Template to be validated by legal counsel
This document is a working template. Information marked “To be provided” must be filled in, and the entire text must be reviewed and validated by legal counsel before final publication — especially if the publisher is established outside France.
Purpose of this policy
This policy describes how your personal data is collected and processed when you visit the site and use its forms, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”) and French Act No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (the “French Data Protection Act”).
We only collect the data needed to process your request.
Data controller
The data controller is the company that publishes the site:
- Company name
- To be provided
- Registered office
- To be provided
- To be provided
- Data protection officer (if applicable)
- To be provided
Its full contact details are given in the legal notice.
Data collected
When you fill in a request form (project, personalized study or partnership), we collect:
- Identity: full name;
- Contact details: email address and, if you wish, phone number;
- Country and project location;
- Project characteristics: project type (individual, developer or investor), estimated floor area, preferred start date;
- For partnership requests: company, position (optional), project typology and planned number of homes;
- Estimated budget, only if you choose to provide it (optional field);
- Message (optional): any information you choose to share with us;
- Attached configuration, where applicable: a summary of the choices made in the configurator (typology, number of bedrooms, floor area, style, materials, terraces);
- Request information: assigned reference, date and time of receipt, language and page from which the form was sent, consent given.
Optional fields are marked as such in the form; without the required fields, we would be unable to process your request. Please do not include any sensitive data (health, opinions, beliefs, etc.).
While you browse, the site’s hosting provider may record technical connection data (IP address, date and time, pages requested), which is needed for the security and proper operation of the service.
Purposes and legal bases
Your data is used for the following purposes, each based on a legal basis provided for by the GDPR:
| Purpose | Legal basis |
|---|---|
| Responding to your contact, information or partnership requests | Your consent (Article 6(1)(a) of the GDPR), given by ticking the checkbox in the form |
| Carrying out a personalized study of your project | Pre-contractual measures taken at your request (Article 6(1)(b) of the GDPR) |
| Managing the pre-contractual relationship: discussions, proposals, preparation of an offer | Pre-contractual measures taken at your request (Article 6(1)(b) of the GDPR) |
| Ensuring the security and proper operation of the site | The publisher’s legitimate interest (Article 6(1)(f) of the GDPR) |
Your data is not subject to any automated decision-making or profiling.
Recipients
Your data is intended solely for the authorized MODUL’OPEN staff responsible for handling your request.
It may be shared with our technical service providers (website hosting, request intake and management tool, email), who act as processors, on our instructions and in compliance with the GDPR. Providers concerned: To be provided · list of processors.
Where the study of your project requires it, certain information may be shared with partners involved in its design or construction (architects, engineering firms, manufacturing facilities): To be provided · categories of partners. Your data is never sold or transferred for commercial purposes.
Retention periods
- Requests not followed up: To be provided · period from our last exchange, then deletion or anonymization;
- Pre-contractual or contractual relationship: for its entire duration, then archiving for the applicable limitation periods: To be provided · periods;
- Technical connection logs: To be provided · period.
Transfers outside the European Union
Data hosting location: To be provided · country or region.
If a provider is located outside the European Union, the transfer is subject to appropriate safeguards, such as a European Commission adequacy decision or standard contractual clauses. Providers concerned: To be provided · providers and safeguards.
Your rights
Under the GDPR and the French Data Protection Act, you have the following rights:
- Right of access: to obtain confirmation that your data is being processed and to receive a copy of it (Article 15 of the GDPR);
- Right to rectification: to have inaccurate or incomplete data corrected (Article 16);
- Right to erasure: to have your data deleted in the cases provided for by law (Article 17);
- Right to restriction: to request that the use of your data be temporarily suspended (Article 18);
- Right to object: to object, on grounds relating to your particular situation, to processing based on our legitimate interest (Article 21);
- Right to data portability: to receive the data you have provided to us in a structured, commonly used format (Article 20);
- Withdrawal of consent: to withdraw your consent at any time, without affecting the lawfulness of processing carried out before its withdrawal (Article 7(3));
- Post-mortem instructions: to set instructions regarding the retention, erasure and disclosure of your data after your death (Article 85 of the French Data Protection Act).
To exercise these rights, email us at To be provided · personal data email or write to the data controller’s postal address, stating the purpose of your request. If there is reasonable doubt about your identity, you may be asked for proof of identity.
We will respond within one month of receiving your request. This period may be extended by two months, taking into account the complexity or number of requests; you will be informed if this is the case.
Complaint to the CNIL
If, after contacting us, you believe that your rights have not been respected, you may lodge a complaint with the French data protection authority, the Commission nationale de l’informatique et des libertés (CNIL — www.cnil.fr (opens in a new tab)), or with the supervisory authority of the European Union Member State in which you reside.
Security
We implement appropriate technical and organizational measures to protect your data against loss, alteration, disclosure or unauthorized access: encrypted connections (HTTPS), access restricted to authorized staff, To be provided · additional measures.
In the event of a data breach likely to result in a risk to your rights and freedoms, we will make the notifications required by the regulations.
Changes to this policy
This policy may change, in particular to reflect changes to the site or to the regulations. The date of the last update is shown at the top of the page.
See also · Legal notice
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