Update date: August 16, 2024 

The protection of your personal data is at the heart of our concerns, the DELTA IMMO Group has adopted strong principles in its Personal Data Confidentiality Charter available at the following address: https://group.bnpparibas/uploads/file/bnpparibas_charte_confidentialite_des_donnees_personnelles.pdf. 

DELTA LINK INTERNATIONAL and the other entities of the group are part of the DELTA IMMO Group, and offer a complete range of real estate-related services to its investors, developers, building occupants and public sector clients, at all stages of the real estate life cycle: real estate development, transaction, consulting, expertise, property management and investment management. DELTA LINK INTERNATIONAL (“We”), an entity of the DELTA IMMO Group, as data controller, is responsible for the collection and processing of your personal data in the context of its activities. 

The DELTA IMMO Group supports all of its clients – individuals, entrepreneurs, VSEs (Very Small Enterprises), SMEs (Small and Medium Enterprises), large companies and institutional investors – in their real estate activities and in carrying out their projects thanks to our financing and investment solutions. As a member of an integrated Group in collaboration with the various entities of the Group, we provide our clients with a complete range of real estate products and services. 

The purpose of this document is to explain to you how we process your personal data and how you can control and manage it. If necessary, additional information may be communicated to you at the time of collection of your personal data. You are concerned by this notice, if you are (“You”): 

• one of our clients or in a contractual relationship with us (for example, as an owner, tenant, the principals, agents, investors, users, purchasers, occupants, sub-tenants, rental managers, condominium trustees, partners, and their representatives); 

• a family member of our client. Indeed, our clients may sometimes be required to share information about their family with us when this is necessary to know them better; 

• a person interested in our products or services; 

• a visitor to our websites and applications. When you provide us with personal data relating to other people, do not forget to inform them of the communication of their data and invite them to read this. We will take care to do the same when we can (i.e. when we have the contact details of the people). 

You have rights that allow you to exercise significant control over your personal data and the way we process it. If you wish to exercise the rights described below, please send us a request by post to DELTA IMMO: 1 Rue Dulong – Évreux 27000 – France with a scan/copy of your identity document when necessary, or by email to the following address: https://www.delta-immo.fr/contact on our website.

2.1. You can request access to your personal data If you wish to have access to your personal data, we will provide you with a copy of the personal data to which your request relates as well as information relating to their processing. Your right of access may be limited when the regulations provide for it.

This is the case for the regulations relating to the fight against money laundering and the financing of terrorism which prohibits us from giving you direct access to your personal data processed for this purpose. 

In this case, you must exercise your right of access with the CNIL (National Commission for Information Technology and Civil Liberties) which will question us. 

2.2. You can request the rectification of your personal data If you consider that your personal data is inaccurate or incomplete, you can request that it be modified or completed. In certain cases, supporting documentation may be requested. 

2.3. You can request the erasure of your personal data If you wish, you can request the deletion of your personal data within the limits permitted by law. 

2.4. You can object to the processing of your personal data based on legitimate interest If you do not agree with processing based on legitimate interest, you can object to it, for reasons relating to your particular situation, by indicating to us precisely the processing concerned and the reasons. We will no longer process your personal data unless there are legitimate and compelling reasons for processing them or they are necessary for the establishment, exercise or defense of legal claims. 

2.5. You can object to the processing of your personal data for commercial prospecting purposes You have the right to object at any time to the processing of your personal data for commercial prospecting purposes, including profiling to the extent that it is linked to such prospecting. 

2.6. You can suspend the use of your personal data If you contest the accuracy of the data we use or object to your data being processed, we will verify or review your request. During the period of consideration of your request, you have the possibility to ask us to suspend the use of your data.

2.7. You have rights in the face of an automated decision In principle, you have the right not to be subject to a fully automated decision based on profiling or not that has a legal effect or significantly affects you. We can nevertheless automate this type of decision if it is necessary for the conclusion/performance of a contract concluded with us, authorized by the regulations or if you have given your consent. In any event, you have the possibility to contest the decision, to express your point of view and to request the intervention of a human being who can review the decision. 

2.8. You can withdraw your consent If you have given your consent to the processing of your personal data, you can withdraw this consent at any time. 

2.9. You can request the portability of part of your personal data You can request to retrieve a copy of the personal data that you have provided to us in a structured, commonly used and machine-readable format. Where technically possible, you may request that we transmit this copy to a third party. 

2.10. You may request to define guidelines for the management of your personal data after your death You may request to define guidelines for the retention, deletion and communication of your personal data after your death. 

2.11. How to file a complaint with the CNIL? In addition to the rights mentioned above, you may file a complaint with the competent supervisory authority, which is most often the one in your place of residence, such as the CNIL (Commission Nationale de l’Informatique et de Libertés) in France. The purpose of this section is to explain to you why we process your personal data and on what legal basis we rely to justify it. 

3.1. Your personal data is processed to comply with our various legal obligations Your personal data is processed when necessary to enable us to comply with the regulations to which we are subject, in particular real estate, banking and financial regulations

3.1.1. We use your personal data to: 

• Prevent and detect fraud and regulatory breaches;

• Manage and control the risks (financial, legal, compliance or reputational) that we face in the course of our activities; 

• Prevent, detect and report risks related to Corporate Social Responsibility and sustainable development; 

• Combat money laundering and terrorist financing; 

• Contribute to combating tax fraud and meeting our reporting and tax control obligations; 

• Manage operations for accounting and tax purposes; 

• Participate in the prevention of corruption; 

• Monitor the compliance of customers and intermediaries; 

• Comply with the provisions applicable to trust service providers issuing electronic signature certificates; 

• Exchange and report different operations, transactions or requests or respond to an official request from a duly authorized local or foreign judicial, criminal, administrative, tax or financial authority, an arbitrator or mediator, law enforcement authorities, government bodies or public bodies; 

• Implement a professional alert system; 

• Process and respond to your requests to exercise your rights. 

3.1.2. We also process your personal data to combat money laundering and the financing of terrorism We belong to a Real Estate and Investment Group that must have a robust system for combating money laundering and the financing of terrorism (LCB/FT) at the level of our entities, as well as a system for applying local, European or international sanctions decisions. 

In this context, we are joint data controllers between the entities of the DELTA IMMO Group (the term « we » in this section includes the DELTA IMMO Agency, the DELTA IMMOPROS agency, DELTA INVESTISSEMENT and the DELTA LINK INTERNATIONAL agency. The processing implemented to meet these legal obligations is detailed in the appendix « Processing of personal data to combat money laundering and the financing of terrorism ».

3.2. Your personal data is processed to perform a contract to which you are a party or pre-contractual measures taken at your request Your personal data is processed when it is necessary for the conclusion or performance of a contract to: 

• assess whether we can offer you a product or service and under what conditions; 

• provide you with the products and services subscribed to in accordance with the applicable contract (mandates, advice, expertise, rentals, etc.); 

• ensure the management of services in buildings (access, maintenance and works); 

• check the conformity of buildings and the management of deliveries and reserves; 

• select and contract the reservation of a property for sale, rental with the owners, principals or co-owners;

• provide assistance missions to customers in the application of building damage insurance and management, monitoring and reporting of claims;

• manage complaints and disputes relating to contracts; 

• choose the co-contractors, exchange within the framework of the contract, negotiate, formalize the contracts and manage them (in particular invoicing and payment); 

• respond to your requests and assist you in your procedures. We draw your attention to the mandatory nature of the collection of data mentioned as mandatory in our web or paper forms. If you do not provide mandatory information, we will not be able to process your request. 

3.3. Your personal data is processed to meet our legitimate interest or that of a third party When we base a processing on legitimate interest, we weigh this interest against your interests or your fundamental rights and freedoms to ensure that there is a fair balance between them.

If you would like to obtain more information on the legitimate interest pursued by a processing, please contact us using the contact details provided in section 2 “HOW CAN YOU CONTROL THE PROCESSING THAT WE CARRY OUT ON YOUR PERSONAL DATA?” above. 

3.3.1. As part of our activity as a real estate professional, we use your personal data to: 

• Manage the risks to which we are exposed: 

– we keep proof of operations or transactions, including in electronic format; 

– we monitor your transactions to manage, prevent and detect fraud; 

– we manage any unpaid amounts; 

– we handle legal claims and defense elements in the event of litigation;

• Improve cybersecurity, manage our platforms and websites, and ensure business continuity; 

• Prevent bodily harm and damage to people and property via video surveillance; 

• Control access to buildings (parking, visitor management, access control); 

• Conduct energy consumption studies and monitor building performance; 

• Improve the efficiency of our operational processes and customer services (e.g. monitoring your requests and improving your satisfaction based on data collected during our interactions with you, including through telephone recordings, emails, contact forms); 

• Conduct statistical studies and develop predictive and descriptive models for the purposes of: 

– market assessment and analysis and sales monitoring; 

– commercial: to identify the products and services that we can offer you and best meet your needs, to create new offers or identify new trends, to develop our commercial policy taking into account our customers’ preferences; 

– security: to prevent potential incidents and improve security management; 

– compliance (in particular to combat money laundering and the financing of terrorism) and risk management; 

• Manage and invite you to events (for example, organizing conferences, participation and meetings at trade fairs); 

• Organize competitions, promotional operations, conduct customer opinion and satisfaction surveys; 

• Manage the company’s media coverage and press relations; 

• Handle complaints and defense elements in the event of a dispute; 

• Manage a list of opposition to commercial prospecting; 

• Respond to your requests, for example those made through social networks; 

• Respond to requests in order to propose offers and services; 

• Handle complaints and defense elements in the event of a dispute; 

• Manage a list of opposition to commercial prospecting. 

3.3.2. We use your personal data to send you commercial offers by electronic means, paper mail and telephone As an entity of the DELTA IMMO Group, we want to be able to offer you access to our entire range of products and services that best meet your needs. Unless you object on behalf of your company, we may send you these offers by electronic means, telephone or postal mail, for the products and services of the DELTA IMMO Group.

3.3.3. We analyze your personal data to carry out standard profiling in order to personalize our products and offers To improve your experience and satisfaction, we need to determine which customer panel you belong to. To do this, we establish a standard profile from the relevant data that we select from the information: 

• that you have directly communicated to us during our interactions with you or when subscribing to a product or service; 

• resulting from your use of our various channels: sites and applications (such as if you are interested in digital, if you prefer a customer journey to subscribe to a product or service with more autonomy (selfcare)). Unless you object, we will carry out this personalization based on standard profiling. We can go further to better meet your needs, if you consent, by carrying out a tailor-made personalization as indicated below. 

3.4. Your personal data is processed if you have consented For certain personal data processing operations, we will provide you with specific information and ask for your consent. We remind you that you can withdraw your consent at any time. In particular, we ask for your consent for: 

• a tailor-made personalization of our offers and our products or services based on more sophisticated profiling to anticipate your needs and behaviors; 

• using your browsing data (cookies) for commercial purposes or to enrich the knowledge of your profile. Other consents to the processing of your personal data may be requested when necessary. We collect and use your personal data, namely any information that identifies you or allows you to be identified. Depending in particular on the type of product or service we provide to you and the interactions we have with you, we collect different types of personal data about you, including: 

• Identification data: for example, full name, gender, place and date of birth, nationality, identity card number, passport number, driving license number, vehicle registration number, photo, signature, customer identification number, proof of identity; 

• Contact information: (professional) postal address, email address, telephone number; 

• Economic, financial and tax information: for example, tax identifier, tax status, country of residence; 

• Education and employment information: for example, job, employer name; 

• Data collected as part of our interactions with you: your comments, suggestions, needs collected during our exchanges with you online during telephone communications (conversation), discussion by email, chat, chatbot, exchanges on our pages on social networks and your latest claims/complaints; 

• Data relating to your food preferences (only in the context of organizing events); 

• Connection data to online services: Your connection and tracking data such as cookies and tracers for non-advertising or analytical purposes on our websites, our online services, our applications, our pages on social networks; 

• Data from the video protection system (including video surveillance cameras); 

• Data concerning your devices (mobile phone, computer, tablet, etc.): IP address, technical characteristics and unique identification data;

• Login identifiers or personalized security devices used to connect you to our websites and applications.

We may collect sensitive data such as health data, biometric data, or data relating to criminal offences, in compliance with the strict conditions defined by data protection regulations. We collect personal data directly from you, however we may also collect personal data from other sources. We sometimes collect data from public sources: 

• publications/databases made available by authorities or official third parties (for example the Official Journal of the French Republic, the Trade and Companies Register, databases managed by financial sector supervisory authorities); 

• websites/social media pages of legal entities or professional clients containing information that you have made public (for example, your own website or your page on a social network); 

• public information such as that published in the press. We also collect personal data from third parties: 

• other entities of the DELTA IMMO Group;

• our customers (companies or individuals); 

• our business partners; 

• payment initiation service providers and account aggregators (account information service providers); 

• third parties such as fraud prevention agencies; 

• data brokers who are responsible for ensuring that they collect relevant information in a lawful manner. a. With DELTA IMMO Group entities As a member company of DELTA IMMO Group, we work closely worldwide with other potential group companies. Your personal data may therefore be shared between DELTA IMMO Group entities, when necessary, to: 

• comply with our various legal and regulatory obligations described above; 

• meet our legitimate interests which are: 

– to manage, prevent, detect fraud and risks including operational risk; 

– to ensure the security of information systems and premises; 

– carry out control and risk management operations; 

– ensure the management of contracts and payments, as well as the processing of disputes; 

– achieve some of our communication and marketing purposes; 

– conduct statistical studies and develop predictive and descriptive models for commercial, security, compliance, risk management and anti-fraud purposes; 

– improve the reliability of certain data concerning you held by other Group entities; 

– offer you access to all of the Group’s products and services that best meet your desires and needs; 

– personalize the content and prices of products and services.

b. With recipients, third parties to the DELTA IMMO group and subcontractors In order to achieve some of the purposes described herein, we may, when necessary, share your personal data with: 

• subcontractors who perform services on our behalf, for example technical service providers in real estate, IT services, printing, telecommunications, debt collection, consulting, distribution and marketing services; 

• banking and commercial partners, independent agents, intermediaries or brokers, financial institutions, counterparties, central repositories with whom we have links if such a transfer is necessary to provide you with services or products or to meet our contractual obligations or carry out transactions (for example banks, correspondent banks, depositories, issuers of securities, paying agents, exchange platforms, insurance companies, payment system operators, issuers or intermediaries of payment cards, mutual guarantee companies or financial guarantee organizations); 

• local or foreign financial, tax, administrative, criminal or judicial authorities, arbitrators or mediators, authorities or public establishments or institutions (such as the Banque de France, the Caisse des Dépôts et des Consignations), to whom we or any member of the DELTA IMMO Group are required to disclose data: 

– at their request; 

– as part of our defense, an action or a procedure; 

– in order to comply with a regulation or a recommendation emanating from a competent authority with regard to us or with regard to any member of the DELTA IMMO Group; 

• third-party payment service providers (information concerning your bank accounts), for the purposes of providing a payment initiation service or account information if you have consented to the transfer of your data to this third party; 

• certain regulated professions such as lawyers, notaries, or auditors when specific circumstances require it (litigation, audit, etc.) as well as to our insurers or any current or potential buyer of the companies or activities of the DELTA IMMO Group; 

• certain professionals specific to the real estate activity, in particular: 

– principals, owners, lessees/sellers; 

– lessors; 

– condominium associations; 

– certification bodies; 

– architect, technical design office, surveyors, real estate experts; 

– technical service providers; – business providers, real estate agents; 

– local rental observatories (national agency for housing information). 

In the event of international transfers from the European Economic Area (EEA) to a country outside the EEA, the transfer of your personal data may take place on the basis of a decision made by the European Commission, when it has recognized that the country to which your data will be transferred ensures an adequate level of protection.

In the event of a transfer of your data to a country whose level of protection of your data has not been recognized as adequate by the European Commission, we will either rely on an exemption applicable to the specific situation (for example, if the transfer is necessary to perform a contract concluded with you, such as when executing an international payment) or we will take one of the following measures to ensure the protection of your personal data: 

• standard contractual clauses approved by the European Commission; 

• binding corporate rules. To obtain a copy of these measures to ensure the protection of your data or to receive details relating to the place where they are accessible, you can send us a written request to DELTA IMMO 1 Rue Dulong – Évreux 27000 – France or by the online form at https://www.delta-immo.fr/contact. 

Personal data is retained for the duration of the contractual relationship and for the period necessary to comply with applicable laws and regulations, or for a period defined in light of operational constraints, such as accounting and to assert legal rights or respond to requests from regulatory bodies. 

For example, customer data is retained for the duration of the contractual relationship and may be retained for 5 years or 10 years from the end of the contractual relationship. For prospects, this data is retained for 3 years. 

In a world where technologies are constantly evolving, we regularly review this document and update it if necessary. We invite you to read the latest version of this document online, and we will inform you of any significant changes through our website or via our usual communication channels. 

Processing of personal data to combat money laundering and terrorist financing The filtering of our customer bases and transactions, reasonably designed to ensure compliance with applicable laws; Systems and processes to detect suspicious transactions and report suspicions to the relevant authorities; A compliance program reasonably designed to prevent and detect corruption and influence peddling in accordance with the « Sapin II » law. 

In this context, we are required to use: 

• public information available in the press on facts related to money laundering, terrorist financing or corruption; 

• knowledge of risky behavior or situations (existence of a suspicious transaction report or equivalent) that can be identified at the DELTA IMMO Group level. We may be required to process special categories of data or criminal data since the objective is to combat money laundering and terrorist financing. 

We carry out these checks when entering into a relationship, but also throughout the relationship we have with you, on yourself, but also on the transactions you carry out. 

At the end of the relationship and if you have been the subject of an alert, this information will be retained in order to identify you and adapt our control if you enter into a new relationship with an entity of the DELTA IMMO Group, or as part of a transaction to which you are a party. 

To meet our legal obligations, we exchange information collected for AML/CFT, anti-corruption or international sanctions purposes between DELTA Group entities.