LES BORDES ESTATE
PRIVACY POLICY
Effective date: 14 July 2022
1. INTRODUCTION
Les Bordes Golf International SAS, its subsidiaries and affiliates (collectively “Les Bordes”, “us”, “we”, or “our”) respects the privacy of visitors to our website, and our purchasers and customers (collectively, “you”). This Privacy Policy (“Policy”) describes how we collect, process, share and safeguard Personal Data that is collected through or in connection with our website residences.lesbordes.com (the “Website”) or in connection with any actual or contemplated real estate purchase from Les Bordes (a “Transaction”). It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any questions or concerns.
Please read this Policy carefully. If you do not agree with this Policy or any part thereof, you should not access or use any part of the Services, or seek to enter into any Transaction. If you change your mind in the future, you must stop using the Services and cease any Transaction, and you may exercise your rights in relation to your Personal Data as set out in this Policy.
2. PERSONAL DATA WE COLLECT
We collect Personal Data about you from different sources listed below. In this Policy, “Personal Data” means any information related to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).
PERSONAL DATA YOU PROVIDE TO US
Correspondence and other communications: When you contact us, including about our Services or in connection with a Transaction, via a contact form on our Website, email, via LinkedIn or by other means, you provide us with Personal Data, such as your full name, email address, telephone number and the subject and content of your communications.
Identity and contact information: When you engage with us in relation to a Transaction, we may collect Personal Data such as first name, last name, legal name, email, phone, ID information, date of birth, your address, your employer, your job title, your marital status, your place of birth and other identity and KYC information. We may also process your image for ID verification purposes. For example, we may process your biometric information for facial recognition in the ID verification process.
Information collected in the context of a real estate purchase: When you engage with us in relation to a Transaction, we may collect information such as information on your conveyancing solicitor and other advisors, your bank details, your lender and other Personal Data you may provide to us in the context of the purchase or negotiations.
Marketing information: When you register your choices for receiving communications about our activities and publications, we store this information.
Where you provide us with the Personal Data of third parties, it is your responsibility to inform them about the processing of their Personal Data in accordance with this Policy, and to confirm that they have given their permission.
INFORMATION COLLECTED VIA AUTOMATED MEANS
Cookies and Similar Technologies: we collect Personal Data via cookies, pixel tags, or similar technologies on our Website (collectively referred to as “Cookies”), including for conducting analytics and advertising. For more information on our use of Cookies, please read our Cookies Policy.
Usage and Device Data: when you access and use the Website, we receive and store information about interactions with our Website, such as date/time stamps, usage information and statistics, as well as your device, including your internet protocol (IP) address, network connection, browser type, device type, device identifiers, operating system version and type.
INFORMATION WE RECEIVE FROM THIRD PARTIES
The third parties below process your Personal Data in accordance with their own privacy policies. Please review these policies carefully before using their services.
Social media information: We maintain pages on social media platforms, such as Facebook and Instagram. You or the platform providers may provide us with information through the social media platform, and we will treat such information in accordance with this Policy.
Other sources: We may obtain your Personal Data from other third parties, such as marketing partners.
3. HOW WE USE YOUR PERSONAL DATA
We will use your Personal Data for one or more of the purposes set out below. We only use your Personal Data as described in this section if we have a valid legal ground for the processing, as set out below.
To communicate with you and to respond to your requests and complaints. If you reach out to us, including to register your interest in a Transaction, we will perform our contractual obligation towards you by using your Personal Data to respond and resolve your queries and facilitate support. It is in our legitimate interests to communicate with you about our Services and, at your request, about real estate from Les Bordes, including by sending you announcements and messages. The Personal Data we process when doing so includes your correspondence with us and your contact details.
Negotiating and Executing a Transaction. We use your Personal Data to take steps to enter into a contract with you to regarding the sale and purchase of real estate from Les Bordes, and to negotiate and enter into a sales contract with you. The Personal Data we process when doing so includes your contact, identity and real estate purchase information. Where we process your biometric information, we will only do so with your consent.
To improve or monitor usage of our Services and to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity. It is in our legitimate interests to improve and keep our Services safe for our users, which includes conducting troubleshooting, testing and research and to keep the Services secure. When doing so we may use Personal Data that we automatically collect about you such as usage and device information.
To monitor and analyse trends and use of our Services and Transactions. It is in our legitimate interests to analyse the use of our Services and information relating to Transactions. When doing so, we will process Personal Data that we automatically collect about you or that is generated about you when you use the Services or when we engage about Transactions.
Direct marketing. Except where consent is required, unless you have opted out of receiving marketing communications, it is in our legitimate interests to use your Personal Data to communicate with you regarding our Services, real estate from Les Bordes and other news, products or services we think will be of interest to you. You can opt out of such communications by following the unsubscribe mechanism on any communication, or by otherwise emailing us at info@lesbordes.com.
To enforce our Terms and Conditions, to comply with legal obligations and to defend Les Bordes against legal claims or disputes. It is in our legitimate interests to enforce and comply with our terms and policies and any sales contract relating to a Transaction, to ensure the integrity of our Services and to defend ourselves against legal claims or disputes. Where we do so, we will use the Personal Data relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on Les Bordes, for example to keep records of transactions, or as requested by any judicial process or governmental agency.
We only rely on legitimate interest as a legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms and we ensure we comply with any request you make to exercise your rights.
If, where we are processing your Personal Data to perform our contract with you, you do not provide the Personal Data, we may not be able to conclude or fulfill such contract.
4. HOW WE SHARE YOUR PERSONAL DATA
We disclose Personal Data about you with the following recipients and in the following circumstances:
Affiliates: affiliates and subsidiaries of Les Bordes, for purposes consistent with this Policy.
Notaries: We may share all Personal Data you provide to us in the context of a Transaction to notaries, as required for the purpose of concluding the Transaction.
Service Providers: We rely on vendors and service providers for the provision of our Services and for the purposes set out above, such as providers of website analytics, hosting and cloud computing services and other IT services, database management and customer support services in addition to other administrative services. These third parties may have access to or process your Personal Data as part of providing these services.
Advertising Partners: We may share your personal information with third party advertising companies.
Advisors: we work with various advisors, including tax consultants and legal advisors, with whom we may share your Personal Data.
Legal: information about our customers, including Personal Data, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Les Bordes, customers, a third party, or the public.
Business Transaction: if Les Bordes is involved in a merger, acquisition or asset sale, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be sold, transferred or otherwise shared including as part of any due diligence process.
5. YOUR RIGHTS AND CHOICES
If you reside in the EEA, Switzerland or the UK, you have the following rights, as provided under applicable law and subject to any limitations in such law:
access the Personal Data we hold about you;
request we correct any inaccurate Personal Data we hold about you;
request we delete any Personal Data we hold about you;
restrict the processing of Personal Data we hold about you;
object to the processing of Personal Data we hold about you;
receive any Personal Data we hold about you in a structured and commonly used machine readable format or have such Personal Data transmitted to another company; and/or
withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.
Please note that, prior to any response to the exercise of such rights, we will require you to verify your identify. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case. For more information on your rights, please contact us using the details in the “Contact Us” section below.
6. INTERNATIONAL DATA TRANSFERS
If you reside in the EEA, Switzerland or the UK, then please note that we may transfer your Personal Data outside of those regions to the United States for storage and processing.
If we transfer your Personal Data internationally, these countries may not provide the same protections as the data protection laws where you are based. We will ensure that relevant safeguards are in place to afford adequate protection for your Personal Data and we will comply with applicable data protection laws, in particular if you reside in the EEA, Switzerland or UK by relying on an EU Commission or UK government adequacy decision, on contractual protections for the transfer of your Personal Data or a derogation if available. For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact Us” section below.
7. CHILDREN’S PRIVACY
Our Services are not directed to children, and we do not knowingly collect Personal Data from anyone under the age of 16. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us as set out in the “Contact Us” section below. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
8. RETENTION OF PERSONAL DATA
We retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws.
To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. SECURITY OF PERSONAL DATA
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of Personal Data we process. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your Personal Data, we cannot guarantee its security.
10. LINKS TO OTHER SITES
The Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
11. CHANGES AND UPDATES TO THIS POLICY
We will update this Policy from time to time. You are advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If we make material changes, we will let you know via email and/or a prominent notice on our Services.
12. COMPLAINTS
If you wish to lodge a complaint about how we process your Personal Data, please contact us at info@lesbordes.com. We will endeavor to respond to your complaint as soon as possible. You may also lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
13. CONTACT US
Les Bordes Golf International SAS is the entity responsible for the processing of your Personal Data, and is the data controller in respect of such processing. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us by email at info@lesbordes.com.
