2. Credit

2.1 This document was created using a template from Docular.net.

3. The personal data that we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process.

3.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

3.3 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). Transaction data may include your name, contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

3.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Operations. We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3 Publications. We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is legitimate interests, namely publishing content in the ordinary course of our operations.

4.4 Relationships and communications. We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

4.5 Direct marketing. We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.

4.6 Record keeping. We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.7 Security. We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.8 Insurance and risk management. We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.9 Legal claims. We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this process is legitimate interests, namely protecting and asserting our legal rights, your legal rights and the legal rights of others.

4.10 Legal compliance and vital interests. We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2 We store your personal data held in our website database on the servers of our hosting services providers.

5.3 We may disclose personal data to our suppliers or subcontractors identified as https://robsmith-it.com/ insofar as is reasonably necessary for the proper administration and security of our website.

5.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under EU data protection law.

6.2 The hosting facilities for our website are situated in France. Transfers of data to this country are protected by appropriate safeguards and the use of standard data protection clauses. More details can obtain from Commission Nationale de l’Informatique et des Libertés.

6.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum of 12 months following the date of the most recent contact between you and us,. It will be stored for a maximum period of 12 months following that date;

(b) account data will be retained for a minimum period of 12 months following the date of closure of the relevant account. It will be stored for a maximum period of 12 months following that date;

(c) transaction data will be retained for a minimum period of 12 months following the date of the transaction. It will be stored for a maximum period of 12 months following that date;

(d) communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 1 month following that date.

7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Your rights

8.1 In this Section 8, we have listed the rights that you have under EU data protection law.

8.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask us to erase your personal data;

(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask us to transfer your personal data to another organisation or you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) right to withdraw consent – if the legal basis of our processing of your personal data is consent, you can withdraw consent.

8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and   https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles]

8.4 You may exercise any of your rights in relation to your personal data by using the contact details below.

9. About cookies

9.1 A cookie is a file containing an identifier sent by a web server to a web browser. The cookie is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies. Persistent cookies are stored by a web browser and remain valid until the expiry date, unless deleted manually before then. A session cookie will expire at the end of the user session, when the web browser is closed.

9.3 Cookies may not contain any information that personally identifies a user. However, personal data that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 Full details about the cookies we use on our website are available in our Cookie Policy

11. Cookies used by our service providers

11.1 Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

12.2 Blocking all cookies may have a negative impact upon the usability of many websites.

12.3 If you block cookies, you may not be able to use all the features on our website.

13. Other Information We Collect and Use

CCTV Surveillance in Communal Areas

13.1 We use CCTV cameras in communal areas of our premises to enhance the safety and security of all residents, visitors, and staff.

13.2 The operation of these cameras is in accordance with EU data protection laws (including the GDPR). Footage is processed only for legitimate security purposes.

13.3 We do not install CCTV cameras in private areas (such as bathrooms or bedrooms).

13.4 All footage is stored securely and retained for no longer than 14 days. Access to CCTV footage is strictly limited to authorised personnel.

13.5 Information about how we use CCTV, and your rights concerning this data, is available in our CCTV & Security Camera Policy.

14. Amendments

14.1 This privacy policy may be updated from time to time and a new version published on our website.

14.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

15. Our details

15.1 Website owned and operated by La Nef Fontainebleau

15.2 Address is : La Nef Residence, 1 rue du Sergent Perrier, 77300 Fontainebleau.

15.3 You can contact us:

• using our website contact form;
• by telephone, on the contact number published on our website; or
• by email, using the email address published on our website.