Your personal data
Icade and its affiliated companies (hereafter referred to as “ICADE” or “we”) attach great importance to the protection of your personal data and carefully monitor compliance with provisions relating to privacy and personal data processing. We are committed to abiding by French Data Protection Act No. 78-17 of January 6, 1978, amended by European Regulation No. 2016/679 of April 27, 2016 on personal data protection.
ICADE collects your data when you visit its website “icade-sante.fr” (the “website”) as well as when you interact and communicate with us.
ICADE is committed to protecting your privacy. This Data Protection Policy explains how we collect and use your personal data and how you can exercise your rights in relation to the use of your data.
The website is published by ICADE which is responsible for processing your personal data.
The purpose of this Data Protection Policy (hereafter referred to as the “Policy”) is to set out how and when ICADE, as a data controller, collects, uses and communicates the personal data that you provide in order to meet your needs and optimise and improve the quality of the services we offer you.
This Policy applies to all users, whether registered on our website or not, and related services provided by ICADE.
We collect the data you provide directly when:
● You apply for a job online or email us your CV
● You interact and communicate with us or our services for other reasons
● You ask to receive information from ICADE
● You create a user account on one of our websites
● You contact us by phone
● You send us an email
● You submit a contact form
● You reserve a meeting room and/or opt to have food delivered
● You are authorised to access one of ICADE’s common areas via an access card
In conducting our business, we sometimes need to request your personal data and/or that of your family members, such as:
● Your first name, surname, postal address, title, date of birth, email address, phone number, language, occupation, company, the relevant business park(s);
● Your location data;
● Your postal/billing address;
● Proof of address;
● National ID card, passport or residence permit;
● Your preferences and interests;
● IP/MAC address;
● Visitor and browsing data;
● Other information you wish to communicate;
● Other information that we would be legally required to collect.
Mandatory fields are marked with an asterisk.
It should be noted that some data is automatically collected as a result of your activity on one of our websites.
If you contact us by phone, your call may be recorded for training purposes or to improve services and we will gather information related to your call.
When you apply for a job, we collect your CV or cover letter, including the information provided in these documents such as your identity, interests, date of birth, nationality, personal and professional experience.
We also collect data from third-party websites, such as advertising and social media platforms. At that time, you are made aware of the data that we receive from the third party involved.
Lastly, it should be pointed out that as part of the Wi-Fi hotspot provided by ICADE, the collection of browsing data includes the web pages visited and the date and time of the visit.
ICADE will only use your data where we have an appropriate and relevant legal ground to do so.
ICADE collects your personal data where the processing is necessary to perform a contract or take pre-contractual steps at your request, based on your consent and the legitimate interests of ICADE or a third party, or pursuant to a legal or regulatory obligation.
We use, store and process your data in order to meet your needs, support our business relationship, optimise our services and tools to create and maintain a more secure environment of trust and ensure our compliance with our legal obligations as set out below.
We collect your consent for the following purposes:
● If you accept to receive information from ICADE by ticking a dedicated opt-in box;
● To conduct surveys.
For the following purposes, your data is necessary for the legitimate interests pursued by ICADE:
● Requesting information;
● Completing the registration form;
● Managing the hiring process, particularly by enabling applicants to apply online or email their applications;
● Managing and following up requests from the website’s users in addition to prospective clients who may contact us by phone or email, via our website’s “Contact us” feature;
● For internal statistical purposes; Managing access via an access card;
● Providing you with access to our website and some of our services;
● Ensuring the security of property and individuals via CCTV.
For the following purposes, your data is necessary for the performance of contracts:
● Preparing and drafting contracts;
● Executing and monitoring contracts;
● Managing incidents and assistance requests related to building use;
● Providing you with a Wi-Fi network;
● Managing and monitoring access to buildings in the property portfolio.
We can also process your data in order to comply with our legal obligations to:
● Fight against money laundering and the financing of terrorism (KYC);
● Fight against fraud and corruption, and manage conflicts of interests;
● In the event of formal demands or requests from authorities;
● Handle your claims;
● Other legal obligations.
For the specific purposes set out above, we may transfer your data to ICADE Group entities.
We also share your data with third-party service providers:
● Providers of business development, marketing and advertising services enabling you to receive commercial offers and targeted advertising on behalf of ICADE;
● IT service providers to host your data;
● Other third parties to provide you with a service that you requested through a partner or a promotion offered by a third party or ourselves.
In the event our business is sold or merged with another company, your data might be disclosed to our advisers, in addition to any other potential buyer and its advisers, and be transferred to the new transferees or beneficiaries of the business.
We may also share your data:
● In response to a request for information from a competent authority, if we believe that the disclosure of this information is legal or required by law, applicable regulations or in the context of legal proceedings;
● With law enforcement, judicial or administrative authorities or any other authorised third parties.
We share your data with ICADE Promotion’s internal departments and service providers. They will process such data solely within the confines of the aforementioned purposes.
Should ICADE transfer data outside the European Economic Area (EEA), we will only do so in compliance with applicable laws and regulations. For international transfers, ICADE Promotion relies solely on adequacy decisions adopted by the European Commission or standard contractual clauses which will be entered into with third parties.
Our website may use social media sharing plug-ins and other related tools which enable you to share your activity on our website with other applications, sites or media.
The use of these features allows you to share information with your friends or the general public based on the settings of your social media account. For more information on how these social media platforms process the data that you provide or share when using them, please read their privacy policies. We exclude all liability with respect to these policies.
ICADE ensures the security, confidentiality and integrity of the personal data you share on our website icade-sante.fr and our applications by means of technical and organisational measures. ICADE has appointed a Data Protection Officer responsible for making sure that we process personal data in compliance with the applicable data protection rules, keeping a register to provide information about ICADE’s solutions and their processing, as well as ensuring the exercise of your rights.
We will only retain your data for as long as necessary to fulfil the purposes set out in this Policy.
If your data is no longer needed to fulfil the purposes set out in this Policy, the data will be regularly deleted unless it must be retained for a longer period to (i) ensure compliance with retention obligations required by law in addition to accounting and tax requirements, (ii) preserve evidence during the applicable limitation period, and (iii) exercise ICADE’s rights in the event of a legal dispute or litigation throughout the proceedings or investigation.
Similarly, when you create an account on our website, we delete your data if your account has remained inactive for more than three years. We will send you an email informing you of this before your account is deleted.
The French Data Protection Act No. 78-17 of January 6, 1978, amended by European Regulation No. 2016/679 of April 27, 2016 on personal data protection, provides the following rights for individuals.
1. Right of access
You may make a request to ICADE to obtain confirmation that your personal data has or has not been processed by our departments. If your data has been processed, you can request a copy.
2. Right of rectification
You have the right to request that ICADE rectify inaccurate personal data in its database.
3. Right to erasure (“right to be forgotten”)
You have the right to obtain from ICADE the erasure of your personal data without undue delay. ICADE could opt to anonymise your data.
4. Right to object and right to withdraw your consent
If you wish to not or no longer appear in a file in our databases, you may do so by exercising one of these rights at any time.
5. Right to restriction of processing
You may request the restriction of processing of your personal data pending verification (for example: to exercise your right to object, ICADE must verify whether or not any legitimate reasons would warrant further processing).
6. Right to data portability
It is the right to obtain the transmission of your personal data, in structured, commonly used and machine readable formats, to ourselves or another data controller if it is technically feasible.
7. Right to define instructions regarding storage, erasure and communication
You are also entitled to leave instructions for retaining, erasing and disclosing your personal data after your death.
8. Right to lodge a complaint with the French Data Protection Authority (CNIL)
You may file a complaint if you feel that the processing of your personal data constitutes a violation of the regulations. If you wish to obtain further information about your rights, and more particularly on the last-mentioned right, visit the French Data Protection Authority’s (Commission Nationale de l’Informatique et des Libertés, or CNIL) website.
You may exercise these rights at any time by contacting our Data Protection Officer by sending an email, accompanied by a proof of identity, to the following address: firstname.lastname@example.org or by postal mail to: DPO ICADE Promotion - Immeuble Open - 27, rue Camille Desmoulins - CS 10166 - 92445 Issy-les-Moulineaux Cedex, France. If we have reasonable doubts about your identity and if the situation requires it, we might ask you for additional information, which could include a photocopy of an identity document bearing the holder’s signature.
You may also lodge a complaint with the French Data Protection Authority (CNIL) if you believe that the processing of your personal data has infringed upon your right to data protection (https://www.cnil.fr/fr/plaintes).
You may choose to opt out of receiving marketing messages from us by following the opt-out instructions provided to you in those messages.
We may update this Policy at any time. If we make significant changes to the way in which we process your personal data or to this Policy, we will provide this information on our website or through other means, as in an email for example.
We encourage you to regularly consult this Policy to keep abreast of the latest information on our privacy practices
This Data Protection Policy is governed by French law and any dispute arising in connection with it will fall within the exclusive jurisdiction of the French courts.