PERSONAL DATA PROTECTION POLICY
Protection Notice
This document, by its concept and unique technical structure, is protected by intellectual property laws.
Any imitation or reproduction, in whole or in part, of its structure or technical implementation is strictly prohibited and may result in legal action.
1. Introduction
1.1 Purpose of this Policy
This Privacy Policy informs users of the website about the conditions under which Sextant Properties Ltd collects, uses, and protects their personal data (hereinafter referred to as the “Data”).
It applies to all data processing activities carried out by Sextant Properties, regardless of how the data is collected (online, by telephone, by mail, or via partners).
1.2 Applicable Legal Framework
Personal Data is processed in accordance with:
Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation – GDPR)
applicable data protection laws
Personal data refers to any information relating to an identified or identifiable natural person.
1.3 Context and Nature of Data Processing
As part of its real estate activities, including connecting sellers and buyers of property, promoting and marketing real estate, and operating its website, Sextant Properties Ltd may process personal data relating to:
identity information
contact details
real estate project information
commercial relationship management
website navigation (technical data and cookies, subject to your preferences)
1.4 Principles Applied by Sextant Properties
Sextant Properties is committed to complying with the fundamental principles of the GDPR, including:
Lawfulness and transparency
Data is processed on a valid legal basis and for specific purposes.
Data minimisation
Only data strictly necessary for the intended purposes is collected.
Limited retention periods
Data is retained only for as long as necessary for the purposes pursued and legal obligations.
Security and confidentiality
Appropriate technical and organisational measures are implemented to protect personal data.
Respect for user rights
Individuals have rights regarding their personal data and may exercise them under the conditions set out by applicable regulations.
This policy may be updated from time to time to reflect legal, regulatory, or operational changes.
2. Scope of Application
2.1 Data Subjects
This policy applies to any person whose data is processed by Sextant Properties, including:
website users
clients, prospects, sellers and buyers of real estate
agents, consultants, and representatives acting on behalf of Sextant Properties
business partners where relevant
2.2 Data Controller
The data controller responsible for the processing of personal data is:
Sextant Properties Ltd
254 Pentonville Road
London
N1 9JY
United Kingdom
Email: [email protected]
2.3 Data Protection Officer (DPO)
Sextant Properties has appointed a Data Protection Officer responsible for ensuring compliance with data protection regulations and acting as a contact point for any questions regarding personal data.
Contact:
Email: [email protected]
Postal address:
Sextant Properties Ltd
254 Pentonville Road
London
N1 9JY
United Kingdom
2.4 Definitions
Data
Any information relating to an identified or identifiable natural person.
Processing
Any operation performed on personal data (collection, storage, use, transmission, deletion, etc.).
User
Any person browsing the website.
Client
Any person using services provided by Sextant Properties.
Processor
Any entity processing data on behalf of Sextant Properties under documented instructions.
3. What Data Do We Collect?
3.1 Overview
In the course of our activities, Sextant Properties collects and processes different categories of personal data.
Data may be collected:
directly from you (contact forms, requests for information, appointments, phone or email exchanges)
through technical tools necessary for the operation of the website and audience measurement (cookies, subject to your consent)
The data is used to:
respond to your enquiries
assist you with your real estate projects
manage commercial relationships
improve our services
send relevant information about Sextant Properties where applicable
The processing of personal data may rely on the following legal bases:
Consent
Performance of a contract
Legitimate interest
Legal obligations
This policy does not apply to employee data, which is governed by a separate internal policy.
3.2 Categories of Data Collected
| Data Collected | Purpose | Legal Basis |
|---|---|---|
| Identification data (name, email, phone, postal address, title) | Contact requests, account creation, customer relationship management | Pre-contractual measures / Contract performance |
| Identity documents where required | Identity verification and compliance with anti-money laundering obligations | Legal obligation |
| Property project information (budget, search criteria, property details) | Property search assistance and transaction support | Pre-contractual measures / Contract |
| Transaction data | Execution of real estate services | Contract |
| Marketing data | Sending newsletters and commercial communications | Consent / Legitimate interest |
| Navigation data (IP address, cookies, device info) | Website operation, analytics and improvement | Legitimate interest / Consent |
| Security logs | Fraud prevention and system security | Legitimate interest |
| Accounting data | Accounting and tax obligations | Legal obligation |
4. Data Retention
Personal data is retained only for the time necessary to fulfil the purposes described in this policy and to comply with legal obligations.
Typical retention periods include:
| Type of Data | Retention Period |
|---|---|
| Contact data (prospects) | 3 years after last contact |
| Client data | Duration of the relationship + 5 years |
| Transaction data | 5 years after the end of the relationship |
| Marketing data | Until consent is withdrawn |
| Website analytics | 13 months |
| Security logs | 6 to 12 months |
| Accounting data | 10 years |
5. Data Security
Sextant Properties implements appropriate technical and organisational measures to protect personal data, including:
access control and permission management
secure authentication mechanisms
protection of IT environments (servers, systems, applications)
regular backups
monitoring and logging systems
Internal procedures are also implemented to limit risks and ensure compliance with data protection regulations.
6. Data Storage and Transfers
Some data may be hosted by specialised service providers.
Our hosting provider may include:
Amazon Web Services (AWS).
Where data is transferred outside the European Economic Area or the United Kingdom, appropriate safeguards are implemented, including:
Standard Contractual Clauses approved by the European Commission
adequacy decisions
recognised data transfer mechanisms such as the EU-US Data Privacy Framework where applicable.
7. Data Protection Impact Assessments
Sextant Properties carries out Data Protection Impact Assessments (DPIA) when processing activities are likely to result in a high risk to individuals’ rights and freedoms.
These assessments help identify risks and implement appropriate protective measures.
8. Data Breach Management
In the event of a personal data breach, Sextant Properties will notify the relevant supervisory authority within 72 hours where required by law.
Where the breach is likely to result in a high risk to individuals, affected persons will be informed accordingly.
9. Your Rights
Under applicable data protection laws, you have the right to:
access your personal data
request correction of inaccurate data
request deletion of your data
request restriction of processing
object to processing
request data portability
withdraw consent at any time
not be subject to automated decision-making producing legal effects
You may exercise your rights by contacting:
We will respond within one month, unless the request is complex.
10. Marketing Communications
Sextant Properties may send marketing communications or newsletters relating to its services.
You may unsubscribe at any time by:
clicking the unsubscribe link in emails
contacting the Data Protection Officer
11. Supervisory Authority
If you believe your personal data has been processed unlawfully, you may lodge a complaint with a competent data protection authority.
6. PURPOSE AND RETENTION OF PERSONAL DATA
Personal Data is collected for the following purposes:
| Purpose | Data Concerned | Legal Basis | Retention Period |
|---|---|---|---|
| Account creation and management | Name, email, phone number, address, project details | User’s consent | 3 years from last login or upon account deletion request |
| Commercial prospecting | Name, email, phone number, project details | User’s consent | 3 years from last contact |
| Business relations management | Name, email, phone number, project details | User’s consent | 3 years from last contact |
| Site security and improvement | IP address, browsing data | Legitimate interest | 13 months |
| Site statistics and marketing research | IP address, browsing data | User’s consent | 6 months |
| Content personalization, targeted advertising | IP address, browsing data | User’s consent | 6 months |
| Managing personal data rights requests | Email, phone, ID copy | User’s consent | 3 years from last contact |
The Company reserves the right to anonymize data before deletion.