01 Data controller
DAMA, a real estate agency established in Nice, is the controller for the processing described in this policy.
DAMA — simplified joint-stock company
Le Gilly, 74 avenue Alfred Borriglione
06100 Nice, France
SIREN : 918 458 308
SIRET : 918 458 308 00015
RCS Nice : 918 458 308
DAMA is represented by its president, DAMA INVEST, itself represented by its manager, Ms Valeriia Dankovtceva.
Contact us about your personal data
Email: fm@dama-agency.com
Telephone: +33 6 45 86 86 13
Postal address: DAMA — Data Protection, Le Gilly, 74 avenue Alfred Borriglione, 06100 Nice, France.
02 Data that may be collected
Depending on how you use the website and the nature of your project, DAMA may process:
- your first and last names and contact details;
- information about your property project: purchase, sale or rental, property type and location, budget, availability, criteria and the reference of the relevant property;
- the content of your messages, attachments, emails or conversations;
- information required for a viewing, valuation, mandate or contractual relationship;
- where required by law, supporting documents needed for identity checks and anti-money laundering and counter-terrorist financing obligations;
- your marketing communication preferences and evidence of your consent;
- technical browsing data: IP address, device, browser, pages viewed, traffic source and information obtained through authorised cookies.
Required fields are identified in the forms. Without this information, DAMA may be unable to respond to your request or provide the requested service.
Source of the data
Data is collected mainly from you through the website forms, telephone, email or WhatsApp exchanges, as well as during a viewing, valuation or the preparation of a contract. Browsing data is collected when you authorise the relevant trackers.
If DAMA receives data from a partner, a principal or a publicly accessible source, the required information is provided at first contact within the time limits set by law.
03 Purposes, legal bases and retention periods
DAMA limits each processing activity to what is necessary for the stated purpose. The periods below are indicative and may be extended where required by a legal obligation or the defence of legal rights.
ProcessingLegal basisIndicative retention period
Information, callback or viewing requestPre-contractual steps requested by the data subjectTime needed to handle the request, then up to 3 years after the prospect’s last active contact
Property search and recommendationsPre-contractual steps; consent where the communication constitutes marketingUp to 3 years after collection or the prospect’s last active contact
Valuation, sale, purchase or rentalPre-contractual steps and performance of the contractDuration of the relationship, followed by archiving for the statutory periods, generally 5 years
Administrative, accounting and dispute managementLegal obligation and legitimate interestDepending on the document; notably 10 years for accounting records
Due diligence and anti-money launderingLegal obligationPeriod required by law, generally 5 years after the end of the relationship or transaction
Marketing by email or SMSConsent, except where a legal exception applies to certain existing clients for similar servicesProspects: 3 years; clients: duration of the relationship, then 3 years
Telephone marketingSpecific prior consentConsent: maximum 1 year; evidence: at least 3 years
Audience measurementConsent for non-exempt trackersAccording to the periods actually configured in the tools
Security and technical logsDAMA’s legitimate interest in securing the websiteA period proportionate to the security purpose
Data-subject requests and objectionsLegal obligationTime required to handle the request; suppression list retained for at least 3 years
04 Callback requests and telephone marketing
When you expressly ask to be called back about a specific property or service, DAMA uses your number to respond to that request. The exchange is limited to this purpose.
Any subsequent use of the number to offer new property opportunities to an individual is based on specific, freely given consent expressed through an affirmative action. The relevant box must be optional and unchecked by default. Refusing this marketing does not prevent DAMA from responding to your initial request.
Consent to telephone marketing may be withdrawn at any time. It is valid for a maximum of one year; evidence of the choice is retained for at least three years.
05 Recipients and service providers
Within the scope of their duties, data may be accessible to:
- DAMA’s directors, employees, associates and authorised professionals;
- service providers responsible for publishing, hosting, maintenance, forms, CRM, messaging, storage and communications;
- professionals required for the property transaction — including notaries, property diagnostic specialists, insurers, lawyers or financial institutions — where the engagement requires it;
- public authorities, judicial authorities or authorised bodies where required by law.
DAMA does not sell the personal data of its clients or prospects.
Services that may be used
The website uses Tilda for publishing, forms, CRM and certain statistics. It may also integrate Google Analytics, Google Maps, YouTube, Google Fonts and links to WhatsApp. The messaging provider used to receive and retain emails still needs to be identified in the internal documentation.
When you open WhatsApp, a Google map or a YouTube video, the relevant service processes certain data under its own policy.
06 Transfers outside the European Economic Area
Some service providers may process data, or make it accessible, from countries outside the European Economic Area, including certain Tilda, Google or Meta services.
Where such a transfer takes place, DAMA ensures that it is based on a mechanism recognised under the GDPR: an adequacy decision, Standard Contractual Clauses or another appropriate safeguard. You may request information about the applicable safeguards by writing to fm@dama-agency.com.
07 Cookies and other trackers
The website may use trackers that are strictly necessary for its operation and security, audience-measurement tools and trackers associated with maps, videos or external services.
Non-essential trackers must be placed only after your consent. The cookie manager must make it equally easy to accept or refuse, allow choices by purpose and let you withdraw consent at any time through a permanent “Manage my cookies” link. Continuing to browse does not constitute consent.
08 Information displayed with forms
A short notice must appear close to each form. General acceptance of this policy must not be required in order to submit a request. Any marketing consent must be separate, optional and unchecked by default.
Sample notice:
DAMA processes the information entered to respond to your request and follow it up. Marked fields are required. Your data is intended for authorised DAMA personnel and its technical service providers; it is retained while the request is handled and, for a prospect, for up to three years after the last active contact. You may exercise your rights by writing to fm@dama-agency.com.
Separate telephone consent:
☐ I agree to be contacted by telephone by DAMA to receive other property offers. My consent is valid for one year and may be withdrawn at any time.
09 Security and data breaches
DAMA implements technical and organisational measures proportionate to the risks to protect data against loss, unauthorised access, alteration or disclosure.
In the event of a breach, DAMA assesses its consequences. It notifies the CNIL where the incident is likely to create a risk to individuals’ rights and freedoms, and informs the individuals concerned directly where a high risk justifies doing so.
10 Your rights
Depending on the processing and its legal basis, you have rights of access, rectification, erasure, restriction and objection and, where the conditions are met, a right to data portability. You may withdraw your consent at any time without affecting processing already carried out. You may also issue instructions regarding your personal data after your death.
To exercise your rights, write to fm@dama-agency.com or to the postal address shown above. Proof of identity may be requested only where necessary to verify the requester’s identity.
If you believe your rights have not been respected, you may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.
11 Changes to this policy
This policy may be amended to reflect changes in processing activities, the tools used or the law. The update date appears at the top of the page.
