Please find below our policy for processing personal data (“Data”).
This Policy aims to provide you with further information in connection with our commitment to protecting your Data, whether you are a customer, partner, supplier, shareholder or more generally a contact of any GECINA Group company.
This policy is part of an approach to ensure transparency and fair treatment. It describes the way we collect, use and manage your personal data, and presents your rights, as well as the way we ensure compliance with our legal obligations.
It is intended to supplement the information that we provide you with, particularly in relation to any contracts entered into with you. If there are any contradictions between the terms of this policy and any contractual stipulations, the latter will take precedence.
The GECINA Group companies process your Data in accordance with the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”) and the amended French Data Protection Act 78-17 of January 6, 1978 (“French Data Protection Act”) (collectively “the Data Protection Regulations”).
When you complete a form on one of our sites or you enter into a commercial or investment relationship with a GECINA Group company, Data may be collected by or on behalf of a GECINA Group company.
A Data Protection Officer (“DPO”) has been appointed. The DPO is authorized to handle all issues relating to the protection of personal data. If you have any questions concerning the use of your personal data, you can contact the DPO by email at email@example.com or by post at GECINA DPO, 16 rue des Capucines 75002 Paris, France.
These Data are processed exclusively with a view to responding to your requests for information and their processing is based on your consent and/or the GECINA Group’s legitimate interest.
- In order to answer our clients or potential clients demand for commercial information the GECINA Group may collect the following Data :
- These Data are processed exclusively with a view to responding to your requests for information and their processing is based on your consent
- We use the personal data to review our customers’ solvency, as well as to manage and monitor our relationships, particularly for the management of contracts, invoices and receipts, the management of complaints, the collection of unpaid invoices and the management of disputes. The data collected are essential for these processing operations.
These personal data are collected directly from you, but we may also receive data concerning you that has been collected by a third party.
- When you enter into a commercial or investment relationship (as a shareholder or buyer of one or more assets from the Group’s portfolio) with a GECINA Group company, the following Data may be collected:
These Data are processed to monitor this commercial or investment relationship.
In this context, we also collect and process:
For retailers: all Data strictly linked to commercial activities, either directly from you, or from the company that you work for.
For investors: date and place of birth, percentage of capital and voting rights held, other Data but strictly linked to the investment, either directly from you, or from the company that you work for.
For suppliers: name of the supplier’s contact person, email, phone number, position, powers, and all Data strictly linked to the provision of goods and/or services, either directly from you, or from the company that you work for.
- When you visit one of our internet sites, we collect the data transmitted to our server by your browser. During your visit of our site, only the data that are technically necessary for us to present the site to you will be collected.
Processing is carried out in the legitimate interest of improving the site’s stability and features. The data will not under any circumstances be transmitted or used for any other purpose.
We use Google Analytics to analyze our web traffic. This is a Google internet audience analysis tool that enables us to better understand our users’ behavior. This tool generates statistics concerning the use of our websites without personally identifying users.
To learn more about Google Analytics cookies, visit: https://support.google.com/analytics/answer/6004245?hl=en
We process your personal data exclusively in the cases permitted by the regulations and specifically when:
Your Data are stored for a limited period corresponding to the purposes for which they have been collected, in accordance with the regulations in force and any legal, contractual, tax and social requirements, in addition to the GECINA Group’s legitimate interests.
With regard to customers, data are stored for the duration of the contractual relationship and beyond, during three years for residential leases or five years for commercial leases or civil leases, after the end of the relationship.
With regard to data collected to deliver commercial information, it is stored as long as the customer or potential customer remains active, or for a maximum of three years after the last contact.
With regard to candidates for lettings, in cases when a lease is not signed, the information is stored for three months after being collected.
With regard to commercial or investment relationships, the personal data collected in this context are stored for the duration of the commercial or investment relationship.
With regard to data collected in response to your requests, these data are stored for the duration of the management of these requests.
With regard to cookies, the consent that you have given is valid for a maximum of 13 months.
Following the end of these periods, the corresponding data are erased or anonymized, provided that they are no longer required to apply any contracts, ensure compliance with any legal obligations or provide proof of rights and/or when there is no longer any legitimate interest in storing them.
In accordance with the Data Protection Regulations and the legal limits in force, your rights include:
- The right to access your Data, particularly to check that they are accurate and exhaustive
- The right to have your Data rectified
- The right to have your Data erased
- The right to object to or request a restriction of the processing of your Data
- The right to the portability of the Data that you have provided us with
- The right to give specific or general instructions concerning the processing of your Data following your death.
For the processing of your Data based on consent, you also have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
You can exercise these rights by emailing our DPO:
- Depending on the subject of your request:
- Or by post for the attention of: GECINA DPO, 16 rue des Capucines, 75084 Paris cedex 02, France.
Your requests will be processed as quickly as possible. Please include a photocopy of your proof of identity with your request so that we can verify your identity.
Your Data are strictly confidential and may not, without your approval, be transferred to any third parties outside of the GECINA Group for commercial and/or promotional reasons.
Some of your Data may be disclosed to our providers / subcontractors strictly in connection with our processing operations for the following purposes:
• Management of buildings, such as work carried out by a provider in our properties
• Management of pre-litigation cases and disputes: legal advisors, bailiffs, collection agencies, etc.
• Management of the investment relationship: the GECINA Group may entrust the management of the investment relationship to third-party companies, to which the Data collected as listed in point 2 may be transferred for the performance of this relationship. These companies’ servers are located in France
• Management of any documents required by the regulations, such as documents relating to supplier referencing
• Internet site administration and maintenance operations: your Data collected using online forms may be transferred to our provider for maintenance and administration operations. The servers are located in France.
• Legal reasons: your Data may be disclosed following legal requests from relevant authorities in this area.
Your Data are processed, most of the time, within the European Union and are not, where possible, transferred to third countries.
However, in connection with the GECINA Group’s processing operations and purposes, as described previously, if your Data are transferred to third countries, the GECINA Group undertakes to take all adequate and appropriate measures, in accordance with the Personal Data Protection Regulations, to ensure that the level of protection that you are guaranteed with these Regulations is not compromised.
To manage the internet sites effectively, Google Analytics may be used and may process your data in the United States of America. Google Analytics adheres to Privacy Shield, which can be consulted at https://www.privacyshield.gov/list, which ensures the security of your data.
We will publish any changes on this page and at the places we consider appropriate depending on the area concerned and the significance of the changes made.
You can submit complaints to the French Data Protection Agency (CNIL), which is the regulatory authority responsible for ensuring compliance with the Personal Data Protection Regulations in France, directly online at https://www.cnil.fr/fr/agir or by post at Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy - TSA 80715, 75334 Paris Cedex 07, France.