MY LYON PROPERTY (hereafter "BARNES Lyon") attaches great importance to the protection and respect of your private life and your personal data (hereafter "Personal Data" or "Personal Information").
BARNES Lyon undertakes to implement adequate measures for the protection, confidentiality and security of Personal Data in accordance with the regulations in force in France and in the European Union, in particular the General Regulation on the Protection of Personal Data EU 2016/679 of 27 April 2016 and the rules of national law taken for its application.
The purpose of this "Personal Data Protection Charter" (hereinafter the "Charter") is to inform all natural persons concerned (hereinafter referred to as "You" or "Your/Yours") about the way in which BARNES Lyon collects, uses and discloses Personal Data and about the means available to You to exercise your rights with regard to this information.
Consequently, BARNES Lyon invites you to read this Charter carefully in order to know and understand the processing of Personal Data.
With its recognized know-how in the sale and rental of residential properties, BARNES Lyon has divided its expertise into different departments, each providing a personalized response to your requirements.
In any case, we are committed to respecting the following two (2) essential principles:
You remain in control of your personal data;
Your data is processed in a transparent, fair, confidential and secure manner.
2. Identity of the data controller
2.1 BARNES Lyon as data controller
MY LYON PROPERTY, a simplified joint stock company with a capital of € 10,000.00, whose registered office is located at 14 QUAI GENERAL SARRAIL 69006 LYON, registered in the Lyon Trade and Companies Register under the number 803199785, will be the data controller for all processing relating to the services provided via the "BARNES Lyon.com" website (hereinafter referred to as the "Website") as well as via its agencies and agents (hereinafter referred to as the "Services").
Via the BARNES Lyon.com website:
Management of information requests via the contact form
Management of newsletter subscriptions
Management of requests for estimates in video
Via the services provided by agencies and their authorized agents:
Management of the communication
Management of real estate properties
Management of client files.
2.2 BARNES Lyon as co-processor
Because of its special status as an exclusive licensee of BARNES INTERNATIONAL REALTY, MY LYON PROPERTY will be co-manager with various actors for the following processing operations:
This Charter concerns the processing of data by BARNES Lyon in its capacity as data controller or joint data controller.
3. Contact details for our Data Protection Officer
Our Data Protection Officer (hereinafter referred to as "DPO") is available to answer all requests, including requests to exercise rights, relating to your personal data.
You can contact him:
Either by email at the following address: email@example.com
Or by mail at
BARNES LYON 6E,
14, Quai du Général Sarrail, 69006 LYON.
4. Collection & origin of data
In the context of providing the Services, BARNES Lyon collects and processes personal data concerning you. This data may come directly from you, or may have been collected from other partners involved in the processing operations (banking institutions, notary chosen for the sale, agents with whom you are in contact, BARNES SAS etc.).
In all cases, you are informed of the purposes for which your data is collected by us via the various online data collection forms, emails sent to you, occasional notifications or even via our Cookies Policy.
Your personal data collected by BARNES Lyon is processed in accordance with the purposes set out at the time of collection in compliance with the RGPD and the guidelines of the CNIL.
5. Purposes and legal bases for processing
Your various data are collected by BARNES Lyon to ensure the personalization of our services. You will find below the details of the processing activities of the information that concerns you, from the moment you request information or a video appointment, to the terms of the mission that you mandate us.
5.1 Details of the processing of management of the site's audience measurement
5.1.1 Legal basis
Our legitimate interest in ensuring the proper functioning of the website constitutes the legal basis for this processing.
5.2 Details of the processing of information requests via the contact form
The purpose of the operations relating to the management of requests received via the contact form is to receive and follow up on responses to your request.
5.2.1 Legal basis
For this processing, the legitimate interest is considered the legal basis.
5.3 Details of the processing of newsletter subscriptions
When you check the box intended to register to receive, by e-mail, news and offers concerning the services of BARNES Lyon, OR when you send us your e-mail address by voluntarily entering it on the dedicated form, we consider that you consent to receive our newsletters. We consider you as a prospect.
5.3.1 Legal basis
For this processing, consent is considered the legal basis.
5.4 Détails du traitement de gestion des fichiers client
La réalisation d’opérations relatives à la gestion des fichiers client couvre les objectifs suivants :
- Analyse des profils
- Demandes de prise en charge électronique
- Diversification des actions marketing
- Envoi de newsletter clients
- Facturation des clients
- Gestion de clientèle : fiche client, courriers et relances
- Gestion des contrats
- Gestion des demandes de droit d'accès, de rectification et d'opposition
- Gestion des factures
- Gestion des impayés/recouvrement et du contentieux
- Gestion des paiements
5.4.1 Base légale
Ce traitement est nécessaire à l’exécution des prestations prévues dans le mandat conclu ou en cours de conclusion entre BARNES Lyon et vous-même.
5.5 Détails du traitement de gestion des biens immobiliers
La réalisation d’opérations relatives à la gestion des biens immobiliers couvre les objectifs suivants :
- Appréciation de la solvabilité des candidats à la location d’un bien immobilier
- Comptabilité du mandat de gérance
- Convocation aux assemblées générales
- Déclaration des revenus fonciers
- Décompte des taxes et charges y afférentes
- Gestion et transaction par voies télématique et électronique
- Envoi de lettres de relance
- Organisation d’opérations de recouvrement de créance
- Etablissement de pièces comptables nécessaires au recouvrement et à la gestion des comptes des locataires
- Réalisation d'opérations de négociation en lien avec les transactions immobilières
- Régularisation des charges
- Tenue des comptes des intéressés
- Tenue des comptes des locataires
- Tenue des comptes des propriétaires
5.5.1 Bases légales
Ce traitement est nécessaire à l’exécution des prestations prévues dans le mandat conclu ou en cours de conclusion entre BARNES Lyon et vous-même.
5.6 Détails du traitement de Gestion de fidélisation de nos clients
Si vous avez bénéficié de notre expertise en matière de transactions immobilières, nous souhaiterions vous recontacter à l'avenir pour vous proposer la même prestation ou un autre service directement lié au domaine de l'immobilier.
5.6.1 Base légale
Notre intérêt légitime à vous faire continuer à bénéficier de notre expertise tout en vous remerciant de votre fidélité constitue la base légale de ce traitement.
6. Processed data
The compulsory or optional nature of the personal data collected and the possible consequences of a failure to reply are indicated at the time of their collection on the associated forms.
You can consult the details of the personal data that we are likely to have on you below.
NB: the details of the information provided below are not intended to be exhaustive and aim above all to inform you about the categories of data that BARNES Lyon is likely to process.
6.1 For audience measurement management
We process the following measures on our website:
Statistical data (audience measurement, page by page, the list of pages from which a link was followed to request the current page (sometimes called "referrer") whether internal or external to the site, per page and aggregated on a daily basis, the type of terminal, browser and screen size of visitors, per page and aggregated on a daily basis, statistics on page loading times per page and aggregated on an hourly basis, statistics on time spent on each page, bounce rate, scroll depth, per page and aggregated on a daily basis, statistics on user actions (click, selection), per page and aggregated on a daily basis, statistics on the geographical area of origin of requests, per page and aggregated on a daily basis. )
6.2 For the management of information requests via the contact form
Data relating to your identity: title, birth name, surname or married name, first name, telephone number, e-mail address, "private/professional" status
Information relating to the property
Electronic communications (e.g. content of the message sent)
6.3 To subscribe to newsletters
If you have agreed to receive newsletters by checking the box below the contact form
Data relating to your identity: Civil status, birth name, surname or married name, first name, telephone number, e-mail, "private/professional" status
Information about the property
If you have actively expressed your wish to receive the newsletters, via the dedicated form:
Data relating to your identity: e-mail
6.4 For the management of customer filesData related to your identity: Marital status, ID card number, Place of birth, Current employer, Socio-professional category, First name, File number, Civil status, Customary name or spouse's name, Birth name, Personal address, Comments on the person, Date of birth, Personal e-mail, Nationality, Passport number, Driver's license number, Passport, Sex, Private landline telephone, Private mobile telephone, City, Visas, Age, Profession or job held
Data related to your professional life: Profession or job, Professional e-mail, Professional telephone number.
Financial data: Income assessment, Assets (land, real estate, accounts and investments...), Name of the lending institution, Loan repayment, Economic and financial situation
Information concerning the service: Discounts granted to the customer, Person(s) in charge of the customer relationship, Goods purchased by the customer, Transaction number, Details of the good or service subscribed by the customer, Origin of the sale (seller, partner, affiliate) or of the order
6.5 For the management of real estate
Information required for property administration, management and real estate transactions: (e.g., classification of the property, internal identification code, insurance company for the property, composition of the tenant or prospective tenant household, details of the tenant or prospective tenant's employer, etc.) Classification of the dwelling, Internal processing code allowing identification, Insurance company of the dwelling, Composition of the tenant household or tenant applicants, Contact details of the tenant employer or tenant applicants, Contact details of the agent or manager of the dwelling, Date of entry into and departure from the dwelling, Details of the goods and services provided, Identity of the applicant for rent or his guarantor, Identity of the applicant for purchase, Identity of the co-owner or landlord, Identity of the tenant, Nature and amount of charges for the property, Nature and amount of maintenance and improvement work, Property identification number, Resources of guarantors, Resources of the tenant or tenant applicant, Family status of the tenant or tenant applicant, Employment status of the tenant or tenant applicant, Housing status (owner or tenant), Type/characteristics of the current property or properties.
6.6 For the management of the communication:
Information exchanged via communication by means of exchanges and comments from customers and prospects, Correspondence with the sales representative,Date of subscription to the newsletter, Date of request to unsubscribe from the newsletter, Opening of the newsletter, Promotion, Requests for documentation customers prospects, Prospecting.
6.7 For the management of customer loyalty
Data relating to your identity: Last name or married name, First name, Personal address, Personal e-mail, Private cell phone, Private fixed phone.
Data relating to your professional life: Profession or job held, Professional e-mail, Professional telephone number.
Data relating to former services
Information contained in the commercial communication via exchanges and comments from customers and prospects and via your requests for documentation as a customer or prospect.
7. Recipients of your data
Within the limits of their respective attributions and for the purposes mentioned in article 6, the main persons who are likely to have access to your data are the following
according to the purposes, the authorized personnel of our marketing, sales, administrative, logistic, legal and IT departments;
The authorized personnel of our subcontractors;
Certain categories of subcontractors have access to the data collected:
The website development provider.
The web marketing and SEO provider
The provider of automation and email marketing.
The real estate software publisher
The real estate administrator software publisher
The management software provider
The cloudcomputing and storage provider.
For any additional information on our subcontractors, you can send a request for additional information to our Data Protection Officer by email at firstname.lastname@example.org.
Other organizations that may have access to your data are
Financial organizations (banks...) and supervisory bodies;
If necessary, the courts concerned, mediators, chartered accountants, auditors, lawyers, bailiffs, debt collection companies;
Your personal data is not communicated, exchanged, sold or rented without your prior express consent in accordance with the applicable legal and regulatory provisions.
8. Transfer of data outside the European Union
In some cases, your personal information will be stored on servers located outside the EEA.
This is particularly the case when we transfer information to some of our subcontractors located in the United States. We have ensured that standard contractual clauses approved by the European Union Commission are in place to contractualize the security obligations and measures required by the GDPR, as set forth in its Article 46.
You may request access to documents ensuring appropriate contractual guarantees by making a request to our Data Protection Officer by email at email@example.com.
9. Duration of data retention
We keep your data only for the time necessary for the purposes pursued, as described in Article 4 of this Charter.
9.1 For the management of audience measurement of the site
The data collected for this treatment will be kept for 13 months.
9.2 For the management of information requests via the contact form
Since most prestigious real estate projects can take up to 4 years to materialize, we allow ourselves to keep your information requests for a maximum of 4 years.
9.3 For newsletter subscription management
Since most prestigious real estate projects can take up to 4 years to materialize, we allow ourselves to keep your requests for information for a maximum of 4 years, unless you withdraw your consent before this period.
9.4 For the management of customer files
Information relating to the provision of services to you as a customer is kept for up to 8 years after the end of the business relationship.
9.5 For property management
Your information collected in connection with the purchase or sale of a property is retained for up to 10 years after the contractual documents are signed.
9.6 For communication management
The data used for communication management is kept for up to 2 years from the last contact.
9.7 For customer loyalty management
Given the fact that you may want to renew your real estate project in the future and the infrequent recurrence of the need for our expertise in this area, we consider that the need will arise no later than 8 years after your last project. We would therefore like to be able to contact you again within a maximum of 8 years from your previous transaction with us.
10. Connection data and cookies
For the proper functioning of the BARNES Lyon website and services, we use connection data (date, time, Internet address, protocol of the visitor's computer, page consulted) and cookies (small files saved on your computer) that allow us to identify you, to memorize your consultations, and to benefit from measurements and statistics of the audience, in particular relating to the pages consulted.
By browsing our site, you accept that BARNES Lyon installs this type of so-called "technical" cookies, whose sole purpose is to allow or facilitate electronic communication between your terminal equipment and our site, by facilitating the management and browsing of the site.
Our access to the information stored in your terminal equipment or the registration of information in the latter will therefore only take place in the following cases:
To enable or facilitate communication by electronic means;
When necessary to provide our online appointment service at your express request.
If the browser allows it, you can deactivate these cookies at any time by following the procedure indicated by the browser. However, BARNES Lyon informs you that such deactivation may result in slowing down and/or disrupting access to the website.
The Services and the BARNES Lyon website are not intended for minors. BARNES Lyon does not voluntarily collect personal data from minors under the age of 15.
12. Social networks
When browsing the BARNES Lyon website, you have the option of clicking on the icons dedicated to the social networks Twitter, Facebook and LinkedIn on our site.
Social networks help to improve the user-friendliness of the website, and help to promote it through sharing.
When you use these buttons, BARNES Lyon may have access to personal information that you have indicated as public and accessible from their Instagram, Facebook and LinkedIn profiles. However, BARNES Lyon does not create or use any database independent of Facebook, Instagram and LinkedIn and does not exploit any of your privacy data through these means.
In order to limit access by third parties to your personal information on Facebook, LinkedIn or Instagram, we invite you to set up your profiles and/or the nature of your publications via the dedicated spaces on social media in order to limit the audience.
BARNES Lyon complies with the RGPD and the French Data Protection Act regarding the security and confidentiality of your data.
We implement all the technical and organizational measures necessary to ensure the security of our personal data processing and the confidentiality of the data we collect.
In this respect, we take all the necessary precautions, with regard to the nature of the data and the risks presented by the processing, to preserve its security and, in particular, to prevent the data from being deformed, damaged or accessed by unauthorized third parties (physical protection of the premises, authentication procedures for persons accessing the data with personal and secure access via confidential identifiers and passwords, secure https protocol, logging and traceability of connections to the software deployed in-house).
14. Rights of individuals
In accordance with the Data Protection Act and the RGPD, you have the following rights:
14.1 Right to information on the processing of Personal Data
BARNES Lyon undertakes to make every effort to provide concise, transparent and accessible information on the conditions under which users' Personal Data is processed.
14.2 Right of access to Personal Data
Each user has the right to access the Personal Data processed by BARNES Lyon and to receive a copy in electronic form (for any additional copy, BARNES Lyon will be entitled to demand payment of a fee based on the administrative costs incurred).
14.3 Right to erase ("right to be forgotten") and rectify Personal Data
Each user has the right to request the deletion and/or rectification of his or her Personal Data if it is erroneous or obsolete.
It is specified that BARNES Lyon may retain certain Personal Data when required by law or for legitimate reasons.
14.4 Right of opposition
Users may object at any time, for legitimate reasons, to
the use of their Personal Data for direct marketing purposes or
to the re-use of their Personal Data for purposes other than those consented to, except in the case of the execution by BARNES Lyon of one of its legal obligations.
14.5 Right to limit the processing of Personal Data
Users have the right to request that the processing carried out on their Personal Data be limited to what is necessary. This right is applicable only :
if the user disputes the accuracy of his/her Personal Data;
if the user can establish that the processing of his/her Personal Data is unlawful and requests a limitation of their use rather than their deletion;
if BARNES Lyon no longer needs the user's Personal Data but it is still necessary for the user to establish, exercise or defend legal rights;
if the user objects to the processing based on the legitimate interest of the data controller, during the verification as to whether the legitimate reasons pursued by the data controller prevail over those of the user.
14.6 Right of complaint to a supervisory authority
If users consider that the efforts made by BARNES Lyon to preserve the confidentiality of Personal Data do not guarantee the respect of their rights, they have the possibility of lodging a complaint with the competent supervisory authority (CNIL or any other authority mentioned on the list available from the European Commission).
15. Modification of the personal data protection charter
BARNES Lyon reserves the right to modify the present Personal Data Protection Charter at any time in order to comply with legislative and regulatory changes and/or to improve its policy on the processing and protection of Personal Data.
In case of modification, a new version will be updated and put online with the date of "Last update".
16. Applicable law and competent court
16. Applicable law and competent court
The present Charter is subjected to the French law, including the provisions applicable to the rules of private international law.
IN THE ABSENCE OF AMICABLE AGREEMENT, JURISDICTION IS GIVEN TO THE COURTS OF THE JURISDICTION OF THE COURT OF APPEAL OF PARIS NOTWITHSTANDING PLURALITY OF DEFENDANTS AND/OR CALL IN GUARANTEE TO KNOW ANY LITIGATION RELATING TO THE INTERPRETATION OF THE PRESENT CHARTER.