[VAR_PAGE_NAME]

1. INTRODUCTION 

This privacy policy is intended for you, in your capacity as a “User” of the website “www.mondossiernotaire.fr” (hereinafter referred to as the “Website”). 

This Site is published by the notary’s practice [VAR_SITE_NAME].

The notary’s practice [VAR_SITE_NAME] and your notary attach great importance to respecting your privacy and protecting your personal data. As such, we are committed to strictly applying the regulations governing the protection of personal data, namely Law No. 78-17 of 6 January 1978, known as the Data Protection Act, and Regulation No. 2016/679 of 27 April 2016 (hereinafter the ‘General Data Protection Regulation’).

The purpose of this privacy policy is to inform you of the commitments and measures taken by your notary to ensure respect for your privacy and the protection of your personal data. 

The provisions of this Website’s privacy policy supplement those of the privacy policy on your notary’s practice website. In the event of any conflict between the terms, the provisions of the privacy policy on the notary’s practice website shall prevail.

2. DATA CONTROLLER 

Your notary acts as the data controller for the personal data of their clients, who are Users of the Website. 

3. PURPOSE OF THE PROCESSING 

3.1 PURPOSES 

The processing carried out in connection with the Website serves explicit, legitimate and specific purposes in order to ensure: 

• User authentication 
• The creation of a User profile 
• Access to files by the User 
• The User’s ability to book appointments 

In any event, and for each defined purpose, your notary will use all means at their disposal to ensure the security and confidentiality of the personal data entrusted to them, in accordance with the laws and regulations in force. 

3.2 LEGAL BASIS 

Pursuant to Article 6 of the General Data Protection Regulation, processing must be lawful and have a legal basis. 

• The processing carried out by your notary is necessary for the performance of a contract to which you are a party;
• In certain cases, the processing is also necessary to comply with a legal obligation.  

4. DATA PROCESSED 

Your notary undertakes to comply with the applicable legal provisions and, in particular, to provide Users of the Website with comprehensive information on the processing of their personal data and to maintain a record of data processing operations that accurately reflects the reality. 

4.1 IN CONNECTION WITH THE USE OF THE ONLINE APPOINTMENT BOOKING PAGE ONLY 

When using the online appointment booking page, without logging into the client area, the only data collected to create your profile is your: surname, first name, email address and telephone number. 

4.2 WHEN USING THE CUSTOMER PORTAL 

The personal data collected by your notary whilst you are using the client portal comes from several sources. This may include data that you provide directly when using the Website or data collected automatically by your notary. 
When using the Website, you will be asked to provide us with personal data at several stages:

• When you log in: Username, password 
• When creating your profile: Surname, first name, date of birth, country of birth, town of birth, email address, telephone number, postal address, postcode, town and marital status. 
• When you add a new document: Surname, first name, date of birth, telephone number, postal address, postcode, town, marital status, financial information, income. 
• When you make a payment: Surname, first name  

Data relating to payment methods is not collected by the Notary’s Office but by the Caisse des Dépôts et Consignations, which applies a strict policy to ensure the protection of the personal data it collects. When you make an online payment, you are redirected directly to the Caisse des Dépôts et Consignations website and connected to your own bank to complete the payment. 

5. RECIPIENTS OF THE DATA 

In order to fulfil the aforementioned purposes, your data may be transferred: 

• To our data processors, solely for the purposes set out by the Data Controller and provided that they offer sufficient safeguards in accordance with the requirements of the General Data Protection Regulation. Furthermore, these data processors may use this data for other purposes, such as compiling statistics or developing artificial intelligence tools, but only after the data has been anonymised and with your consent; 
• To government bodies or legally authorised partners such as the Directorate-General for Public Finances, or, where applicable, the land registry, notarial authorities, notarial bodies, and the central registers of the notarial profession (Central Register of Last Wills and Testaments, Central Electronic Register of Notaries, PACS register, etc.);
• To the notarial offices involved in the deed;
• To the High Council of Notaries or its delegate, for entry into a property database concerning deeds relating to the transfer of immovable property for valuable consideration, pursuant to Decree No. 2013-803 of 3 September 2013; 
• To public or private bodies for verification purposes in the context of identifying politically exposed persons or those subject to asset freezes or sanctions, and for the purposes of combating money laundering and the financing of terrorism. These checks involve the transfer of data to a country outside the European Union which has data protection legislation recognised as equivalent by the European Commission; 
• To the relevant financial institutions, and in particular to the Caisse des Dépôts et Consignations when implementing the online payment service. 

In this regard, the Caisse des Dépôts et Consignations pays particular attention to the protection of personal data and applies a strict policy in this area in accordance with French and European legislative and regulatory provisions: 

• Personal data is processed in a transparent and secure manner, whilst respecting individuals’ rights.
• The Caisse des Dépôts et Consignations is committed to an ongoing approach to the protection of personal data in accordance with the amended French Data Protection Act of 6 January 1978 and the EU General Data Protection Regulation (GDPR) of 27 April 2016
• Caisse des Dépôts has a Data Protection Officer (DPO) registered with the CNIL and a team dedicated to the protection of personal data.
• Caisse des Dépôts et Consignations’ personal data protection policy sets out the types of personal data that may be collected and processed, how it uses such data, and the circumstances in which it may be disclosed.

6. DATA RETENTION PERIOD 

In accordance with current regulations, the data collected is retained in a form that allows the user to be identified for a period not exceeding that necessary for the purposes for which the data is collected and processed. 
However, legal obligations may require us to retain data for a minimum period.

Accordingly, personal data will be retained by your notary for the following periods:

• 30 years from the completion of the service in respect of: clients of the notary’s office, ongoing files, the performance of notarial duties, the drafting of documents and, in particular, requests for information sent to the Land Registry or its replies, and the register of formalities;
• 75 years for authentic deeds, client files and the register of deeds (retained at the notary’s office and subsequently archived);
• 5 years from the date of dissolution of the civil partnership for information relating to civil partnerships, which is stored in the ‘PACSen’ automated data processing system. 

Login logs are retained for a period of six months; at the end of this period, they are deleted.

For the purposes of managing requests regarding your rights in relation to your personal data, the data is retained for a period of one year. 

7. DATA SECURITY 

Your notary implements technical and organisational measures to ensure a level of security appropriate to the risks involved in processing personal data. These measures ensure the integrity, confidentiality and accessibility of personal data.  

8. HOW TO EXERCISE YOUR RIGHTS 

In accordance with the French Data Protection Act and the General Data Protection Regulation, you have the following rights:  

• Right of access and information: you may request access to your processed data and be informed of the circumstances of such processing.
• Right to restriction of processing: you may request that the processing of your personal data be restricted if you contest its accuracy, the lawfulness of the processing, if you object to the processing, or if you wish to retain the data for evidential purposes.
• Right to rectification and erasure: you may request the rectification of your data where it is inaccurate or incomplete.
• Right to object: you may object to the processing of your data carried out on the Website. 
• Right to data portability: you may request that your data be provided in a structured, commonly used and machine-readable format, or request that this data be transferred to another data controller.
• Right to determine the fate of your data after your death and to choose whether or not we should disclose your data to a third party whom you have previously designated. In the event of your death and in the absence of any instructions from you, we undertake to destroy your data, unless its retention is necessary for evidential purposes or to comply with a legal obligation. 
• Right to lodge a complaint: you also have the right to lodge a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés). 

You may exercise these rights by contacting the Data Protection Officer at the following addresses 

• By email: etude.augehorizon@14054.notaires.fr
• By post: AUGE HORIZON NOTAIRES - 13 RUE MARECHAL FOCH , BP 35 14140 LIVAROT PAYS D’AUGE

The person making this request must provide their contact details (surname, first name, address and a copy of a signed identity document) and a legitimate reason where required by law (particularly in the event of an objection). 

To find out more about your rights, please visit the website of the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés) at the following address: http://cnil.fr