This document, to which the General Terms and Conditions of Use of the site
www.millon.com/ (hereinafter the "Site") is to inform you of our practices for processing and protecting your Personal Data, as defined below.
We invite you to read all the information we provide carefully and if you have any questions, please contact us.
" Data ": means any information that directly or indirectly identifies a natural person by reference to an identification number or to one or more elements that are specific to that person. You will never be asked to provide so-called "sensitive" personal data, such as your racial or ethnic origins, your political, philosophical or religious opinions, or your income or tax situation.
Your Data is only collected for the strict purpose of using and understanding the Site and its Services and for the purposes described in article 4.
The Sales Operator acts as the controller of your Data which is collected when you use the Site to provide you with the Services. This means that the Sales Operator is responsible in particular for their collection, security and use for the purposes described herein in compliance with Data protection rules. The Sales Operator does not rent or sell its customer files to third-party commercial companies unrelated to the Services as defined in the General Terms and Conditions of Use of the Site.
Newsletter: Informational, promotional or advertising e-mail sent by the Sales Operator to Users who have provided their contact details with a view to the performance of the Sales Operator's Services.
" Services ": All the services offered by the Sales Operator on the Site and described in article 3 of the General Terms and Conditions of Use;
" User " / " You ": refers to any person using the Site's Services.
2 - CONSENT
By using our Services, you undertake to provide true information about yourself and you understand and accept that your Data may be collected, used, stored and transmitted to third parties as described below for the purposes of providing the Services you wish to benefit from.
Providing false information is contrary to the General Terms and Conditions of Use of the Site, which can be accessed at the following URL link: https: //www.millon.com/conditions-generales-utilisation
3 - DATA COLLECTED
We may collect the following categories of Data:
a. Browsing the Site
Connection data. Each time you connect to the Site, we passively collect information such as, in particular, the IP address of your computer, the date and time of connection, and information about your browser.
Browsing data. We also collect information enabling us to identify how you access the Site, which pages you visit and for how long.
b. Telephone Buy Orders and Auctions and online valuation requests
When you place a Purchase Order or a Telephone Bid, or when you request a free valuation online, we collect certain information such as your first and last names, your postal address, your e-mail address, your telephone number, your date of birth as well as the history and details of your purchases, the number and amounts of your bids.
This information is required by the Sales Operator in order to comply with the legal obligation to formally identify its customers, to which it is subject in the context of the fight against money laundering in particular.
c. Subscription to a Newsletter
In accordance with the General Terms and Conditions of Use, when you subscribe to a Newsletter on the Site, you will be asked to provide a certain amount of Data, in particular your full name, postal address, e-mail address, telephone number, date of birth, etc
This information is required by the Sales Operator in order to send you Newsletters corresponding to the desired subject and sales specialities.
d. Bank details
When you pay for an auction slip online, your bank details are requested to ensure payment of your slip or to guarantee your participation in the auction.
When you make an advance deposit, your details are requested to guarantee your payment for a lot in the event of it being awarded to you. The Sales Operator may decide to deduct the amount deposited before the sale as a guarantee pending your full payment.
However, this Data is transmitted directly to the Sales Operator's payment service provider, the company Ingenico, which is PCI-DSS certified through its own services.
If you refuse to pay your bill online, the Sales Operator will contact you and proceed to pay your bill using the means described on the Site.
We do not keep this Data, which is collected and kept securely by the Sales Operator's payment service provider, Ingenico, which is PCI-DSS certified. This standard is an international security standard whose objectives are to ensure the confidentiality and integrity of cardholder data and thus secure the protection of card and transaction data.
When you place a Purchase Order or a Telephone Bid request on the Site, your bank details are requested by the Sales Operator in order to check the validity of your bank account. However, this data is only kept for the duration of the auction.
4 - PURPOSES OF COLLECTING YOUR DATA
Your Data is collected to enable us to provide you with the Services and to meet one or more of the following purposes:
-To enable you to use the Site,
-To provide a history of the Purchase Orders and Telephone Auction requests submitted,
-To ensure the proper execution of transactions initiated by Users, such as Purchase Orders and Telephone Auctions,
-Provide a free valuation service for the properties offered;
-To offer an efficient customer service, particularly in terms of assistance in using the Site and complaint management,
-Build up a file of Users, customers and prospects,
-To send Newsletters, requests and promotional messages according to the preferences selected from the categories of items offered,
-To compile commercial statistics and statistics on internal use of the Services,
-To manage any disputes arising from the use of the Services and the Site,
-Fight against fraud,
-Manage your requests for access, rectification and opposition to the collection of your Data,
-Comply with our legal and regulatory obligations.
When we collect your Data, we inform you whether certain Data must be filled in or whether they are optional. If you do not fill in these mandatory fields, you will not be able to access the Services.
You can subscribe to our Newsletter by ticking a box on the corresponding page of the Site.
You can unsubscribe from the Newsletters at any time by clicking on the unsubscribe link at the bottom of the emails you receive.
If the unsubscribe link does not work, you can unsubscribe by sending a message to the address given in Article 13.
5 - DATA RECIPIENTS
a. Our service providers
We share your Data with our own service providers located in the European Union, in particular to carry out services and actions at our request and on our behalf, such as checking the validity of your telephone number, sending promotional and marketing emails or SMSs or allowing us to manage your transactions.
We use and process your connection data in order to identify, delimit and eliminate malfunctions and errors in telecommunications systems.
We may also use connection data to detect any illegal use of telecommunications systems and services.
b. Legal authorities
In accordance with the legal provisions in force, the Sales Operator may be required to provide information to the competent authorities and courts for the purposes of criminal proceedings. The Sales Operator may not inform you of the disclosure of your Data to authorised third parties.
Data retention period
We only retain your Data for the period necessary to perform our Services and for up to three (3) years after you subscribe to the Newsletter.
At the end of this three (3) year period, the Sales Operator may contact you again to ask if you wish to continue receiving information about the Sales Operator's products and services. In the absence of positive and explicit action on your part, the Data concerning you will be archived or deleted in accordance with the legal provisions in force.
In accordance with article L.123-22 of the French Commercial Code, the Sales Operator archives all the data of successful bidders for a period of ten (10) years from the end of the contractual relationship, for invoicing and accounting purposes.
Similarly, the Data of successful bidders is archived as part of the management of contracts between traders and non-traders or between traders for a period of five (5) years from the end of the contractual relationship in accordance with article L.110-4 of the French Commercial Code. In accordance with article 213-1 of the French Consumer Code, this period may be extended to ten (10) years when the contract is concluded electronically with a consumer and relates to a sum equal to or greater than 120 euros and the Sales Operator guarantees access to the winning bidder at all times if the latter so requests.
At the end of this period, the Sales Operator undertakes to delete or anonymise the data in its possession.
7 - SECURITY
We have implemented technical and organisational security measures to guarantee the security, integrity and confidentiality of all your Data in order to prevent it from being lost, stolen, damaged, distorted or distributed to unauthorised persons.
We store your Data on servers located within the European Union.
8 - COOKIES
Cookies are text files stored in your browser. They are created when a User's browser loads a given website: the site sends information to the browser, which then creates a text file.
Each time you return to the same site, the browser retrieves the file and sends it to the website server.
You may also continue browsing while refusing cookies under the conditions described below.
a. Cookies used
The Sales Operator uses the services of Google Analytics to collect information about your use of the Site.
Google Analytics is a marketing analysis service operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.
Google Analytics uses codes made up of text and numbers which will be stored on your device and which will make it possible to analyse the use of the Services.
The information generated by the cookie about your use of the Services (including your IP address) will be transferred to and stored by a Google server.
Google will use this information for the purpose of evaluating your use of the Services, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
Google Analytics stores information about
-The pages you visit on the Site;
-The time you spend on each of these pages;
-The links that brought you to the Site;
-What you click on while browsing the Site.
We do not use re-targeting advertising cookies or any other advertising pixel service to indicate whether users have carried out specific actions on a site after clicking on an advertisement appearing on one of the pages.
Google Analytics uses the following cookies:
Used to count how many people visit the Site, distinguishing between users who have already visited the Site.
Used to monitor the frequency with which web page requests are made
b. Purpose of using cookies
The cookies we issue enable us to:
-To compile statistics and volumes of visits to and use of the various components of the Site (sections and content visited, path taken), enabling us to improve the interest and ergonomics of our Services;
-To adapt the presentation of the Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Site, depending on the hardware and display or reading software that your terminal is equipped with.
c. Managing cookie settings
If you wish to continue browsing while refusing cookies, you can change your browser settings at any time.
Each browser has a different configuration for managing cookies and your choices. This is described in your browser's help menu, which will tell you how to modify your cookie preferences. Below you will find information about the main browsers.
We accept no responsibility for the consequences of the impaired operation of certain Services resulting from the impossibility of saving or consulting the cookies required for their operation and which you have refused or deleted.
You may also choose to specifically and solely refuse Google Analytics cookies by installing the add-on module accessible by clicking on the following link:
9 - USER RIGHTS
The Data provided is necessary for the performance of the Services to which you have subscribed. You may not therefore withdraw your consent to the processing of Data necessary for the performance of the Service, unless you cease to use the Services.
You may, however, consult, modify or request the deletion of your Data for legitimate reasons at any time using the contact details given in article 13 below. The Sales Operator will provide information on the measure taken within one (1) month of your request. Requests to limit the processing or portability of Data may be made under the same conditions. This period of one (1) month may nevertheless be extended by two (2) months, provided that you are informed of the reasons for the extension within the period of one (1) month.
You may also object at any time to the processing of your Data to which you have previously given your specific consent for canvassing purposes.
The Sales Operator provides you, free of charge, with information relating to the Data stored concerning you. The information may be provided electronically if you so wish.
For your security, please understand that in the event of a request for information or modification, we must verify your identity. Your proof of identity will not be retained following your request.
The Sales Operator undertakes to inform all Data processing recipients of your request.
10- FATE OF DATA AFTER DEATH
You have the right to formulate, with your specific consent, directives relating to the conservation, deletion and communication of your Data after your death. You may modify or revoke these instructions at any time.
You may appoint a person to carry out your instructions. In the event of your death, this person is then entitled to take cognisance of the instructions and request that they be implemented from the Sales Operator. If no person has been designated or, unless otherwise instructed, in the event of the death of the designated person, your heirs are entitled to take cognisance of your instructions and request that they be implemented by the Sales Operator.
In the absence of instructions or a statement to the contrary in your instructions, your heirs may exercise your rights to the extent necessary for :
-Organising and settling your estate. In this respect, your heirs may access the Data processing that concerns you in order to identify and obtain communication of information useful for the liquidation and division of the estate. They may also receive communication of digital assets or data similar to family mementos, which may be passed on to the heirs;
-The Sales Operator takes the death into account. In this respect, your heirs may object to the continued processing of your Data or have it updated.
If your heirs so request, the Sales Operator must prove, at no cost to the applicant, that it has carried out the operations required by the heirs.
Disagreements between heirs over the exercise of these rights shall be brought before the competent High Court.
11- MODIFICATION OF THE CONFIDENTIALITY POLICY
If you do not accept these changes, you agree to stop using the Services. Otherwise, your use of the Services will be subject to the terms of the new version of the Confidentiality Policy.
Any access to the Services after notification by the Sales Operator of the new version of the Confidentiality Policy shall be deemed to be your full acceptance of this new version of the Confidentiality Policy.
Telephone bidding and online estimate requests.
The Sales Operator also reserves the right to modify or suspend, without reason, all or part of the Services.
Any modification or suspension of the Services does not entitle you to any compensation whatsoever.
12 - DISPUTES
In the event of a dispute regarding the use of your Data, you may refer the matter to the Commission Nationale de l'Informatique et des Libertés (French Data Protection Authority).
13 - CONTACT
You may send any questions you may have concerning your Data and the way in which we use it directly to: email@example.com or to the following postal address
Millon - 19 rue de la Grange-Batelière - 75009 Paris
If you wish to exercise your right to oppose, question, access, rectify or withdraw your Data, you can contact us at the same addresses under the conditions described in article 9 above.
Since this data is kept solely for evidential purposes, it must be archived so that it no longer appears in the active database and can only be accessed by persons authorised to do so by virtue of their function.