1) Processing of personal data
As part of its activity, Hôtel des Ventes de Monte Carlo (HVMC) collects the following categories of data:
- Identity, telephone and postal contact details, email;
- Data relating to navigation on the website (timestamp, IP address of users, technical data relating to the equipment and browser used by users, cookies) and on digital platforms via sharing buttons and media (cookies and other tracers);
- Data relating to the management of user contacts (timestamp and subject of the request, follow-up, action taken, statistics);
- Data relating to the management of publications (object, sales presentations, follow-up, statistics);
- Data relating to the management of technical services (timestamp and subject of requests, follow-up, action taken, statistics);
- Website audience statistics and usage statistics for the online services offered by HVMC.
The data originates from:
- The staff in charge of the publication of the contents and the technical administration of the website;
- Internet users having access to the HVMC website;
- Staff of the technical service providers involved in the processing.
All data is not binding. Data collected for purposes other than audience measurement are mandatory to fulfill the request of the persons concerned.
The data controller is the company that defines for what purpose and how the personal data is used, either for the Hôtel des Ventes de Monte-Carlo (HVMC) site:
Monte-Carlo Auction House (HVMC)
SAM with capital of €100,
10, 12, QUAI ANTOINE IER / LE RUSCINO – Ground floor – LOT 1B,
98000 MONACO,RCI of Monaco n° 11S 05494,
The persons concerned by the processing are:
- Internet users with access to the HVMC website;
- HVMC staff in charge of the technical administration of the website as well as the publication of content;
- Experts who respond to individual requests from Internet users;
- The personnel of the service providers concerned.
2) Purpose of processing personal data
The purpose of the processing is to manage the website administered by the company HVMC. The treatment allows:
- Putting contact forms online;
- Putting contact forms online as part of a request for expertise;
- Sending newsletters to voluntarily registered persons;
- Technical administration directly linked to service providers (domain name registrar, third-party application maintenance);
- Website security management;
- Preparation and publication of content;
- Archiving of published content;
- The production of audience and usage statistics for the HVMC WEB site.
The data collected by HVMC is always collected for the purposes mentioned herein.
The legal bases of the processing are:
- The consent of the person concerned in the context of the newsletter;
- The processing is necessary for the execution of contractual or pre-contractual measures in the context of the management of the requests of the persons concerned;
- Processing is necessary for the purposes of the legitimate interests pursued by the controller
3) Shelf life
- The data collected as part of the contact forms for experts are kept for a period of ….. years from the request;
- Log data (connection logs, etc.) is kept for a period of … months from collection;
- The data necessary for the production of audience statistics and the use of online services (Google analytics) are kept for a maximum period of thirteen months unless the person concerned objects.
- The data collected as part of a request for information is kept for the duration of the processing of the request, as well as for the time necessary for probative purposes and for the management of disputes.
4) Recipient of personal data
Data controller:
HVMC does not sell personal information entrusted by its customers to third parties. However, in order to be able to provide all the appropriate services, this information may also be communicated to technical service providers.
HVMC certifies that this data cannot be used for purposes other than those referred to herein and ensures that the processing takes place in compliance with Monegasque regulations (Law n°1.165 of 23/12/1993 relating to the protection of personal information amended) and more specifically to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and to the free movement of such data.
Subcontractors:
Due to the partial outsourcing of the processing, in particular within the framework of the sending of newsletters approved by the client, such as social networks, the data required may be subject to a transfer outside Monaco and the European Union. In this case, HVMC ensures that this transfer complies with the legal framework: transfer to a country providing a sufficient level of protection, signature of standard contractual clauses issued by the European Commission or, for a service provider established in the United States, verification of its prior adherence to the Safe Harbor or Privacy Shield or request for authorization to transfer data to the United States from the Personal Information Control Commission (Monaco).
To know more : http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087
Furthermore, the publications are likely to be accessible outside the European Union given their presence on the Internet.
5) Confidentiality
This information is strictly confidential and processed in compliance with Law No. 1.165 of 23/12/1993 relating to the protection of personal information (for Monaco) and carried out in accordance with the provisions of Regulation (EU) 2016/679 of the Parliament European Parliament and of the Council of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
6) Customer rights
In accordance with the aforementioned provisions, the customer has a right of access, correction of limitation of data processing, opposition to processing, rectification and also:
Right to data portability: Since May 25, 2018, the Customer may, in certain circumstances, obtain personal data that he has communicated to HVMC (in a structured, usual and machine-readable format) in order to be able to reuse them somewhere else.
Right to erasure of data: The data subject may request the deletion or erasure of his personal data in certain cases, for example if he wishes to withdraw his consent. If the personal data has been shared with third parties, HVMC will notify them of the deletion where possible. At the customer's written request and within the limits of the regulations, we may indicate the subcontractors to whom we have communicated the data so that the Customer can contact them directly.
Right not to be the subject of a fully automated individual decision ("profiling"): The data subject has the right not to be the subject of a decision based solely on automated data processing, including the profiling and which produces legal effects against him or affects his situation in a similar way, unless this type of profiling is necessary for the conclusion or performance of a contract with HVMC. This processing is not performed by HVMC.
The data subject may exercise these rights. He may also exercise any requests or requests relating to these rights by telephone or by email to Customer Service at the following number and address: [email protected] / +377 00 00 00 00, specifying “Personal rights” in the subject line and attaching a copy of proof of identity.
If you feel that the answers you have been given are not satisfactory, you have the right to lodge a complaint with the supervisory authority, the CCIN – Commission de Contrôle des Informations Nominatives. »
7) Cookies
Our Cookie Management Policy can be viewed at the following link: Cookies policy
8) Withdrawal of consent
When consent constitutes the legal basis for the processing of personal data, the customer can always withdraw it, more particularly in the case of marketing communications (newsletter type) by using the link present in our marketing communications to automatically unsubscribe.
The withdrawal of consent will not affect the legality of the processing carried out after this withdrawal.