Introduction

Protecting your privacy rights is very important to us. This privacy policy sets out how we process your personal data when you engage with us. Please read this policy carefully to understand why and how your personal data will be used, how it will be shared, and the rights you have in respect of your personal data.

In this policy, when we talk about “personal data”, we mean information relating to an individual who can be identified – directly or indirectly – by reference to that information. For example, their name, address, phone number, or email address. When we talk about “processing”, we mean any action taken in relation to personal data, including collecting, using, storing, or deleting it.

Who will process your personal data

Provençal Investments S.A. (a limited liability company incorporated under the laws of the Grand Duchy of Luxembourg, having its registered office at 25c, Boulevard Royal L-2449 Luxembourg, registered with the Luxembourg Trade and Companies Register under number B 116.230, acting through its permanent establishment in France, registered number 491 440 095 R.C.S. Antibes, 9 rue Saint-Barthélémy, 06160 Antibes), referred to in this policy as Caudwell, we or us is the data controller in respect of the personal data processing described in this policy. When we say we are the “data controller“, this means we exercise overall control over how your personal data is processed.

When we process your personal data, we will do so in compliance with applicable data protection laws, including GDPR, and applicable local data protection laws.

If you have any questions about this policy, or would like to exercise any of the rights described in it, you can contact us by either email or post, using the following details:

• By email: info@caudwell.com
• By post: Caudwell Ltd.38 Park Street, London, W1K 2JF, United Kingdom

How do we process your personal data

Whenever we process your personal data, we strive to do so according to the following principles:

• We will process personal data lawfully, fairly, and transparently.
• We will only collect personal data for a specific and legitimate business purpose, and will only use it in a manner that is consistent with that purpose.
• We will only collect personal data that is , relevant and that is limited to what is adequate and necessary for the relevant purpose; we will not collect excessive personal data.
• We will keep personal data accurate and up to date.
• We will not keep personal data for longer than we need it, and will delete it securely once it is no longer needed.
• We will keep the personal data we process safe and secure.

What personal data we will process about you

When you engage with us, we collect the following information about you:

• First name;
• Last name;
• Address;
• Email address;
• Telephone number;
• Nationality;
• Information about properties you may be interested in, and
• Information about your use of our website and online resources, such as when you last accessed them, which pages you have looked at, and the IP address you used to log in. If you access certain online resources we offer, such as digital presentation models, we will also generate user credentials that allow you to log in.

We collect this information from you directly or from selected partners, such as Google. We will process this personal data for the purposes described below.

To be clear, we do not collect sensitive personal data about you, such as information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, or information concerning your health, sex life, or sexual orientation.

Why we process your personal data, and how long we keep it for

We will only process your personal data where we have valid legal grounds to do so in accordance with applicable data protection law. We rely on the following legal grounds when processing your personal data:

• Consent, i.e., where you have given us your consent to the processing (for example, if you consent to receive direct marketing from us).
• Performance of a contract, i.e., where it is necessary for the performance of a contract with you, or in order to take steps prior to entering into that contract (for example, if you complete a property purchase with us).
• Legal or regulatory obligation, i.e., where we need to process your personal data in order to comply with a legal or regulatory obligation (for example, if we need to carry out anti-money laundering checks).
• Legitimate interests, i.e., where the processing is necessary for our legitimate interests (or those of a third party).

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Our legitimate interests

We use your personal data where this is necessary for our legitimate interests (or those of a third party). This includes where use of your personal data is necessary to:

• Ensuring we provide an efficient and profession service to you and providing you with a good experience when you engage with us regarding potential property purchases or investements;
• Ensure effective administration and management of our website and online resources and ensuring network and information security;
• Maintaining an up-to-date client database and managing our client contacts;
• Administer our operations and business, including our relationships with clients, in an efficient and effective way, including understanding and responding to queries, complaints and feedback and seeking to improve and develop our services;
• Ensure the security of our or another’s premises or property, and
• Enforce our legal rights and manage any dispute and legal claims and take legal or other professional advice.

Sharing your personal data

Access to your the personal data is restricted to only those who need it for a legitimate business purpose, on a “need to know” basis, and who are subject to confidentiality obligations.

There are certain circumstances where we will transfer your personal data to third parties, i.e.:

• Caudwell entities and affiliates to administer and manage our relationship with you and so we can provide the best service across our group. We also share your personal data with Caudwell entities and affiliates for management forecasting and financial planning purposes. The list of Caudwell entities and affiliates with whom we share your personal data is as follows:
  • 1 Mayfair Management Company Ltd
  • Alba Properties S.A.
  • Amberwood Drive Ltd
  • Broughton Holdings Limited
  • Caudwell Design Ltd
  • Caudwell Ltd
  • Caudwell Marine Ltd
  • Caudwell Properties (100) Ltd
  • Caudwell Properties (101) Ltd
  • Caudwell Properties (102) Ltd
  • Caudwell Properties (107) Ltd
  • Caudwell Properties (108) Ltd
  • Caudwell Properties (109) Ltd
  • Caudwell Properties (110) Ltd
  • Caudwell Properties (111) Ltd
  • Caudwell Properties (112) Ltd
  • Caudwell Properties (France) Ltd
  • Doughty
  • Doughty Properties Ltd
  • Hyde Park Finance Ltd
  • JDC Investment USA Limited
  • JDC Investments Limited
  • Lyme Properties Ltd
  • Marguerite Olivette SCCV
  • Olive Properties S.A.
  • Patio Properties S.A.
  • Prime London Holdings 11 Ltd
  • Tennis Properties S.A.
  • Titania 2012 Ltd
  • Unshacked.com Limited
• Service providers, who may process your personal data on our instructions. These include IT suppliers (including website, software, and app developers and providers), cloud hosting providers such as Salesforce (our CRM provider), professional advisors, advertising partners, marketing agencies, database providers, backup and disaster recovery specialists and email providers. The list of service providers and affiliates whom we share your personal data is as follows:
  • Adgenda Media International (Marketing & Advertising)
  • Broad Access Services (Cloud Services)
  • COMO (Marketing)
  • DD London (Marketing)
  • Lawrie Cornish (Advertising)
  • Linassi (Marketing)
  • Monday.com (CRM)
• Advertising partners, who may process your personal data in order to show you digital advertising that you might
  be interested in. The list of advertising partners whom we share your personal data is as follows:
  • Google
  • Meta

The recipients of your personal data described above will be required to meet appropriate standards on processing information and security when processing your personal data.  The information we provide them, including your information, will only be processed in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy policy.

Your personal data may also be transferred to other third-party organisations in certain scenarios:

• If we’re discussing selling or transferring part or all of our business, the information may be transferred to prospective purchasers under suitable terms as to confidentiality.
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you.
• If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority. For example, the police, e.g., in order to assist fraud protection and minimise credit risk; or
• If we are defending a legal claim your information may be transferred as required in connection with defending
  such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Where your personal data will be processed

We will transfer your personal data within the European Economic Area and the UK, relying on the safeguards set out below:

Please contact us at info@caudwell.com if you would like further information on the specific safeguards used by us when transferring your personal data.

Security

We are committed to keeping your personal data secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical and organisational measures to safeguard and secure the personal data we process. We employ a suite of IT security tools in order to safeguard personal data, we restrict access to data, and we have physical and organisational security measures in place to prevent unauthorised or unlawful access to personal data, as well as accidental loss, destruction, or damage to personal data. We also maintain an inventory of personal data and evaluate the protections that we have in place for that data to ensure that our security measures are tailored to the sensitivity of the data.

In addition, as described above, we have limited access to your personal data to only those individuals who need access to it in order to fulfil their roles, and only to the extent that they need such access. Employees are not authorised to share personal data with other employees or third parties unless that sharing is authorised and complies with this privacy policy.

If, despite all our efforts, a data breach does occur, we shall do everything in our power to limit the damage. In case of a data breach which is likely to result in a high risk to you, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. Where required, we always inform the relevant supervisory authority or authorities without undue delay.

Your rights

You have a number of rights in relation to our handling of your personal data. Your rights include the following:

• Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, as well as additional information about our use of your personal data (such as the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been, or will be, disclosed).
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
• Erasure: you are entitled to ask us to delete or remove personal data where one of the grounds set out under Article 17 of the GDPR applies.  There are certain exceptions set out under applicable law where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, where one of the grounds set out under Article 18 of the GDPR applies; for example if you want us to verify its accuracy.
• Transfer: you may transfer and request us to transfer (where technically feasible)  your personal data to another party where the processing is carried out by automated means and based either on your consent or the performance of the contract.
• Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground. We will then no longer be able to process your personal data on the basis of our legitimate interest, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims
• Withdraw consent: where you have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time and for free by contacting us at info@caudwell.com.
• Post-mortem rights: you are entitled to define directives relating to the conservation, deletion and communication of your personal data after your death, under the conditions set out in article 85 of law no. 78-17 of January 6, 1978 relating to information technology, files and civil liberties, as amended. In particular, you can register your specific directives – i.e. directives indicating how your personal data relating to certain processing operations identified in said directives are to be handled after your death – with us. You may revoke or modify your instructions at any time. Compliance with these instructions is without prejudice to the provisions applicable to public archives containing personal data.

You can exercise your rights or contact us for any other requests relating to your personal data at info@caudwell.com.

You also have the right to lodge a complaint with the ‌judicial authority or a supervisory authority, in particular in the Member State of the European Union in which you usually reside, work, or the place where you believe a breach of the GDPR has occurred.

The French data protection authority may be contacted as follows:

• Commission nationale de l’informatique et des libertés
• Address: 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France
• Relevant webpage: Contacter la CNIL

Changes to this privacy policy

This privacy policy may change from time to time and is available on our website. You can tell when this privacy policy was last updated by looking at the date at the top of the policy. If we make changes to this privacy policy, we will post the updated version on our website.

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email.

Any changes to this privacy policy will become effective upon posting. We encourage you to review this website from time to time for the latest information.

Cookie Policy

General Information
On its website, Provençal Investments S.A. (a limited liability company under Luxembourg law, with its registered office at L-2449 Luxembourg, 25c, Boulevard Royal, registered with the Luxembourg Trade and Companies Register under number B 116.230, acting through its permanent establishment in France, registered under number 491 440 095 R.C.S. Antibes, 9, rue Saint-Barthélémy, 06160 Antibes) uses cookies, beacons, tags and other similar technologies (“cookies”).

Please read this Cookie Policy carefully. It explains what a cookie is, which cookies we use, their purpose, and their duration, how to manage your cookie preferences, and any changes to our Cookie Policy. You can manage your cookie preferences at any time using the cookie widget located at the bottom of each page of our website.

We and our partners use cookies that are strictly necessary for the operation of our website https://leprovencal.com/. With your prior consent, Provençal Investments S.A. also uses cookies to understand how users use the site and measure its effectiveness (Site Performance), to improve non-essential website or application features during your browsing (Browsing Optimization), or to present you with personalized advertisements based on your browsing activity and profile (Personalized Advertising).

If we collect personal data about you through cookies, we use it in accordance with our Privacy Policy, which you can refer to for more information about our use of personal data and its sharing with third parties.

What is a Cookie?

A cookie is a small file stored by a server on a user’s device (computer, phone, etc.) and associated with an internet domain (i.e., in most cases, all pages of the same website).

Cookies have many uses. They can be used to remember the language in which the web page is displayed, or to track your browsing for statistical or advertising purposes, etc. Some of these uses are strictly necessary for the functionalities expressly requested by the user or for establishing communication, and are therefore exempt from the requirement for consent. Others, which do not fall under these criteria, require your consent before being placed on your device.

Cookies can be “first-party” (generated by the website you are visiting) or “third-party” (generated by a domain, website, or mobile application other than the one you are visiting).

What cookies do we use, why, and for how long?

Technical Cookies

Technical cookies are necessary for providing the service you have requested (i.e., accessing and using the website). They enable website navigation and use. Technical cookies allow us to remember essential settings you have chosen, such as your language or cookie preferences, in order to provide you with the browsing experience you normally expect.

The use of technical cookies does not require your consent.

We use the following technical cookies:

Purpose: Website functionality (basic services)

Cookie name: moove_gdpr_popup

Third-party partner(s) deploying cookies on our website and their privacy policy: Moove Agency

Cookie duration: 365 days

Description: Used to store cookie consent preferences.

Analytical Cookies

Analytical cookies are used to determine how you use our website. This allows us to optimize performance and understand how people use our website and online resources.

The use of analytical cookies requires your consent.

If you do not accept these analytical cookies, we will not be able to measure the website’s performance and audience. This will not affect your experience or the website’s functionality.

We use the following analytical cookies:

Purpose: Analysis

Cookie Name: ga

Third-Party Partner(s) deploying cookies on our website and their privacy policy: Google (Privacy Policy – ​​Privacy Policy and Terms of Service – Google)

Cookie Duration: 30 days

Description: Used to distinguish users for analytical tracking.

Cookie name: _ga_MSCF4KCEHL

Third-party partner(s) deploying cookies on our website and their privacy policy: Google (Privacy Policy – ​​Privacy Policy and Terms of Service – Google)

Cookie duration: 60 days

Description: Used to maintain session state.

Profiling Cookies

Profiling cookies are used to track your profile and your interaction with the website in order to display personalized advertisements on our website (i.e., based on your stated preferences and online behavior). We use profiling cookies to carry out promotional and marketing activities effectively.

The use of profiling cookies requires your consent.

If you do not accept profiling cookies, we and the relevant third parties will no longer be able to show you personalized advertising messages (i.e., advertisements tailored to your browsing habits and interests), and we will have fewer opportunities to adapt our marketing strategy to your preferences and online behavior.

Purpose: Personalized ads

Cookie name: _fbp

Third-party partner(s) deploying cookies on our website and their privacy policy: Meta (Privacy Policy: Meta’s privacy policy: how Meta collects and uses user data | Privacy Center. Manage your privacy on Facebook, Instagram, and Messenger. Facebook Privacy)

Cookie duration: 41 days

Purpose: Campaign performance measurement

Description: Used by Facebook to provide a range of advertising products, such as real-time bidding for advertisers.

Cookie name: _gcl_au

Third-party partner(s) deploying cookies on our website and their privacy policy: Google (Privacy Policy: Privacy Policy – ​​Privacy Policy and Terms of Service – Google)

Cookie duration: 90 days

Description: Used to track conversions and measure the performance of advertising campaigns.

How to manage your cookie preferences

When you first visit our website, a banner explaining the use of cookies will appear. This banner allows you to consent to all cookies, reject all cookies, or give your consent to cookies purpose by purpose by clicking on Settings. If you continue browsing without giving your consent, the banner will disappear after a short time, and only technical cookies (as described above) will be used.

You can change your initial settings and manage your cookie preferences at any time (including withdrawing your consent) using the cookie widget at the bottom of each page of our website. If you change the status of one of the cookie purposes to disable it, cookies will no longer be deployed on your device for that specific purpose.

Changes to our Cookie Policy

This Cookie Policy may be updated periodically. If we make significant changes to this Cookie Policy, we will notify you by displaying a pop-up window on our website for a reasonable period before the change takes effect. We take care not to use cookies for purposes for which you have not given your prior consent (where required by law).

The date of the last update is shown at the top of this Cookie Policy.