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Personal data policy

 
INTRODUCTION Praemia REIM (hereinafter referred to as Praemia REIM) and all its subsidiaries (hereinafter referred to as the Praemia REIM group) place a high importance on privacy protection and ensure the protection of your personal data. The Praemia REIM group is subject to applicable data protection regulations, particularly the European General Data Protection Regulation No. 2016/679 of April 27, 2016 (known as "GDPR"), and all national laws enacted in its implementation, as a subsidiary matter.
This document clearly and simply reflects and describes our policy on the matter and informs you of the conditions under which Praemia REIM, in its capacity as data controller, collects and uses your personal data in accordance with data protection principles, and the means you have to control this use and exercise your related rights.
DEFINITIONS
  • Personal Data: any information or data relating to an identified or identifiable natural person (e.g., name, address, phone number, photograph, date of birth, IP address, etc.).
  • Cookie and Tracker: a data block not used for identification purposes but to record information related to the client's browsing within the service. Cookies and trackers aim to collect information about your browsing on the sites. These files store information to facilitate your browsing, adapt your content, and optimize certain functionalities.
  • Processor: the natural or legal person, public authority, service, or other body that processes personal data on behalf of the data controller.
  • Processing: any operation or set of operations performed on personal data, whether or not by automated means (collection, recording, organization, storage, modification, alignment, retrieval, consultation, extraction, use, availability, alignment, combination, as well as blocking, erasure, or destruction of such personal data).
DATA CONTROLLER Praemia REIM is the entity that determines the means and purposes of collecting and using personal data and therefore acts as the data controller.
PERSONAL DATA In strict compliance with the regulations in force, we primarily process the following personal data:
  • Declarative data: collected directly from you or from partners with whom we have a contractual relationship;
  • Personal data generated during the use of online services/website;
  • Personal data related to the identification of individuals.
WHY DO WE COLLECT YOUR PERSONAL DATA? The personal data collected and processed by Praemia REIM are used in accordance with the principle of data minimization, limiting the collection of personal data to only the purposes defined below:
  • Managing requests via the contact form;
  • Operations related to commercial management and the implementation of marketing actions.
In the context of our business relationship and subject to obtaining your express consent, your personal data may also be used for products or services distributed by companies of the Praemia REIM group and its business partners. Praemia REIM only implements processing if at least one of the following conditions is met:
  • Consent has been obtained,
  • The legitimate interest of Praemia REIM justifies the implementation of the concerned personal data processing,
  • The execution of a contract binding you to Praemia REIM requires the implementation of the concerned personal data processing.
WHO ARE THE RECIPIENTS OF THE PERSONAL DATA PROCESSED BY THE Praemia REIM GROUP? The personal data collected by Praemia REIM, as well as those collected subsequently, are intended for Praemia REIM in its capacity as data controller. Praemia REIM ensures that only authorized persons have access to this data. Praemia REIM's service providers may be recipients of this data to perform the services that Praemia REIM entrusts to them. Some personal data may be sent to third parties (business partners) or legally authorized authorities to meet Praemia REIM's legal, regulatory, or contractual obligations.
Personal data may be combined, pooled, or shared among all entities of the Praemia REIM group. Moreover, Praemia REIM takes appropriate measures to ensure that our processors process your personal data in accordance with the data protection legislation in force.
If your personal data are transferred to countries outside the European Economic Area (EEA), the Praemia REIM group will ensure the following guarantees: WHAT SECURITY MEASURES ARE IMPLEMENTED BY THE Praemia REIM GROUP? Regulations require us to ensure a level of security and confidentiality of your personal data. In this regard, we consider the collected data about you as confidential information falling under professional secrecy to which we are subject. This data may be transmitted, exploited, or stored according to the security framework described below:
Praemia REIM implements and maintains a series of logical, organizational, and physical security measures on its IT environments to maintain the security of the data stored in its information system. We subscribe to a Cyber Threat Intelligence (CTI) service and regularly conduct a series of tests on our websites and web-exposed applications to correct any identified vulnerabilities and flaws. We comply with best practices in information system security regarding backups, data access, and incident response.
Praemia REIM ensures that its processors and service providers implement and maintain a security system compliant with the GDPR.
If we detect an incident impacting personal data, we ensure, as required by regulations, to notify the French Data Protection Authority (CNIL) as soon as possible after becoming aware of it and to inform the concerned individuals.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA? We have established a data retention policy to ensure that your personal data are kept only for a duration not exceeding what is necessary for the purposes for which they are processed. To determine these durations, we consider the various purposes for which these data are collected, the individuals concerned by the collection, compliance with legal, regulatory, or professional obligations to which we are subject.
YOUR RIGHTS
WHAT ARE YOUR RIGHTS? In accordance with the applicable data protection legislation, you have the rights of access, rectification, and erasure of your personal data, the rights to object to or restrict the processing of your personal data, the right to data portability, the right not to be subject to automated processing, and the right to set guidelines for the handling of your personal data after your death.
  • Right to be informed: You have the right to obtain clear, transparent, and understandable information about how we use your personal data and about exercising your rights.
  • Right of access and rectification: At any time, you can request access to your personal data and their rectification if they are inaccurate or incomplete.
  • Right to erasure: You have the right to obtain the erasure of your personal data. However, the right to erasure (or "right to be forgotten") is not absolute and is subject to specific conditions. Therefore, we may retain your personal data as permitted by applicable law, particularly when their processing is necessary for compliance with a legal obligation to which the Praemia REIM group is subject or for the establishment, exercise, or defense of legal claims.
  • Right to restrict processing: You have the right to obtain the restriction of processing, in certain circumstances. In this case, the data may only be processed, except for storage, with your consent or for the establishment, exercise, or defense of legal claims.
  • Right to data portability: You have the right, in certain circumstances, to receive the personal data concerning you that you have provided to the Praemia REIM group in a structured, commonly used, and machine-readable format and to transmit them to another data controller.
  • Right to object to processing: You have the right to object, on legitimate grounds, to certain types of processing.
  • Right to withdraw consent: If you have given your consent to the processing of your personal data, you have the right to withdraw it at any time.
  • Right not to be subject to automated processing: You have the right not to be subject to a decision based solely on automated processing (often based on profiling) that has legal effects or significantly affects you.
  • Right to set guidelines for the handling of your data after your death: You can define guidelines for the storage, erasure, and communication of your personal data after your death. These guidelines can be general or specific. General guidelines are registered with a trusted third party. Specific guidelines are registered with the data controller.
MANAGING COOKIES AND TRACKERS
WHY DO WE USE COOKIES AND TRACKERS? When browsing our sites, information may be recorded in "Cookies" or trackers installed by us. A cookie is a small file placed on your computer, tablet, or smartphone when you browse a website. It aims to collect information about your browsing on the sites. These files store information to facilitate your browsing, adapt your content, and optimize certain functionalities. They allow us to collect usage data such as your IP address, keywords used, origin or duration of the visit.
THE DIFFERENT TYPES OF COOKIES
  • Cookies not requiring consent:
    • Essential functional cookies: enable site navigation and use of functionalities, and secure your connection.
    • General audience measurement cookies: exempt from consent and allow for the production of anonymous statistics.
  • Cookies requiring consent:
    • Audience measurement cookies: measure the performance of our site (number of visits, origin of visits, visitor profile, etc.) and optimize your customer experience. We also inform you about the existence of an opt-out system for Google Analytics tracking. For more information, please consult Google's web page. The maximum retention period for these cookies is 13 months.
    • Advertising cookies: allow Praemia REIM and its partners to offer and tailor the advertising you see on our sites to your user profile.
HOW TO CONFIGURE YOUR COOKIES?
As indicated by the CNIL, you must consent by a clear positive act, freely, specifically, and informed, to the use of cookies. You can accept or reject the recording of cookies and trackers by selecting the desired settings through our preference center, which allows you to modify the default setting or get more details on each type of cookie or tracker. Upon connecting to our sites, a banner appears with the following message: "Cookies allow us to personalize content and ads, provide social media features, and analyze our traffic. We also share information about your use of our site with our social media, advertising, and analytics partners, who may combine it with other information you have provided to them or that they have collected from your use of their services (refuse all, validate the selected choice, accept all)." Your cookie preferences are recorded for a duration of 6 months.
You also have different means to manage cookies:
  • Configure your internet browser to periodically prompt you to accept or reject cookies before a cookie may be stored on your device.
  • Configure your internet browser to systematically save or reject certain cookies based on their issuer.
For more information, you can visit the CNIL website at: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
CONTACT US
For any questions regarding the processing of your personal data by Praemia REIM, please contact the Data Protection Officer by email at dpo@praemiareim.com or by mail at: Data Protection Officer, Praemia REIM, 10 rue du Général Foy, 75008 Paris.
You may also file a complaint with the competent supervisory authority. In France, this is the CNIL (Commission Nationale de l'Informatique et des Libertés).
We may modify this Personal Data Policy to reflect changes in our practices or to clarify them, and to ensure compliance with regulations.
Updated version as of July 1, 2024.