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Privacy Policy

This Privacy Policy is established in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR) and French Law No. 78-17 of 6 January 1978, as amended, relating to information technology, data files, and civil liberties.

It applies to all personal data processing activities carried out by the Union Patronale de la Charente (UPC) in connection with the CAP CHARENTE Platform, whether such data is collected directly from Users (Visitors and Contributors) or included within economic land Listings published on the Platform.

In the event of any inconsistency between this Privacy Policy and the Terms and Conditions of Use (TCU) regarding personal data protection, this Privacy Policy shall prevail.

ARTICLE 1 – DEFINITIONS

For the purposes of this Privacy Policy:

  • CNIL: the French Data Protection Authority (Commission Nationale de l'Informatique et des Libertés).
  • Consent: any freely given, specific, informed, and unambiguous indication of a data subject’s wishes by which they signify agreement to the processing of personal data concerning them.
  • Contributor: any natural or legal person whose account has been approved by the UPC and who is authorized to create, publish, and manage economic land Listings on the Platform.
  • Cookies (or Trackers): small text files stored on a User’s device for functional, statistical, or other purposes.
  • Personal Data: any information relating to an identified or identifiable natural person within the meaning of Article 4(1) GDPR.
  • Hosting: the technical service through which servers are made available for storing and processing Platform data. All Platform data is hosted exclusively within the European Union.
  • Data Subject: any natural person whose personal data is processed by the UPC.
  • Controller: the Union Patronale de la Charente (UPC), which determines the purposes and means of processing.
  • Processor: any entity processing personal data on behalf of the UPC.
  • Processing: any operation performed on personal data as defined by Article 4(2) GDPR.
  • User: any individual or legal entity accessing the CAP CHARENTE Platform.
  • Personal Data Breach: a security incident leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

ARTICLE 2 – DATA CONTROLLER

The Data Controller is:

Union Patronale de la Charente (UPC)
33 rue de l'Arsenal – 16000 Angoulême – France
Phone: +33 (0)5 45 95 15 51
Email: upmedef16@upmedef16.com

ARTICLE 3 – DATA PROTECTION CONTACT

Any questions regarding personal data protection may be addressed to: contact@16h33.fr.

ARTICLE 4 – PERSONAL DATA COLLECTED

4.1 Contributor Account Data

When creating and managing a Contributor account, the UPC may collect:

  • First and last name
  • Occupation
  • Role (owner, representative, public authority, etc.)
  • Postal address
  • Email address
  • Telephone number
  • Date of birth
  • Login credentials (encrypted password)
  • Connection logs, IP addresses, and access timestamps

4.2 Data Included in Listings

Economic land Listings may include technical and descriptive information about properties, including personal data where a Contributor or contact person is identified.

Data categories may include:

  • Property identification and location
  • Offer characteristics (surface area, availability, pricing, contact details, intended economic use)
  • Accessibility information
  • Utilities and infrastructure
  • Environmental constraints
  • Land and lot information

4.3 Automatically Collected Data

During browsing, technical information may be collected automatically, including IP addresses, browser type and version, operating system, pages viewed, session duration, and connection timestamps.

ARTICLE 5 – PURPOSES, LEGAL BASES, AND RETENTION PERIODS

Personal data is processed for the following purposes:

  • Creation and management of Contributor accounts (contractual necessity)
  • Verification and approval of Contributor applications (legitimate interest)
  • Publication and management of economic land Listings (contractual necessity and legitimate interest)
  • Moderation and compliance monitoring (legitimate interest)
  • Connecting Users with local institutional stakeholders (legitimate interest or consent)
  • Platform security and fraud prevention (legitimate interest)
  • Audience measurement and Platform improvement (consent or anonymized legitimate interest)
  • Compliance with legal obligations (legal obligation)

Retention periods vary depending on the processing activity and comply with GDPR requirements.

ARTICLE 6 – RECIPIENTS OF PERSONAL DATA

Internal Access

Personal data is accessible only to authorized UPC personnel involved in administration, moderation, and operation of the Platform.

External Recipients

Data may be disclosed to:

  • The hosting provider acting as a Processor
  • The IT service provider responsible for development and maintenance
  • Competent authorities where required by law

No personal data is sold, rented, or transferred for commercial purposes.

ARTICLE 7 – TECHNICAL SERVICE PROVIDERS

7.1 Hosting Provider

The UPC uses a specialized hosting provider acting as a Processor under Article 28 GDPR. A data processing agreement ensures compliance with GDPR requirements, including confidentiality, security, breach notification, audit rights, and EU-only hosting.

7.2 IT Service Provider

The IT service provider is responsible for development and maintenance. Any incidental access to personal data is strictly limited, contractually protected by confidentiality obligations, and governed by the principle of data minimization.

ARTICLE 8 – RIGHTS OF DATA SUBJECTS

In accordance with Articles 15–22 GDPR, individuals have the following rights:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Right to withdraw consent at any time
  • Right to establish post-mortem instructions regarding personal data

Requests may be submitted by email to contact@16h33.fr or by post to:

Union Patronale de la Charente (UPC)
Data Protection Contact
33 rue de l'Arsenal
16000 Angoulême – France

The UPC will respond within one month, extendable by two additional months where necessary.

ARTICLE 9 – RIGHT TO LODGE A COMPLAINT

Any person who considers that the processing of their personal data violates the GDPR may lodge a complaint with the CNIL:

CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07 – France
www.cnil.fr

ARTICLE 10 – DATA SECURITY

The UPC implements appropriate technical and organizational measures to ensure a level of security appropriate to the risks involved, including:

  • Password encryption
  • HTTPS/TLS encryption
  • Individual authentication mechanisms
  • Role-based access controls
  • Access and activity logging
  • Regular backups
  • Staff awareness and training
  • Confidentiality obligations for service providers
  • Personal data breach management procedures compliant with GDPR

Despite these measures, absolute security cannot be guaranteed.

ARTICLE 11 – DATA HOSTING AND LOCATION

All Platform data, including personal data, is hosted exclusively within the European Union.

Hosting Provider:

ALWAYSDATA SARL
91 rue du Faubourg Saint-Honoré
75008 Paris – France

Servers are physically located in France and benefit from certifications including ISO 27001, ISO 22301, ISO 50001, and PCI-DSS.

No personal data is hosted or processed outside the European Union or the European Economic Area.

ARTICLE 12 – INTERNATIONAL DATA TRANSFERS

At the date of entry into force of this Privacy Policy, no transfers of personal data outside the EU/EEA are carried out. Should such transfers become necessary in the future, the UPC will implement appropriate safeguards in accordance with Chapter V GDPR and update this Privacy Policy accordingly.

ARTICLE 13 – COOKIES AND TRACKERS

Strictly Necessary Cookies

These cookies are essential for the operation of the Platform and include session management, authentication, consent preferences, and security mechanisms.

Analytics Cookies (Consent Required)

  • Google Analytics 4 (GA4): audience measurement and website performance analysis. Data retention: up to 14 months.
  • Google Tag Manager: tag management solution that facilitates deployment of analytics and marketing tools.
  • Axeptio: consent management platform used to record and manage user cookie preferences. Consent records are retained for up to 6 months.

Functional Cookies

These cookies improve user experience by remembering settings such as language preferences and search filters.

Cookies are retained for a maximum period of 13 months, in accordance with CNIL recommendations.

Users may manage their preferences at any time through the cookie management tool available on every page of the Platform.

ARTICLE 14 – CHANGES TO THIS PRIVACY POLICY

The UPC reserves the right to modify this Privacy Policy at any time to reflect legal, regulatory, technical, or operational developments.

In the event of substantial changes, registered Contributors will be notified by email. Continued use of the Platform after notification constitutes acknowledgment of the updated version.

The current version of this Privacy Policy remains permanently accessible from all pages of the Platform.