intended to inform you of our practices regarding the collection, use, and sharing of information that you may provide to us through our website (hereinafter the “Site”) and within our agencies. The purpose of this Policy is 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 concerning your personal data in accordance with the applicable regulations.
Definition
Client: Any professional, legally capable individual as defined by Articles 1123 and following of the French Civil Code, or any legal entity, who visits the Site covered by these general terms and conditions. Services: https://bo-house.com provides the following to its Clients: Content: All elements constituting the information available on the Site, including text, images, and videos. Client Information: Hereinafter referred to as ���Information(s),” meaning all personal data that may be held by https://bo-house.com for the purposes of managing your account, customer relations, and for analytical and statistical purposes. User: Any internet user accessing and using the aforementioned Site. Personal Information: "Any information which, in any form whatsoever, directly or indirectly, identifies a natural person to whom it applies" (Article 4 of French Law No. 78-17 of January 6, 1978).
The terms “personal data,” “data subject,” “processor,” and “sensitive data” have the meanings defined under the General Data Protection Regulation (GDPR: No. 2016-679).
Presentation du site internet
In accordance with Article 6 of French Law No. 2004-575 of June 21, 2004 on confidence in the digital economy, users of the website https://bo-house.com are hereby informed of the identity of the various parties involved in its creation and maintenance: Owner: SAS BO-HOUSE – Share capital: €10,000 – VAT number: FR60828073593 – 4 Rue du Parc des Lices, 83990 Saint-Tropez Publication Director: Early – hello@earlyonline.fr
The publication director may be either a natural or legal person. Webmaster: Jen Yuan – jen@view-source.com Hosting Provider: OVH – 2 rue Kellermann, 59100 Roubaix, France Data Protection Officer: Fabien Dubois de Labarre – fabio@bo-house.com Purpose of the collection and use of your data / Why does Bo-House process your data? Bo-House collects and processes personal data for the following purposes:
Management of relationships with clients and prospects: the information concerning you allows us, in particular, to get to know you, establish a personalized relationship, follow up on your requests and provide you with the expected services
Management of real estate transactions: the information you provide allows us to establish a mandate, fulfill our obligations as agents and comply with the requirements of such real estate operations
Management and follow-up of requests for information about our services: You have the possibility to contact us through different channels to request information about the services offered. We collect and use certain data in order to manage and respond to these requests
Management of rental and real estate valuations: We offer to estimate the rental value of your property in the event of a rental, or to estimate the market value of your property in case of sale
Improvement of the quality of our services: We use your personal data to implement and develop our services, including for the personalization of commercial offers proposed by Bo-House
Human resources management: You have the possibility 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 the fight against money laundering and the financing of terrorism
Understand your behavior, preferences and thus respond to your needs and expectations: Based on your consent, we use data relating to how you use our website and social networks, in particular to:
Understand your behavior and preferences, such as how you search for and find our services, understand 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, as well as on our social media, and your interactions with our advertisements, particularly sponsored links on partner websites, we proceed to scoring and profiling. This analysis allows us to distinguish occasional visitors from those showing a stronger interest in our services, in order to better tailor our communications and offers.
As part of these purposes, Bo-House only processes data that is relevant and necessary for the objective pursued. What data is processed? By using our website or during your visits to our agency, you may provide us with information, some of which may identify you and therefore constitute personal data within the meaning of the GDPR (hereinafter referred to as “data”). This is particularly the case when you wish to:
Contact us for any request, and in particular to learn more about our activities
Subscribe to one of our services
Receive communications
Register for services accessible online (e.g. creation of a client account (owner), management of favorites and alerts)
Receive our newsletters
Participate in our contests and other promotional operations
Request a property valuation
Entrust the management of a property
Contact our agency
Share a property listing with a third party
Give a review of our services
Work at Bo-House
The personal data collected by Bo-House is grouped into the following categories:
Data categories: Main data processed
Civil status: Last name, first name, gender, place and date of birth, nationality
Contact details: Postal or email address, landline or mobile phone numbers
Personal life: Family situation
Professional life: Current position, industry, CV, education, professional training, distinctions, etc.
Personal characteristics: Legal protection measures, power of attorney, and signature
Identification data: Client identification number, user ID
Connection and browsing data: Date and time of connection and/or browsing, browser type, browser language, IP address
Economic and financial data: Financial identification, economic, tax and accounting data, payment history
Data related to client expectations: Data regarding the client’s expectations for the requested services (examples: property search criteria or destination preferences)
Data related to property ownership: Address, property description, required diagnostics, property and rental values
Profile, scores and client segmentation: Marketing score and segmentation, client satisfaction indicator
During data collection, you will be informed whether some of the data must be provided or whether it is optional. Bo-House uses personal data solely for the purposes for which it was collected. We are committed not to sell, exchange or transfer your data to third parties without the explicit consent of the individuals concerned, except in cases where the law requires it. How long do we retain your data? Bo-House retains personal data only as long as necessary to fulfill the purposes for which it was collected, in accordance with legal retention periods and best practices in the real estate sector. Your data is not retained beyond the strictly necessary period for the pursued purposes as stated in this Policy, and in accordance with applicable regulations. For example, data used to respond to your requests is kept for the time necessary to process your request, then archived in accordance with applicable legal prescription periods. Data used to provide you with the requested service is kept for the duration of the contractual relationship, then archived for five (5) years. Data used for commercial prospecting is retained for three (3) years from the last contact with the prospect or client. Data collected for verification purposes, as part of anti-money laundering and anti-terrorism efforts, is retained for ten (10) years from the end of each real estate transaction. Data used for recruitment purposes is retained for two (2) years from the last contact with the non-recruited candidate, unless longer retention is consented to. Technical data used for site management and to better understand your behavior and preferences is retained for thirteen (13) months from your consent. Your data is deleted when the retention period expires. However, your data may be archived beyond the defined durations for the purposes of research, legal claims or prosecution of criminal offenses, and may be made available to judicial authorities. Archiving means your data will no longer be available online but will be extracted and securely stored on an independent medium. Are your data transferred, how and where? Secure hosting within the European Union: We inform you that your personal data is primarily hosted securely on data centers located within the European Union. This location ensures a level of protection and security in line with EU regulatory requirements. In some circumstances, Bo-House may transfer personal data outside of the European Economic Area (EEA). In such cases, we will ensure these transfers are carried out in accordance with legal requirements, with appropriate safeguards to protect confidentiality and security of personal data. Use of third-party communication services and transfers outside the EU: If you choose to use third-party communication services such as WhatsApp to exchange with us, please note that communications may be subject to the data processing practices of the third-party provider. In the case of WhatsApp, a subsidiary of the U.S.-based Meta Platforms, Inc., this means your messages may be collected and processed by Meta and may be subject to data transfers to the United States. On July 10, the European Commission ruled that the United States ensures a level of data protection equivalent to that of the European Union. Personal data transfers from the EU to certain U.S. organizations can now be made freely, without specific safeguards. Who are the data recipients? Collected data is intended for Bo-House’s commercial, technical and administrative teams and service providers. As part of legal procedures, processed data may also be disclosed to competent authorities. Data security Bo-House implements appropriate technical and organizational measures to ensure the security and confidentiality of personal data, especially to prevent unauthorized access, modification, disclosure or destruction. Confidentiality and employee training Bo-House commits to ensuring the confidentiality of personal data by requiring that all employees and partners with access to personal data sign a confidentiality agreement. Access to personal data is restricted to those needing it to perform their professional duties. 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. These are stored in “cookies” installed on your device. These data allow us to improve user experience, analyze website usage and personalize content and ads. Users can control cookie use by modifying their browser settings. For more information about our cookie use, please refer to our Cookie Policy. Links to third-party websites Our website may contain links to third-party sites. Bo-House is not responsible for the privacy and data protection practices of those third-party sites. We encourage users to review the privacy policies of any such websites before providing personal data. This location ensures a level of data protection and security in line with the Union's regulatory requirements. In certain circumstances, Bo-House may transfer personal data outside the European Economic Area (EEA). In such cases, we will ensure that transfers are carried out in accordance with legal requirements, implementing appropriate safeguards to protect the confidentiality and security of personal data. Use of third-party communication services and transfers outside the EU: Additionally, 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 may be subject to a data transfer to the United States. On July 10, the European Commission ruled that the United States ensures a level of personal data protection equivalent to that of the European Union. Personal data transfers from the EU to certain U.S. entities can now be made freely, without specific safeguards. Who are the data recipients? The data collected is intended for Bo-House's commercial, technical and administrative teams, as well as its service providers. In the context of legal proceedings, the processed data may also be disclosed to competent authorities. Data security Bo-House implements appropriate technical and organizational measures to ensure the security and confidentiality of personal data, particularly to protect against unauthorized access, modification, disclosure or destruction. Confidentiality and employee training Bo-House is committed to guaranteeing the confidentiality of personal data by ensuring that all employees and partners comply with the principles and obligations set out in this Data Protection Policy. Employees and partners with access to personal data are required to sign a confidentiality agreement committing them to respect the confidentiality and security of the data. Restricted access to data Access to personal data is limited to Bo-House employees and partners who need it to perform their professional duties. Bo-House has implemented access controls to ensure that only authorized persons can access personal data. 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 is recorded 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 changing their browser settings. For more information on our use of cookies, please see our Cookie Policy. Links to third-party sites Our website may contain links to third-party websites. Bo-House is not responsible for the privacy and data protection practices of these third-party sites. Users are encouraged to review the privacy policies of third-party sites before providing personal data. Rights of data subjects Individuals whose personal data is processed by Bo-House have various rights under applicable regulations, including the right of access, rectification, deletion, restriction of processing, data portability, and the right to object to processing. To exercise these rights, data subjects may contact us at the following email address: info@bo-house.com Right of access, rectification, and objection In accordance with current European regulations, users of https://bo-house.com have the following rights: right of access (Article 15 GDPR) and rectification (Article 16 GDPR), the right to update or complete user data, the right to block or delete personal data (Article 17 GDPR) when it is inaccurate, incomplete, ambiguous, outdated, or when its collection, use, communication or retention is prohibited, the right to withdraw consent at any time (Article 13-2c GDPR), the right to limit the processing of user data (Article 18 GDPR), the right to object to the processing of user data (Article 21 GDPR), the right to data portability for the data users have provided, when the data is subject to automated processing based on consent or a contract (Article 20 GDPR), the right to define what happens to the user’s data after death and to choose whether https://bo-house.com should share this data with a third party previously designated by the user. As soon as https://bo-house.com becomes aware of a user’s death and in the absence of instructions, https://bo-house.com undertakes to delete the data, unless its retention is necessary for probative purposes or to fulfill a legal obligation. If the User wishes to understand how https://bo-house.com uses their personal data, requests rectification, or objects to their processing, the User may contact https://bo-house.com in writing at the following address: BO-HOUSE – DPO, Antony Tardieu, 4 Rue du Parc des Lices, 83990 Saint-Tropez. In such case, the User must specify which personal data they would like https://bo-house.com to correct, update or delete, and must identify themselves precisely by including a copy of an identity document (ID card or passport). Complaints If, after contacting us, you still believe your rights are not being respected, you may lodge a complaint with a competent European supervisory authority: the Commission Nationale de l’Informatique et des Libertes (CNIL) for France. Requests for deletion of personal data will be subject to legal obligations imposed on https://bo-house.com, particularly regarding document retention or archiving. Finally, users of https://bo-house.com can file a complaint with supervisory authorities, including the CNIL (https://www.cnil.fr/fr/plaintes). Changes to the data protection policy Bo-House reserves the right to change this Data Protection Policy at any time. The changes will be published on our website and, where appropriate, communicated to the persons concerned. info@bo-house.com If you have any questions about this Data Protection Policy, please contact us at the following email address: info@bo-house.com Consent By providing personal data to Bo-House, the persons 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 receiving marketing communications. Cookie policy Bo-House integrates third-party computer applications to enhance the functionality and experience of the user. Some applications issue their own cookies. However, the issuance and use of cookies by third parties are subject to the privacy policies of those third parties. When you arrive on the Bo-House website, you are notified by a banner that we collect cookies subject to your choices. Our cookie policy allows you to better understand how they work. info@bo-house.com These are text files added to a user's browser during their visit to websites. They ensure proper functioning, improve navigation and provide certain information to the owners of these sites. This information therefore enables Bo-House to improve the performance of the website and offer users content tailored to their interests. However, the information collected through cookies does not allow us to identify individual users or send them advertising messages by email or post. What types of cookies are used on our website? When you arrive on the website, a banner appears stating that the website uses cookies. Via this banner, you can choose to accept cookies. There are two different types of cookie issuers: Internal cookies, known as ‘first party’ cookies, are those placed by the website visited by the user, more specifically on the website's domain. Third-party cookies are those placed on domains other than the main website and managed by third parties. They allow third parties to see which pages have been visited on the website in question by a user and to collect information about them, in particular for advertising purposes. As such, Bo-House has no control over the use of cookies by third parties. Bo-House only uses cookies for three main purposes: 1 Necessary: these help to make the website usable by enabling basic functions such as page navigation and access to secure areas of the site. The site cannot function properly without these cookies. Bo-House does not transfer any of this data to third parties, does not reuse it for other purposes, does not cross-reference it with other processing, including customer files, and does not store it in any way for longer than 13 months. 2 Statistics: these help website owners, through the collection and communication of anonymous information, to understand how visitors interact with the website. 3 Marketing: these allow visitors to be tracked across the website. The aim is to display advertisements that are relevant and interesting to the individual user and therefore more valuable to publishers and third-party advertisers.
Personal Data Management
The Client is informed of the regulations concerning marketing communication, including the Law of June 21, 2014 for Confidence in the Digital Economy, the French Data Protection Act of August 6, 2004, as well as the General Data Protection Regulation (GDPR: No. 2016-679).
Data Controllers
For the Personal Data collected as part of the creation of the User’s personal account and their navigation on the Site, the data controller is: BO-HOUSE.
https://bo-house.com is represented by Mr. Antony TARDIEU, its legal representative. As the data controller of the information it collects, https://bo-house.com undertakes to comply with the legal framework in force. In particular, it is the responsibility of the Client to define the purposes of the data processing, to provide prospects and clients—based on their consent—with comprehensive information on the processing of their personal data, and to maintain a register of processing activities that reflects reality. Each time https://bo-house.com processes Personal Data, it takes all reasonable steps to ensure the accuracy and relevance of the Personal Data with regard to the purposes for which it is processed.
Purpose of the Data Collected
https://bo-house.com may process all or part of the data:
to enable navigation on the Site and the management and traceability of services and orders requested by the user: connection and usage data, billing, order history, etc.
to prevent and combat computer fraud (spamming, hacking, etc.): equipment used for browsing, IP address, password (hashed)
to improve browsing on the Site: connection and usage data
to conduct optional satisfaction surveys on https://bo-house.com: email address
to carry out communication campaigns (SMS, email): phone number, email address
https://bo-house.com does not sell your personal data, which is therefore only used when necessary or for statistical and analytical purposes.
Non-communication of Personal Data
https://bo-house.com undertakes not to process, host, or transfer the Information collected from its Clients to a country located outside the European Union or recognized as “not adequate” by the European Commission without first informing the client. However, https://bo-house.com remains free to choose its technical and commercial subcontractors, provided that they offer sufficient guarantees in accordance with the requirements of the General Data Protection Regulation (GDPR: No. 2016-679). https://bo-house.com undertakes to take all necessary precautions to preserve the security of the Information and, in particular, to ensure that it is not disclosed to unauthorized persons. However, if an incident affecting the integrity or confidentiality of the Client’s Information is brought to the attention of https://bo-house.com, the latter must inform the Client as soon as possible and provide the corrective measures taken. Furthermore, https://bo-house.com does not collect any “sensitive data.” The User’s Personal Data may be processed by subsidiaries of https://bo-house.com and by subcontractors (service providers), exclusively for the purposes outlined in this policy. Within the limits of their respective roles and for the purposes mentioned above, the main individuals likely to have access to the data of Users of https://bo-house.com are primarily members of our customer service team. Last updated: 20/03/2024
In the event of any discrepancies between the French version and any translated version of this policy, the French version shall prevail. If you have any questions, you can contact us at the following email address: info@bo-house.com