Privacy Policy
Table of Contents
Preamble.
BD LP attaches the utmost importance to the protection of privacy and personal data collected from Users of its Website, as these terms are defined hereinafter.
The purpose of this privacy policy is to inform users (hereinafter “Users” or “You”) of the website (hereinafter the “Website”) published and operated by the company BD LP MONACO – a limited liability company under Monegasque law registered under identification number 25S10178 and whose registered office is located at 4/6, Rue des Lilas in Monaco (98000) – (hereinafter “BD LP”), of the commitments and measures taken to comply with the regulations inherent to the protection of their personal data (hereinafter the “Privacy Policy”).
Through this Privacy Policy, BD LP undertakes, as data controller, to make commitments and implement adequate measures to ensure the protection, confidentiality, and security of Users’ personal data, and that all processing and collection operations of said data are carried out in compliance with applicable provisions, particularly Law No. 1.565 of December 3, 2024, relating to the protection of personal data published in the Journal de Monaco on December 13, 2024 (the “Law”), as well as those of European Regulation 2016/679 of April 27, 2016 (together with the Law, the “Regulation”).
This Privacy Policy may be modified or supplemented at any time by BD LP in the context of the Website’s operation, particularly to comply with any legislative, regulatory, jurisprudential, or technological developments.
Article 1 – Identity of the Data Controller and DPO
For the processing and collection of data occurring on the Website, the designated data controller is BD LP. The Data Protection Officer (“DPO”) is Laetitia Patetta Arena, whose contact details are reproduced below:
Email: lpa@bdlp.mc
Tel. : +377 92 00 88 65
The DPO can be contacted for any questions regarding the processing of personal data and the exercise of rights recognized for Users concerned by this policy.
Article 2 – Personal Data Collected, Purpose, and Legal Basis for Processing
BD LP scrupulously ensures that the personal data of its Users is collected and processed under the strict conditions that it is relevant, adequate, not excessive, and strictly necessary for achieving the purposes that have been previously determined.
Generally, Users may visit the Website without providing any personal information about themselves, on the understanding that they accept and acknowledge that they will not be able to use certain functionalities for which the transmission of such information is essential. In any event, Users are in no way obliged to transmit this information to BD LP via the Website. Thus, in case of refusal, Users may not be able to benefit from certain information or services they may have requested.
The personal data processing operations implemented by BD LP are based on the following legal grounds, determined according to the purpose pursued:
For the management of the contractual relationship and the execution of requested services, the legal basis retained is the performance of the contract or pre-contractual measures taken at the User’s request;
Purpose: Management of contact requests, response to User inquiries, processing of information requests related to services offered by BD LP.
Legal basis: Pre-contractual measures taken at the User’s request in application of paragraph 3 of Article 5 of the Law.
Categories of data processed: surname, first name, email address, telephone number, content of the message or request submitted.
Mandatory nature: The communication of this data is mandatory to allow BD LP to process the request submitted. Failure to communicate this data will make it impossible to process said request.
For commercial prospecting activities concerning services similar to those already provided, BD LP relies on its legitimate interest in developing its clientele. The User’s free and informed consent constitutes the legal basis for sending commercial communications relating to services different from those previously provided, as well as for the processing of sensitive data, where applicable;
Purpose: Sending commercial communications, newsletters, information on BD LP’s services and news, loyalty actions.
Legal basis: For services similar to those already provided: legitimate interest of BD LP in developing its clientele, in accordance with paragraph 6 of Article 5 of the Law. For services different from those previously provided: free, specific, informed, and unambiguous consent of the User, collected in accordance with the provisions of Article 6 of the Law.
Categories of data processed: surname, first name, email address, history of interactions with BD LP, expressed preferences.
Mandatory nature: The communication of this data is optional. The User may refuse to communicate this data or withdraw their consent at any time without affecting access to other services on the Website.
Finally, certain legal obligations to which BD LP is subject justify certain processing operations, particularly in accounting and tax matters.
Purpose: Compliance with legal and regulatory obligations to which BD LP is subject, particularly in accounting, tax, and anti-money laundering and counter-terrorism financing matters.
Legal basis: Legal obligation to which the data controller is subject, in accordance with paragraph 2 of Article 5 of the Law.
Categories of data processed: All data necessary for compliance with applicable legal obligations, including identification data and data relating to transactions carried out (if relevant).
Mandatory nature: The communication of this data is mandatory under applicable legal and regulatory provisions. Failure to communicate this data will make it impossible to establish a contractual relationship with BD LP.
The User expressly acknowledges that acceptance of the Privacy Policy also implies their consent to the processing of their personal data as described herein, including:
- Their surname, first names, and date of birth;
- Their contact details (email address and telephone number);
- Their technical browsing information;
- Their identity data, telephone number, address, CV, cover letters.
The User’s personal data collected directly (for example, when submitting a question via the contact page or a newsletter subscription request) serve explicit, legitimate, and determined purposes. They are used by BD LP:
- Either for the purpose of managing its clients and activities;
- Or for contact, communication, statistical, commercial, and/or promotional purposes;
- Or to enrich the editorial content of its offer, the Website, and, where applicable, to make adaptations to meet the needs of Users;
- Or to respond to inquiries and requests for information, and send BD LP newsletters.
The communication of personal data in this context is voluntary. If the User does not provide this personal data, they will not be able to benefit from the corresponding services via the Website.
BD LP does not necessarily collect sensitive personal data through the operation of the Website. By voluntarily providing sensitive personal data to the Website (for example, by submitting an online application), the User expressly consents to their personal data being used as described in this Privacy Policy.
BD LP does not, in principle, collect sensitive data within the meaning of Article 2, paragraph 9 of the Law, i.e., data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation.
In the event that the User spontaneously communicates such data (particularly in the context of an application or a free message), they expressly consent to its processing within the strict limits necessary for the purpose pursued, in accordance with the provisions of Article 7 of the Law.
Article 3 – Data Retention Period
Your personal information is retained by BD LP for the strictly necessary period corresponding to the purposes for which it was collected, in accordance with the provisions of Article 4, paragraph 5 of Law No. 1.565 of December 3, 2024. The applicable retention periods are as follows:
Data relating to the management of contractual and pre-contractual relationships. This data is retained for the entire duration of the relationship established between BD LP and the User, extended by the duration of the applicable legal limitation periods, i.e., FIVE (5) years from the end of the relationship in accordance with the provisions of the Monegasque Civil Code relating to the limitation of personal movable actions.
Data relating to commercial prospecting. For Users who have agreed to receive commercial communications, data is retained for the duration of the contractual relationship, extended by three years from the last contact originating from the User (last connection to the Website, last purchase, last click on a link contained in an email, etc.). Beyond this period, BD LP undertakes to permanently delete said data or to continue its retention after obtaining the User’s renewed consent.
Connection and browsing data. Technical connection data is retained for a maximum period of THIRTEEN (13) months from its collection, in accordance with the recommendations of the Personal Data Protection Authority.
Archiving for evidentiary purposes. Certain data may be archived beyond the periods mentioned above for the purposes of establishing, exercising, or defending legal rights, in accordance with the provisions of Article 5, paragraph 5 of the Law. This archived data is subject to enhanced security measures, and access to it is strictly limited to authorized persons. It is retained for the duration of the applicable limitation periods.
Upon expiration of the retention periods mentioned above and in the absence of legal justification for their retention, BD LP proceeds with the definitive erasure of personal data or its anonymization.
Article 4 – Users’ Rights
In accordance with the Regulation, You have a number of rights concerning your personal information, including:
- Right of access
- Right to rectification
- Right to erasure
- Right to data portability
- Right to restriction of processing
- Right to object to processing on legitimate grounds
- Specific right to object to commercial prospecting
- Right to withdraw your consent at any time
You can exercise them by contacting the data controller or the DPO designated by BD LP:
By postal mail: BD LP – 4/6, Rue des Lilas in Monaco (98000)
By email (data controller): contact@bdlp.mc
By email (DPO): lpa@bdlp.mc
In case of refusal or absence of response from BD LP within THIRTY (30) days following receipt of the request, the User is also informed that they have the right to lodge a complaint with the Personal Data Protection Authority (APDP) either:
- Via the following URL: https://apdp.mc/particuliers/;
- Via postal mail (Le Concorde – 11 rue du Gabian in MONACO (98000)).
Article 5 – Data Transfers
Principle. – Personal data collected and processed by BD LP is, in principle, hosted and processed within the European Union or in countries with legislation ensuring an adequate level of protection within the meaning of Article 97 of Law No. 1.565 of December 3, 2024.
Countries benefiting from an adequate level of protection. – In accordance with the provisions of Article 97 of Law No. 1.565 of December 3, 2024, the Member States of the European Union are deemed to have legislation presenting an adequate level of protection. Consequently, data transfers to these States can be carried out without particular formalities.
Transfers outside the European Union. – In the event that certain personal data is transferred to a country, territory, or international organization located outside the European Union and not benefiting from recognition of an adequate level of protection within the meaning of the aforementioned Article 97, BD LP ensures the existence of appropriate safeguards in accordance with the provisions of Article 98 of Law No. 1.565 of December 3, 2024.
User Information and Rights. – You are informed of any transfer of your personal data to a third country not benefiting from an adequate level of protection, as well as of the appropriate safeguards implemented to frame said transfer. A copy of these safeguards can be obtained upon simple request addressed to the data protection officer whose contact details are provided in Article 1 of this policy.
Article 6 – Security (Website and Data)
The Website is provided “as is” and “as available” without any warranty whatsoever. Access to and use of the Website are at the User’s own risk.
It is the User’s responsibility to take all appropriate measures to protect their own data and/or software stored on their telephone and/or computer equipment against any damage, malfunction, virus, hacking, etc. (this list being non-exhaustive).
The User declares to know and accept the limitations and issues of the Internet network for which BD LP, as the operator of the Website, cannot be held liable.
BD LP undertakes to implement all measures to protect the personal data of its Users against any loss, destruction, alteration, unauthorized access, or disclosure, considering the nature of the data and the risks involved in its processing, to preserve the security and confidentiality of your personal data.
Article 7 – Cookies and Trackers
The Website uses cookies and other trackers subject to the provisions of Article 87 of the Law. A cookie is a text file that may be stored in a dedicated space on the hard drive of your device (computer, tablet, mobile phone, etc.) when you consult the Website.
BD LP distinguishes two categories of trackers subject to distinct legal regimes:
- Strictly necessary cookies (essential for the Website’s operation) do not require your prior consent.
- Other trackers (audience measurement, performance, advertising targeting, social media sharing) require your prior consent.
Upon your first visit to the Website, an information banner allows you to accept, refuse, or configure the use of non-strictly necessary trackers. You can modify your choices at any time via the cookie management interface accessible in the footer. Your choice is retained for a maximum period of THIRTEEN (13) months, after which your consent will be requested again.
Detailed list of trackers. – An exhaustive and regularly updated list of trackers used on the Website is available at the following URL link:
Article 8 – Contact
For any information request regarding the personal data protection policy, the User may send a letter to the data controller or to the DPO of BD LP at one of the following addresses:
By postal mail: BD LP – 4/6, Rue des Lilas in Monaco (98000);
By email: contact@bdlp.mc;
By email (DPO): lpa@bdlp.mc.