Privacy
policy

CBo Territoria and its subsidiaries (hereafter "CBo Territoria Group") recognize the importance of ensuring the security and confidentiality of the data they hold. We wish to familiarize you with the way we collect, use and share this information. This Policy describes CBo Territoria Group's privacy practices in relation to the data we collect via the websites, mobile applications, and software applications we have made available for computers or mobile devices (the "Applications"), via the social network profiles and pages we control (collectively referred to, our "Social Network Pages"), through HTML-formatted emails we send to you that link to this Privacy Policy, and through communications you exchange with us in any other manner (collectively, including websites, applications, and Social Network Pages, the "Online Services" and, together with offline channels, referred to as the "Services").

The list of CBo Territoria Group companies is available from the Data Protection Officer at the following address dpo@cboterritoria.com.

1. THE DATA COLLECTED

“Personal data" is information that identifies you as an individual or relates to an identifiable individual.

 

We may collect the following categories of personal data:

 

  • Contact and identification data: last name, first name, gender, professional and personal addresses, telephone number and e-mail address, date and place of birth, title, function, ... ;
  • Data related to your real estate project: budget, income, household composition, ... ;
  • When you call our Call Center, and on the basis of our legitimate interest in improving the quality of our services, our service provider automatically collects the following data: technical information relating to the call (date, time and duration of the call, source of the request), content of the requests, sound recording of the conversation.
 

Si vous communiquez des données personnelles appartenant à d’autres personnes au Groupe CBo Territoria ou à nos prestataires de service autorisés, vous déclarez avoir informé ces personnes des modalités de traitement de leurs données personnelles  afin de nous autoriser à traiter ces informations conformément à la présente Politique de confidentialité.

 

Nous, le Groupe CBo Territoria et nos prestataires de service, pouvons collecter des informations personnelles de diverses façons, y compris :

 

  • Via nos services en ligne (sites web, applications mobiles, réseaux sociaux, courriels…) ;
  • Via nos services hors ligne (courrier, téléphone) ;
  • Via notre Centre d’appels ;
  • Via d’autres sources : nous pouvons recevoir des données personnelles par d’autres sources, comme des bases de données publiques, nos partenaires de marketing et autres parties tierces.

 

If you communicate personal data belonging to other persons to the CBo Territoria Group or to our authorized service providers, you declare that you have informed these persons of the modalities of processing their personal data in order to authorize us to process this information in accordance with the present Privacy Policy.

 

We, CBo Territoria Group and our service providers, may collect Personal Information in various ways, including:

 

  • Through our online services (websites, mobile applications, social networks, emails...) ;
  • Through our offline services (mail, telephone);
  • Through our Call Center;
  • Through other sources: we may receive personal data from other sources, such as public databases, our marketing partners and other third parties.

2. THE USE OF YOUR DATA

We may collect and process personal data with different purposes:

 

  • To provide you with the services you have subscribed to,
  • To send you administrative information, marketing communications, invitations to events related to the group's activity and customer satisfaction surveys,
  • To improve the quality of our services, including the recording of telephone calls made and received by our Call Center. (We inform you that the recordings of telephone calls are kept by our service provider for a maximum of 6 months. The reports and analysis grids produced by the aforementioned service provider as part of the evaluation and training of its employees and in which your personal data could appear are kept for a maximum period of one year);
  • For business purposes, for example: data analysis, audits, monitoring and prevention of fraud and security, development of new products, improvement, enhancement or modification of our services, evaluation of the effectiveness of our business campaigns and operation and expansion of our business activities.
 

In general, the CBo Territoria Group does not process any of your data for purposes incompatible with those for which they were collected, except with your prior consent.

3. OTHER INFORMATION

“Other information" is personal data that does not directly reveal the identity of a natural person, for example:

 

  • Browser and device information;
  • Application usage data;
  • Information collected by cookies, web beacons and other technologies.
 

We and our third party service providers may collect other information in a variety of ways, including:

 

  • Via your browser or device: certain information is collected by most browsers or automatically via your device, such as the MAC (Media Access Control) address, type of computer (Windows or Macintosh), screen resolution, operating system name and version, device model and manufacturer, language, web browser type and version, and name and version of online services (e.g., applications) you use. We use this information to ensure that the online services function properly.
  • Using cookies: Cookies are pieces of information stored directly on the computer or mobile device you are using. They allow us to collect information such as browser type, time spent on online services, pages viewed, referring URL, language preferences and other general traffic data. We and our service providers use this information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while using the Online Services. We also collect statistical information about the use of the Online Services in order to continually improve their design and functionality, to understand how they are used, and to help us resolve questions about them.
  • Using IP Addresses: Your IP address is a number automatically assigned to the computer you are using by your Internet Service Provider (ISP). An IP address can be automatically identified and logged in your server log files when a user accesses online services along with the time of the visit and the pages viewed. The collection of IP addresses is a common practice and is performed automatically by many websites, applications and other services. For example, we use IP addresses to determine whether you are from Metropolitan France or La Réunion.
 

4. LEGAL BASIS OF THE PROCESSING OF YOUR DATA

The CBo Territoria Group collects your personal data for the purposes described in points 2 and 3 of this Policy. In all cases, we collect your data only when there is a legal basis for its collection and processing:

The execution of pre-contractual and contractual measure

Your data is necessary for the execution of the service you have subscribed to or wish to subscribe to. On this contractual legal basis, any refusal to communicate your personal data will prevent the conclusion and execution of the contract.

Legitimate interest :

The CBo Territoria Group may process your personal data for the purpose of pursuing its legitimate interest, to:

 

  • Ensure the treatment of the received requests;
  • Send you satisfaction surveys;
  • Proceed to the recording of the telephone calls;
  • Ensure the communication of our newsletters which allow us to send you administrative information and invitations to events related to the activity of the group.

Your consent :

Subject to having obtained your prior consent, CBo Territoria Group may process your data to: 

 

  • Send you our marketing communications;
  • Deposit certain cookies under the conditions described in the Policy Cookies.
 

At any time, you may revoke your choice and withdraw your consent, according to the methods described in point 6 of the present Policy, without however calling into question the legality of the processing based on the consent and implemented before the withdrawal.

5. DURATION OF CONSERVATION

Your data are kept by the CBo Territoria Group for the time necessary to achieve the purposes mentioned in points 2 and 3 hereof, plus the legal periods of limitation.

With regard to the management of requests made via our website :

The CBo Territoria Group will be able to keep the data during the time of the treatment of the request, and for a maximum of three (3) years as from your last contact with the group.

With regard to the data necessary for the management and follow-up of the commercial relationship:

The CBo Territoria Group keeps the data for the duration of the contractual relationship. After the execution of the contract, the data can also be kept in intermediate archiving, to meet accounting or fiscal obligations or for evidentiary purposes in case of litigation, within the limit of the applicable prescription period.

 

More specifically, concerning data relating to the management of real estate:

 

  • It is kept until the balance of the accounts is settled or the contractual relationship is terminated, with the exception of information required to fulfill legal obligations.
  • Information about the prospective tenant or purchaser is retained only if the rental or purchase is actually completed. In the absence of a rental or acquisition, the information is deleted if the request is not renewed within 3 months.

 

Data obtained from customer satisfaction surveys will be kept for the duration of the survey. For more information, please refer to the data collection materials.

With regard to commercial prospecting :

The data can be preserved for a duration of 3 years as from the last contact with one of the Companies of the Group. At the end of this period of three (3) years, the CBo Territoria Group can contact you again to know if you wish to continue to receive commercial solicitations.

With regard to the management of our newsletters:

Your data will be kept until you unsubscribe, or failing that, for a period of 3 years from the last contact with the Group.

 

For more information on the length of time we keep your data, you can contact our DPO (see Art. 7 of this Policy).

6. SECURITY

We seek to use reasonable administrative, technical and organizational measures to protect personal information in our organization.

 

In the event of a personal data breach, i.e., a security incident, whether malicious or not and whether intentional or unintentional, that results in the compromise of the integrity, confidentiality, or availability of your personal data, we undertake the following obligations:

FOR YOU, THE BREACH OF DATA RESULTS IN

NO RISK

NO RISK

HIGH NO RISK

Internal documentation, in the "violation record”

X

X

X

Notification to the CNIL, within 72 hours

-

X

X

We will notify you as soon as possible

-

-

X

The "Violation Record" contains the following:

 

  • The nature of the violation;
  • The categories and approximate number of individuals affected;
  • The categories and approximate number of files involved;
  • The likely consequences of the breach;
  • The measures taken to remedy the breach and, where appropriate, to limit the negative consequences of the breach;
  • Where applicable, the justification for not notifying the CNIL or informing the persons concerned.
 

However, in accordance with the regulations in force, we are not obliged to inform you of a breach in the following cases:

  • Your personal data is protected by measures that make it unintelligible to anyone who is not authorized to access it;
  • Measures have been taken so that the risk is no longer likely to occur;
  • This communication requires disproportionate efforts for us, especially since we have no means of contacting you to inform you about it.
 

Unfortunately, no data storage or transmission system can be guaranteed to be 100% secure. If you have reason to believe that your interactions with us are no longer secure (e.g., if you believe that the security of your account has been compromised), please notify us immediately in accordance with the instructions in the "What are your rights and how to exercise them?" section below.

7. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?

7.1. Your rights

In application and within the limits of the provisions of the regulations applicable to the processing of personal data, you have the following rights with regard to your data:

Right to access your data

You can obtain from each of the companies of the CBo Territoria Group, acting in the capacity of Data Controller, the confirmation that your data are or are not processed and, when they are, the access to all the data and information.

Right to correct of your data

You can obtain from each of the companies of the CBo Territoria Group, acting in the capacity of Data Controller, as soon as possible, the correction of the data concerning you which would be inaccurate or erroneous. You can also ask that your data be completed, if necessary.

Right to delete your data

Except for legal exceptions, you can ask each of the companies of the CBo Territoria Group, acting in the capacity of Data Controller, to delete your data, as soon as possible, if you consider that the processing carried out on your data is no longer necessary with regard to the purposes for which they were collected.

Right to the portability of your data

You have the possibility of recovering a part of your data in an open and machine-readable format or to ask the companies of the CBo Territoria Group, acting in the capacity of Data Controller, to transmit them to another organization. Only data that you have actively and consciously provided (for example, data that you have filled in an online form) or data generated during the use of a service or device in the context of the conclusion or management of your contract, and which are processed in an automated manner, based on consent or the execution of a contract, are concerned by this right.

Right to object

If your data is processed for prospecting purposes, you can object at any time.

 

Similarly, you may object to the distribution of targeted advertising (cookies).

 

Finally, if you do not want the calls made and received by our call center to be recorded, you can object to this recording by telling the consultant who will be handling your call.

Right to the limitation of the treatment of your dat

You can ask the companies of the CBo Territoria Group, acting in the capacity of Data Controller, to preserve your data without being able to use them, in one of the following cases:

  • You dispute the accuracy of the data used,
  • You object to your data being processed,
  • In case of unlawful use but you object to their deletion,
  • You need it for the establishment, exercise or defense of legal rights.

Right to withdraw your consent to the processing of your data

Where the processing of your personal data is based on your consent (e.g. sending our commercial offers by electronic means), you have the possibility to withdraw your consent at any time.

Right to give post-mortem instructions

You have the option of setting up instructions for the retention, deletion and disclosure of your data after your death. These directives define how you want your rights to your data to be exercised after your death. You can send us these instructions by sending a letter, with the subject line "Post-Mortem Instructions", to the following address: dpo@cboterritoria.com. You may, at any time, modify or revoke your directives.

Right to lodge a complaint with the CNIL

If you consider, after having contacted one of the companies of the CBo Territoria Group, that your rights are not respected or that the protection of your data is not ensured in accordance with the regulations applicable to the treatment and the protection of the personal data, you can, at any time, introduce a complaint to a competent control authority (in France, the CNIL), directly on the website of the CNIL or by postal way to : CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

7.2. Exercising your rights 

You can contact our Data Protection Officer by mail at the following address :

Cours de l’Usine

La Mare

CS 91005

97833 Sainte-Marie Cedex

Or by e-mail at the following address: dpo@cboterritoria.com

8. WITH WHOM DOES THE CBO TERRITORIA GROUP SHARE YOUR DATA?

Your personal data is mainly intended for the internal services of the companies of the CBo Territoria Group.

 

They may also be processed by:

  • Our subcontractors acting for the needs of the implementation of the purposes listed in point 1 of the present Privacy Policy; in this case, a contract is signed and mentions the obligations incumbent on the subcontractors in accordance with article 28 of the GDPR ;
  • Our authorized partners, if you have consented to this.
 

With regard to commercial prospecting, subject to having obtained your express consent if you are a private individual or subject to the fact that you have not exercised your right of opposition if you are a professional, your data can be transmitted to the subsidiaries of the CBo Territoria Group, the list of which is available from the DPO at the following address dpo@cboterritoria.com

9. IS YOUR DATA TRANSFERRED OUTSIDE THE EU?

The servers of the companies of the CBo Territoria Group are hosted on secured servers and located in France. If your data were to be transferred outside the EU, through our subcontractors in particular, we would take particular care to ensure that they process your data in strict compliance with the regulations in force concerning the protection of personal data.