Personal data protection policy:

As part of its business activities, Groupe ASCOMA collects the following categories of data. Our commitments in this area are detailed below:

 Processing of personal data

As part of its business activities, Groupe ASCOMA collects the following categories of data:

• Identity, telephone and postal address details, email
• Website navigation data (time stamp, IP address of users, technical data relating to the equipment and browser used by users, cookies) and digital platform data via share buttons and media (cookies and other tracers)
• Data relating to the management of user contacts (time stamp and subject of the request, follow-up, actions taken, statistics)
• Data relating to the management of publications (subject, presentation of offers, monitoring, statistics)
• Data relating to the management of technical services (time stamp and subject of requests, monitoring, follow-up, statistics)
• Website traffic statistics and use of online services offered by Groupe ASCOMA.

The data originate from:

• The staff in charge of the publication of content and the website’s technical administration
• Internet users having access to the ASCOMA website
• Staff of the technical service providers involved in the processing

Not all data is mandatory. The data collected for purposes other than for analysing website traffic are mandatory to fulfil the request of the individuals concerned.

The data controller is the company that defines for what purpose and how personal data is used, being for the Monte Carlo Auction House (ASCOMA) site:

ASCOMA
SAM au capital de 5.000 000, 00 €,
24, Boulevard PRINCESSE CHARLOTTE, BP133, 98000 MONACO,
RCI de Monaco n° 01S 03913

The individuals involved in the processing are:

• Internet users having access to the ASCOMA website
• ASCOMA staff in charge of the technical administration of the website as well as the publication of content
• Authorized employees who respond to individual requests from Internet users and any individual who contacts ASCOMA via online forms (applications, information and others)

PURPOSE of processing of personal data

• The purpose of data processing is to manage the website administered by ASCOMA. The processing allows:
• Online posting of contact forms
• Online posting of contact forms as part of an application for a job offer made by ASCOMA
• Sending newsletters to individuals who have registered voluntarily
• 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 statistics on website traffic and use of the ASCOMA website.

The data collected by ASCOMA is always collected for the purposes mentioned herein.

The legal bases of the processing are:

• The consent of the individual concerned in the context of the newsletter
• Processing is necessary for the execution of contractual or pre-contractual measures as part of managing requests from the individuals concerned
• Processing is necessary for the purposes of the legitimate interests pursued by the data controller.

STORAGE LIFE

• The data collected as part of the contact forms intended for the specialists are kept for the duration of the processing of the request
• Log data (connection logs, etc.) are kept for a period of one year from the date of collection
• The data necessary for the production of statistics for website traffic and the use of online services are kept for a maximum period of six months unless the individual concerned objects
• The data collected as part of managing the commercial relationship are kept for the duration of the relationship, subject to legal provisions to the contrary
• The data collected as part of a request for information is kept during the processing time of the request, as well as for the length of time required for evidentiary purposes and dispute management
• In all cases, the data is kept in the back office and on the website’s servers for two years from the date of collection.

• DESTINATAIRE RECIPIENT OF PERSONAL DATA

DATA CONTROLLER

ASCOMA does not sell its clients’ personal information to third parties. However, in order to be able to provide all the appropriate services, this information may be communicated to technical service providers.

ASCOMA 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 (Act No. 1.165 of 23 December 1993 as amended, relating to personal data protection) and more specifically the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and to the free flow of such data.

CONFIDENTIALITY

This information is strictly confidential and processed in compliance with Act No. 1.165 of 23 December 1993 relating to personal data protection (for Monaco) and in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and to the free flow of such data. 

Rights of the individual concerned

In accordance with the aforementioned provisions, the individual whose data is processed benefits from a right of access, a right to restrict data processing, a right to object to processing, a right of rectification, and also to the following:

Right to data portability: Since 25 May 2018, the individual concerned may, in certain circumstances, obtain personal data that they have communicated to ASCOMA (in a structured, commonly used and machine-readable format) in order to be able to reuse them elsewhere.

Right to erasure of data: The individual concerned may request the erasure of their personal data in certain cases, for example if they wish to withdraw their consent. If personal data has been shared with third parties, ASCOMA will notify them of the deletion to the extent possible. On a written request from the individual concerned, and within the limits of the regulations, we can specify the subcontractors to whom we have communicated the data so that the individual concerned can contact them directly.

Right not to be the subject of a fully automated individual decision (“profiling”): The individual concerned has the right not to be the subject of a decision based solely on automated processing of data, including profiling, and which produces legal effects against them or affects their situation in a similar way, unless this type of profiling is necessary for the conclusion or execution of a contract with ASCOMA. We do not perform profiling.

The individual concerned can exercise these rights as well as submit all requests or queries relating to these rights, by telephone or email, to the data protection officer at the following number and address: dpo@ascoma.com / +377 97 97 22 22. They should specify “Personal rights” in the subject line of the email and attach a copy of their proof of identity.

If you believe that the answers given to you are not satisfactory, you have the right to lodge a complaint with the supervisory authority, the Commission for the Monitoring of Personal Information (CCIN).

COOKIES

Our Cookie Management Policy can be viewed at the following link: Cookie Management Policy

Withdrawal of consent

When consent constitutes the legal basis for the processing of personal data, the individual concerned can always withdraw it, especially in the case of marketing communications (such as a newsletter), by using the link in our marketing communications to unsubscribe automatically.

The withdrawal of consent will not affect the legality of the data processing carried out after this withdrawal.