PRIVACY AND DATA PROTECTION POLICY MZRE

We collect only the information strictly necessary to provide our services.

This privacy policy has been in effect since September 1, 2025. It forms an integral part of the contractual relationship that we have entered into together in connection with your requests

Scope
This privacy policy applies to the company Michael Zingraf Real Estate

Respect for your personal data

As we are aware that the use and sharing of your personal data are at the heart of your concerns, we are committed to respecting your privacy, protecting your personal data, and using it transparently.
By browsing our website, completing the various contact forms or by any other means of communication, you expressly agree that Michael Zingraf Real Estate may process, store and use the personal information referred to below and in accordance with this policy.

Controller of personal data
The company Michael Zingraf Real Estate, a simplified joint-stock company (SAS) with share capital of 253,200 euros, with registered office at the following address: (06400) CANNES, 53-54 bd de la croisette, and registered with the Cannes Trade and Companies Register under number 328 695 432, represented by its Managing Director Jean-Claude ANNAERT.

Categories of personal data collected and processed
Any personal data identifying you directly: in particular surname, first name, postal, email or telephone contact details, or indirectly; computer traces left by your browsing on the Site, IP address (computer virtual address), are considered personal data and are processed as such. Thus, we collect and process all information you provide to us via our site or by any other means, including when registering or making contact.

You may choose not to provide us with certain personal data. In that case, you may be deprived of services that we would not be able to provide without the data you choose not to share with us. As far as possible, we strive to ensure that you remain fully able to use our services, even if you have not agreed to provide us with your personal data.

The collection of your personal data on our websites is possible in several sections or when you use our services.

In this context and in order to fulfill your requests, we may collect the following data:

• Title, first and last name,
• Date and place of birth,
• Postal address,
• Email address,
• Telephone number,
• Marital property regime or non-patrimonial status,
• Gender,
• IP address of the device or SDK number (Software Development Kit) of the application used

Information relating to browsing and interactions with the Services, the Website (search history, forms, cookies, etc.),

In addition to the above elements and, where applicable, if the individual is also a professional and is likely to enter into or has entered into a contractual relationship with us:

• His/her intra-community VAT number
• Bank details (bank account details)
• His/her RSAC number
• Family relationship details concerning the individual
• Photo

Use of our company website and the transmission of your personal data requires that you be at least 16 years old. Please note that it is impossible for us to determine the user’s age; in any event, if we identify that any personal data collected belongs to a minor under 16, we undertake to delete it.

The purposes of processing:

The collection and processing of your personal data enable us to provide you with an optimal, professional and personalized service. Consequently, you agree that we may use your personal data for the purposes set out below:

• Respond to, follow up on your requests and better understand your needs,
• Provide you with all our available services or those of partner companies,
• Keep you informed about the Company’s news and any benefits you may receive via the newsletter or receive commercial information by electronic communication,
• Improve our services, as well as the use of our websites and services,
• Managing your feedback on services or content,
• Creating and managing customer and prospect files,
• Establish statistics on traffic to its Site or more generally any commercial statistics and any studies relating to the real estate market,
• Carry out prospecting-related operations such as managing technical prospecting operations, carrying out loyalty, prospecting, survey or outreach actions, or conducting satisfaction surveys or studies,
• Carry out any commercial actions towards you
• Transmission, transfer, rental or exchange of customer files or prospect files with group partners
• Implement any communication, advertising or targeted actions,
• Personalize your experience and needs using any browsing-tracking technology, including through automated decision-making,
• Locate you in order to better ensure the requested services and the handling of your request,
• Comply with our legal and regulatory obligations,
• Management of the recruitment process (responses to applications, conducting interviews, etc.).

Recipients of personal data
You are informed that the collected data may be communicated to the following persons, in particular if they are involved in the process according to the purposes set out above:

• To employees or non-employees of group companies who are required to process the data or may intervene in the process, depending on your request;
• To the companies, real estate agencies of the Group and particularly to the commercial agents who make them up;
• To IT service providers, particularly in connection with the provision of a specific service, or for the management of behavior-tracking technologies,
• To the Group’s Commercial Partners (real estate brokers, insurance brokers, banks, wealth management advisors) or to any real estate professional (real estate agency, property dealer, administrator) whose services may add value to your project or who may offer you specific benefits.
• To authorized administrative or judicial authorities, upon request and exclusively to meet legal obligations.

Cookies
The group’s website is: www.michaelzingraf.com

When you visit this site, cookies may be stored on your device (computer, tablet, etc.). A cookie is a small text file placed on your device when you visit a website or view an advertisement. A cookie cannot damage the device you use. The purpose of a cookie is to store information relating to browsing on the Site (pages viewed, date and time of the visit, etc.). This information may be read on subsequent visits by the issuer of the cookie. Under no circumstances do these cookies contain personal data. Cookies are in no way intended to fraudulently collect personal data.

We use different types of cookies because they serve different purposes. You can disable the saving of cookies at any time by configuring your internet browser.

Michael Zingraf Real Estate reminds you that disabling cookies may impair your browsing experience on the Site and recommends that you configure your browser taking their purpose into account.

If you wish to configure your cookies, you can do so as indicated below depending on the browser you use.

FIREFOX
From the “Tools” menu, then “Options,” click the “Privacy” icon, then the “Cookies” menu and select the options you want.

INTERNET EXPLORER 6 AND ABOVE
From the “Tools” menu, then “Internet Options,” click the “Privacy” tab, and select the level by moving the slider.

SAFARI
From the Safari menu, go to “Preferences” and “Security” and select the options you want.

GOOGLE CHROME
Click the Chrome menu icon in the upper-right corner of the browser window, then select “Settings.” At the bottom of the page, click Show advanced settings. In the Privacy section, check/uncheck the privacy settings as you wish.

Regarding third-party cookie management: YOUR ONLINE CHOICES
The website www.youronlinechoices.com, set up by the European Digital Advertising Alliance (EDAA), which brings together advertising professionals, allows you to accept or refuse the cookies used by companies registered on this site when you visit their services.

MEASUREMENT AND AUDIENCE COOKIES
To change your settings for audience measurement and statistics cookies, you can visit the following address:
Google Analytics: https://tools.google.com/dlpage/gaopout?hl=fr
You can also disable cookies by installing the DoNotTrack extension available on Google Chrome:
- https://chrome.google.com/webstore/detail/do-not-track/

This list is not exhaustive and may change.

Links to websites not managed by Michael Zingraf Real Estate
The Michael Zingraf Real Estate website may offer links to other websites, even if they are not managed by Michael Zingraf Real Estate or its subcontractors. Under no circumstances can Michael Zingraf Real Estate be held responsible for the content of these sites, which it does not publish or manage. The redirection to a third-party site does not constitute a recommendation, and Michael Zingraf Real Estate is in no way responsible for the editorial content provided on the relevant sites.

Retention period
Your data will be retained for as long as necessary to fulfill the above-mentioned purposes, in particular for the following periods:

• Contract performance and follow-up: 1 year after the end of the business relationship
• Recruitment: 2 years after the last contact

At the end of these periods, the data will, if necessary, be archived for a period not exceeding the applicable legal limitation periods or archiving obligations, and in particular for a period of 5 years from the last contact you had with the group. Once these periods have expired, the data will be destroyed.

Storage and transfer
We guarantee the confidentiality and integrity of your personal information through the use of secure communication protocols.
If you access the website from a country outside the European Union whose legislation regarding the collection, use and transfer of data differs from European legislation, you agree to transfer your personal data to the European Union in the context of your browsing on the websites.
If Michael Zingraf Real Estate becomes aware that a third party is using or disclosing your personal data without complying with this General Privacy Policy or in violation of applicable law, Michael Zingraf Real Estate will take all reasonable steps to prevent or stop such use or disclosure.
Michael Zingraf Real Estate may also be required to transfer your personal data to third parties outside the European Union if Michael Zingraf Real Estate considers such transfer necessary for technical reasons (for example, website hosting), in the context of Michael Zingraf Real Estate’s legitimate interest or to meet legal obligations. These transfers may be carried out securely, via the Internet, by mail, by fax or by any other method that Michael Zingraf Real Estate deems appropriate and in compliance with applicable law.
Access to these documents is possible by submitting a request, in accordance with the procedure described below (“Exercising your rights”).

Location of storage of your personal data
TAS France - 15 Traverse des Brucs, 06560 Valbonne, France

Your rights
In accordance with the provisions of the French Data Protection Act of 6 January 1978 as amended by Decree No. 2019-536 and European Regulation No. 2016/679 of 27 April 2016, you have the right to:

• Access and obtain a copy of your data,
• Rectification,
• Erasure,
• Restriction of processing,
• Data portability of your personal data,
• Notification of updates to each recipient to whom the data have been disclosed in the event of rectification or erasure of such data,
• Portability of only the personal data you have provided to us,
• Withdraw your consent at any time,
• Give instructions regarding your personal data after your death,
• Lodge a complaint with the CNIL – Complaints Department – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

Rights to object
In addition to the above, the following rights of objection to which you are entitled are explicitly brought to your attention:

• To object at any time, on grounds relating to your particular situation, to the processing of your personal data relating to processing carried out for the purposes of the legitimate interests pursued by the Company, including profiling
• To object at any time to the processing of your personal data for direct marketing purposes, including profiling to the extent that it is related to such marketing
• To object to the communication of your personal data to a third party.

You are informed that in the event of an objection, we will cease processing the data concerning you for the matters set out in this paragraph.
However, if we were to demonstrate that there are one or more legitimate and compelling grounds for the processing, or for the establishment, exercise or defense of legal claims, we would continue such processing and would inform you that we cannot, in whole or in part, comply with the exercise of your right.

Exercising your rights
You may exercise your rights by contacting dpo@michaelzingraf.com or by mail at:

• Michael Zingraf Real Estate,
• 53-54 bd de la Croisette,
• (06400) CANNES,
• Specifying in the subject line of the letter “Data Subject Rights” and enclosing a copy of your identity document.

In accordance with Article 12.3 of the General Data Protection Regulation, you will receive a response within one month of receipt of your request. In certain cases, notably due to the complexity of your request, this period may be extended by two months.
If the issue remains unresolved, you may refer the matter to the CNIL.

 

Legal basis for processing
Pursuant to Article 6.1 of the General Data Protection Regulation, you are informed that the various processing operations of your data mentioned below are:

• Based on your consent, which you may withdraw at any time without affecting the initial lawfulness of the use of your data, for the distribution of communications, all regulated information and, more generally, the Company’s various communications;
• For the purposes of performing your contract or a contract entered into with the company you represent (performance of services, invoicing, contract monitoring, after-sales service and claims, etc.);
• To process and respond to requests for pre-contractual measures taken at your request (management of applications, requests for information, etc.);
• To comply with our legal, accounting and tax obligations (including the retention of supporting accounting records);
• Unless you object and within the limits of your interests and rights, to meet our legitimate needs

Protection of your data
Michael Zingraf Real Estate, as the Controller of your personal data, undertakes to implement all necessary measures to ensure the security and confidentiality of the personal data transmitted or collected.

Information concerning data collected and processed by the company not obtained directly from the data subject
Your personal data may have been communicated to us without our having collected it ourselves, but through other sources (for example, without this list being exhaustive: partners, service providers, customers, etc.).
In accordance with the regulations, we will inform you:

• As soon as possible on the day of the first contact and no later than one month thereafter, of this privacy policy containing all the information the Company is required to provide to you,

Of the source that provided your contact details to the Company.

Changes to the privacy policy
This policy may be amended at any time, in particular in light of legislative, regulatory, or case-law developments. As such, we invite you to consult it regularly, but we reserve the right to inform you of any changes by any means.