Privacy policy
Klair & Arno attaches great importance to protecting your personal data and respecting your privacy.
The purpose of this Privacy Policy is to provide you with clear and transparent information about how we collect, use, share and protect your personal data when you use our website. www.klair-arno.com (hereinafter «the Site») or when you contact our services.
This policy is established in accordance with :
- Moroccan law no. 09-08 on the protection of individuals with regard to the processing of personal data
- The General Data Protection Regulation (RGPD EU 2016/679) applicable to residents of the European Union
- Recommendations from Morocco's National Commission for the Supervision of Personal Data Protection (CNDP)
By using our Site or our services, you accept the terms of this Privacy Policy.
1. IDENTITY OF THE CONTROLLER
The party responsible for processing your personal data is :
Klair & Arno
[Legal form to be completed]
Registered office: [Full address to be completed], Marrakech, Morocco
Trade Register: [RC to be completed].
ICE: [ICE to be completed]
Email : contact@klair-arno.com
Telephone: [number to be completed]
Co-directors: Claire Emeriau & Arnaud Duysens
If you have any questions about the protection of your personal data, please contact us at: contact@klair-arno.com
2. PERSONAL DATA COLLECTED
2.1 Data collected directly
We collect the personal data you voluntarily provide to us when you :
a) Use our contact or information request form:
- Civility
- Full name
- Email address
- Phone number
- Country of residence
- Message / subject of your request
- Any other information you choose to give us
b) Subscribe to our newsletter:
- Email address
- First name (optional)
- Communication preferences
c) Create a user account (if applicable):
- Identification details (surname, first name, email)
- Password (encrypted)
- Property search preferences
- Site browsing history
d) Make an appointment for a visit:
- Full contact details
- Availability
- Type of property sought
- Indicative budget
e) Initiate a property transaction:
- Identity documents (passport, national identity card)
- Proof of address
- Banking and financial information
- Documents required for the transaction (in accordance with Moroccan legislation)
2.2 Data collected automatically
When you browse our Site, we automatically collect certain technical data:
a) Navigation data :
- IP address
- Browser type and version
- Operating system
- Pages visited and length of visit
- Referral source (how you arrived on our Site)
- Screen resolution
- Browser language
b) Cookies and similar technologies :
- Session and persistent cookies
- Web beacons (pixels)
- Local storage
- Tracking technologies
For more details, see our Cookies policy.
2.3 Data from third-party sources
We may also receive data about you from :
- Social networks (if you interact with our pages)
- Commercial partners (partner estate agencies)
- Legally accessible public databases
- Analysis and digital marketing services
3. PURPOSES OF PROCESSING AND LEGAL BASIS
We use your personal data only for specific, explicit and legitimate purposes:
| PURPOSE | LEGAL BASIS | DATA CONCERNED |
|---|---|---|
| Responding to your enquiries | Execution of pre-contractual measures | Contact details, content of request |
| Organising property visits | Execution of pre-contractual measures | Contact details, preferences, availability |
| Managing a property transaction (purchase/sale) | Performance of a contract / Legal obligation | Identity, contact details, legal documents, financial data |
| Sending out our newsletter and marketing communications | Consent (with opt-out) | Email, first name, preferences |
| Personalising your experience on the Site | Legitimate interest | Browsing data, preferences |
| Improve our services and our Site | Legitimate interest | Browsing data, feedback |
| Ensuring the security of the Site and preventing fraud | Legitimate interest / Legal obligation | IP address, connection logs |
| Meeting our legal and regulatory obligations | Legal obligation | All types according to obligation |
| Accounting and tax management | Legal obligation | Billing and transaction data |
| Analyse marketing performance | Legitimate interest | Anonymised browsing data |
Consent : Where we process your data on the basis of your consent, you have the right to withdraw that consent at any time, without this affecting the lawfulness of the processing carried out prior to the withdrawal.
4. DATA RECIPIENTS
Your personal data may be transmitted, within the limits of what is strictly necessary, to the following recipients:
4.1 At Klair & Arno
- Authorised staff (estate agents, customer service, management)
- Administrative and accounting services
4.2 Service providers and subcontractors
We use trusted service providers to help us provide our services:
a) Hosting and technical infrastructure :
- Infomaniak Network SA (Switzerland) - Site hosting
- Secure cloud services
b) Marketing and communication tools :
- Emailing services (newsletter)
- Customer Relationship Management (CRM) tools
- Social networking platforms (Meta, LinkedIn, Instagram)
- Web analysis tools (Google Analytics or alternative)
c) Web development services :
- Happy Biz FZE (Dubai) - website maintenance and development
d) Property partners :
- Partner estate agencies in Morocco
- Notaries and lawyers
- Property experts
- Banking institutions (for transactions)
e) Payment services :
- Secure payment processors (if applicable)
All our service providers are carefully selected and contractually bound to respect the confidentiality and security of your data.
4.3 Legal authorities
We may disclose your personal data if required to do so by law or in response to a legitimate request from a public authority (court, police, tax authorities, etc.).
4.4 International transfers
Some of our service providers may be located outside Morocco, particularly in Europe or the United Arab Emirates. In this case, we ensure that :
- The country benefits from an adequacy decision (equivalent protection)
- Appropriate safeguards are put in place (standard contractual clauses, Privacy Shield, etc.)
- You have given your explicit consent to the transfer
5. DATA RETENTION PERIOD
We keep your personal data only for as long as is necessary for the purposes for which they were collected:
| TYPE OF DATA | SHELF LIFE |
|---|---|
| Contact forms | 3 years from last contact |
| Newsletter | Until deregistration + 1 year to prove consent |
| Inactive user accounts | 3 years of inactivity, then deletion |
| Prospect data | 3 years from last contact |
| Contracts and property transactions | 10 years (legal accounting and tax obligation) |
| Identity papers and official documents | Legal retention period (in accordance with Moroccan regulations) |
| Browsing data (cookies) | 13 months maximum |
| Connection logs and security | 12 months |
| Billing data | 10 years (accounting obligation) |
At the end of these periods, your data is securely deleted or irreversibly anonymised.
6. YOUR RIGHTS
In accordance with Law 09-08 and the RGPD, you have the following rights with regard to your personal data:
6.1 Right of access
You are entitled to :
- Confirmation that your data is being processed
- Access to your personal data
- Information on treatments carried out
6.2 Right of rectification
You may request the correction of inaccurate or incomplete data concerning you.
6.3 Right to erasure («right to be forgotten»)
You can request the deletion of your personal data in the following cases:
- The data is no longer necessary for the purposes for which it was collected.
- You withdraw your consent
- You object to the processing
- The data has been processed unlawfully
- There is a legal obligation to remove
Exception: This right does not apply if we need to keep your data in order to comply with a legal obligation (e.g. keeping contracts for 10 years).
6.4 Right to object
You can object at any time:
- Processing your data for commercial prospecting purposes
- Processing based on our legitimate interests (except for compelling legitimate reasons)
6.5 Right to limit processing
You may request the restriction of processing in certain situations:
- You dispute the accuracy of the data
- The processing is unlawful but you do not wish it to be deleted
- We no longer need the data, but you need it for legal action
- You objected to the treatment (during verification)
6.6 Right to portability
You have the right to receive your data in a structured, commonly used and machine-readable format and to pass it on to another data controller.
6.7 Right to withdraw your consent
Where processing is based on your consent, you may withdraw it at any time. This does not affect the lawfulness of the processing carried out prior to the withdrawal.
6.8 Right to define post-mortem directives
You have the right to specify what happens to your personal data after your death.
6.9 How can you exercise your rights?
To exercise any of these rights, you can :
By email : privacy@klairarno.com or contact@klairarno.com
By post: Klair & Arno, Data Protection Department, [Full address], Marrakech, Morocco
Your application must be accompanied by :
- A copy of your ID (for verification)
- Specifying the right you wish to exercise
- Any information enabling you to be identified in our databases
Response time : We undertake to respond within a maximum of 30 days from receipt of your request.
7. RIGHT TO CLAIM
If you consider that the processing of your personal data constitutes a breach of the applicable regulations, you have the right to lodge a complaint with the competent supervisory authority:
In Morocco :
Commission Nationale de Contrôle de la Protection des Données à Caractère Personnel (CNDP) (French National Commission for the Protection of Personal Data)
Address: Avenue Al Arz, Hay Riad, Rabat 10100, Morocco
Telephone: +212 537 57 11 26
Email : cndp@cndp.ma
Website : www.cndp.ma
For residents of the European Union :
You can contact the data protection authority in your country of residence.
8. DATA SECURITY
The security of your personal data is an absolute priority for Klair & Arno. We implement appropriate technical and organisational measures to protect your data against :
- Accidental or unlawful destruction
- The loss
- Alteration
- Unauthorised disclosure or access
- Any other form of unlawful processing
8.1 Technical safety measures
- Encryption : Use of HTTPS protocol (SSL/TLS) to secure data transmissions
- Secure hosting : Our data is hosted by Infomaniak (Switzerland), renowned for its high security standards.
- Firewall and antivirus : Protection against intrusions and malware
- Regular backups : Automatic, secure back-up copies
- Access control : Strong authentication and profile-based access management
- Pseudonymisation/Anonymisation : Where possible, to limit risks
8.2 Organisational measures
- Staff training : Regular data protection awareness training
- Limited access: Only authorised persons have access to personal data
- Contracts with subcontractors : Strict confidentiality and security clauses
- Internal procedures : Security policy and incident management
- Regular audits: Audit of our practices and systems
8.3 In the event of a data breach
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we undertake to :
- Notify the competent supervisory authority within 72 hours
- Inform you directly if the risk is high
- Take all necessary measures to limit the consequences
9. COOKIES AND SIMILAR TECHNOLOGIES
9.1 What is a cookie?
A cookie is a small text file placed on your terminal (computer, smartphone, tablet) when you visit a website. It enables your browser to be recognised and certain information to be collected.
9.2 Types of cookies used
a) Strictly necessary cookies (mandatory)
These cookies are essential to the operation of the Site and cannot be deactivated:
- Session cookies (authentication)
- Security cookies
- Language preference cookies
b) Performance and analysis cookies (optional)
They enable us to measure the audience and improve the Site:
- Google Analytics or alternative (anonymised data)
- Audience measurement tools
c) Functional cookies (optional)
They improve your user experience:
- Memorising your preferences
- Saving your property search
- Online chat
d) Advertising and targeting cookies (optional)
With your consent, to personalise advertising:
- Facebook Pixel / Meta Pixel
- Google Ads
- LinkedIn Insight Tag
- Retargeting
9.3 Cookie management
On your first visit, a banner will inform you of the use of cookies and allow you to :
- Accept all cookies
- Refuse non-essential cookies
- Customise your preferences
You can change your preferences at any time via :
- The link at the bottom of the Site page
- Your browser settings
Browser configuration :
You can configure your browser to refuse cookies:
- Chrome : Settings > Privacy and security > Cookies
- Firefox : Options > Privacy and security > Cookies
- Safari : Preferences > Privacy > Cookies
- Edge: Settings > Privacy > Cookies
Please note: Rejecting certain cookies may restrict your access to certain Site functions.
9.4 Cookie retention period
- Session cookies: Deleted when the browser is closed
- Persistent cookies : Maximum 13 months
For more details, see our Complete Cookie Policy.
13. CHANGES TO THE PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time in order to :
- Reflecting changes in our practices
- Comply with legislative or regulatory changes
- Improving our services
In the event of a substantial change : We will inform you by email (if we have your contact details) or via a notice visible on the Site.
The date of the last update is shown at the top of this page.
We encourage you to consult this policy regularly to stay informed.
14. CONTACT AND QUESTIONS
If you have any questions about this Privacy Policy or the processing of your personal data, please contact us:
Klair & Arno
Data Protection Department
Email : contact@klair-arno.com
Telephone : [number to be completed]
Mail : [Full address], Marrakech, Morocco
We promise to reply as quickly as possible and to treat your request with the utmost care.