Personal Data Protection Policy

Last updated:

April 16, 2026

This Personal Data Protection Policy (the “Policy”) describes how the company HAVEN-A PLACE ABOVE, a French simplified joint-stock company (SAS) with a share capital of €12,500, whose registered office is located at 169 Boulevard Haussmann, 75008 Paris, registered with the Paris Trade and Companies Register under number 953 921 467, and/or its affiliated companies, in particular HAVEN INTERNATIONAL (hereinafter “Haven”, “We”, “Our” or “Us”), process, as data controller, the personal data of their clients, prospects and visitors (“You”, “Your”) in order to provide You with the best possible experience.

Haven collects, stores, processes, uses and discloses Personal Data about You when You use Our website, when You contact us via the Site forms, when You visit Our social media pages, or when You communicate with Our teams in connection with a real estate project.

1. What categories of data do we collect?

Haven collects the following categories of data, for the purposes described below in Our Policy:

  • Your identity and contact details (surname, first name, address, telephone number, email address), when You choose to provide them, for example to fill in a contact form, request information about a residence, or subscribe to Our newsletter;
  • Browsing information: IP address, browser type, pages viewed, visit duration, data collected by cookies (see Our Cookie Policy);
  • Information that You publicly share on our social media channels or via contact forms;
  • Information collected from third parties: data transmitted by partners in connection with a referral to Haven, subject to the consent of the individuals concerned.

2. For what purposes do we use your data?

Your data is used for the purposes described below:

  • Responding to your requests: Process your information requests, answer your questions, and contact you regarding a property project. Legal basis: Performance of pre-contractual measures;
  • Improving our services: Analyse the use of the Site to enhance its content, usability, and personalise your experience. Legal basis: Legitimate interest;
  • Marketing communications: Contact you, with your consent where required, about new residences, projects, events, or editorial content that may interest you. Legal basis: Consent;
  • Security: Protect our company, our Site, and our users from fraud and unlawful activities. Legal basis: Legitimate interest;
  • Analysis and statistics: Measure the Site’s audience, the effectiveness of our communications, and improve our online presence. Legal basis: Legitimate interest;
  • Legal obligations: Retain a record of exchanges and documents for legal, administrative, or tax purposes. Legal basis: Legal obligation.

3. With whom do we share your data?

We only disclose or share Your data in the following cases:

  • With entities within the Haven Group: Access is limited to authorised personnel whose role justifies it, for internal management and project coordination purposes;
  • With our service providers: Including the Site’s hosting provider, technical service providers, analytics tools, and communication agencies, to the extent necessary for them to perform their duties on behalf of Haven;
  • With our property partners: Including agencies, brokers, and notaries, as part of facilitating a purchase project, and only with your prior consent;
  • With competent authorities: When we are legally required to do so, to comply with a court order or a request from an authorised authority.

4. Cookies and trackers

We use cookies and trackers on the Site. To learn about the types of cookies used, their purposes, and how to manage Your consent, please refer to Our Cookie Policy, available on the Site.

5. Transfer of your data

Data concerning You may be transferred and processed in a country where a Haven entity or one of Our service providers is located (in particular Switzerland for Haven International).

These recipients may be established in a country benefiting from an adequacy decision by the European Commission. Where this is not the case, We ensure an adequate level of protection by entering into transfer agreements based on the European Commission’s standard contractual clauses, or any other valid transfer mechanism.

6. Data retention period

Your data is retained for the period reasonably necessary for the purposes described, or for the retention period permitted by law:

  • Prospects who have not proceeded further: Three (3) years from the date of the last contact;
  • Clients: For the duration of the commercial relationship, followed by archiving for the applicable legal limitation period (five years for civil matters, ten years for accounting matters);
  • Navigation data: A maximum of thirteen (13) months, in accordance with the recommendations of the CNIL.

Your data is then destroyed or anonymised.

7. Your rights

In accordance with the General Data Protection Regulation (GDPR) and the French Data Protection Act, You have the following rights regarding Your Personal Data:

  • Right of access: Obtain confirmation that your personal data is being processed and receive a copy of that data;
  • Right to rectification: Request the correction of inaccurate, incomplete, or outdated data;
  • Right to erasure: Request the deletion of your data in accordance with legal requirements;
  • Right to restriction of processing: Request the temporary suspension of the processing of your data;
  • Right to data portability: Receive your data in a structured, machine-readable format;
  • Right to object: Object to processing based on legitimate interest or to direct marketing;
  • Right to withdraw consent: Withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
  • Post-mortem directives: Set instructions regarding the handling of your data after your death.

You also have the right to lodge a complaint with the French Data Protection Authority (CNIL): www.cnil.fr.

8. Protection of your data

We implement appropriate technical and organisational security measures to protect Your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

However, no method of electronic transmission or storage is completely secure. We encourage You to exercise caution when using the Internet to access Our Site.

9. Minors

The Site is not intended for minors. We do not knowingly collect personal data from individuals under eighteen (18) years of age. If We learn that a minor has provided Us with personal information, We will delete it as soon as practicable.

10. Third-party sites

The Site may contain links to third-party sites or services subject to their own privacy policies. This Policy does not apply to such third-party sites. We invite You to consult their respective privacy policies.

11. Policy amendments

This Policy may be amended to reflect changes in Our practices or applicable regulations. We will publish any updates on the Site and inform You of any significant changes.

12. Contact us

Data Protection Officer (DPO): ADDB, Aleksander Dembinski

  • By post: HAVEN-A PLACE ABOVE, 169 Boulevard Haussmann, 75008 Paris
  • By email: ad@addb.fr