Protection of personal data

The CMP collects and processes the personal data that you have communicated, either directly when you visit us or via online or paper forms, such as your identification data, your contact details, your professional situation, your economic or banking information, as well as those generated by the execution of the loan or savings contracts you have taken out or as part of your budgeting process, or when browsing our sites or applications.

The personal data collected on customers in the context of pawnbroking is used for :

• Management of pawnbroking contracts,
• Online personal account management for pawnbroking customers,
• Online appointment management,
• Management of information operations on Parcours Budget services for vulnerable customers.

Here are the details of the purposes, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Pawnbroking contract management
Management of object commitments, conservation, loan repayments, renewals, disbursements and sale bonuses;	Execution of the pawnbroking contract	Internal CMP, subcontractors and authorized third parties (judicial requisition)	10 years after the closing of the last pawnbroking contract in accordance with article L.131-2 of the Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)
Compile anonymous statistics and manage the pawnbroking department's activities.	Legitimate interest	Internal CMP	Anonymous statistics
Online personal account management for pawnbroking customers
Teleservice for managing pawn loan renewals and repayments (including online payment management).	Executing a pawnbroking contract	Internal CMP, subcontractors and authorized third parties (judicial requisition)	10 years after the closing of the last pawnbroking contract in accordance with article L.131-2 of the Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)
Management of online appointments for pawnbroking
Online pawnbroking appointment booking teleservice	Executing a pawnbroking contract	Internal CMP and subcontractor	12 months after appointment
Information operations on Parcours Budget services
Management of telephone call-backs to pawnbroking customers in financial difficulty for information on Budget Path services (non-commercial prospecting).	Consent	Internal CMP	6 months maximum after contact

The provision of personal data is mandatory for the contractualization of the loan.

In the case of pawnbroking, customer data is also processed for the following purposes, detailed in the sections below:

• Improve the quality of our customer service, notably through satisfaction surveys (in-room forms, letters, e-mails, etc.);
• Manage commercial email prospecting campaigns;
• Combating money laundering and the financing of terrorism;
• Meet regulatory requirements for internal control in financial institutions (internal audit, risk management and periodic control);
• Manage claims and litigation.

The personal data collected concerning persons registered for online sales, online bidders and buyers in the context of online or indoor auctions are used under the responsibility of Crédit Municipal de Paris in conjunction with the auctioneers managing the CMP public auctions and the company Commissaire-Priseur Multimédia (CPM), supplier of the Interenchères platform, for the following purposes:

• Auction management ;
• Implementing prospecting and loyalty-building operations (sending out sales catalogs);
• Preventing unpaid bills and fighting crazy bids through the TEMIS* shared file.

Here are the details of the purposes, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Auction management (internet or live)
Management of registrations for sales and auction operations (including purchase orders and requests for information), issuing of sales reports and buyers' slips;Management of collections, monitoring of payments and collection;	Execution of the sales contract and/or execution of the Interenchères membership contract (GCU)	Internal CMP, auctioneers in charge of managing CMP auctions, InterAuction platform provider (CPM) and authorized third parties (judicial requisition)	10 years after the sale, in accordance with article L.131-2 of the French Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)
Compile anonymous statistics and manage the activities of the Sales Expertise Conservation Department (VEC)	Legitimate interest	Internal CMP	Anonymous statistics
Prospecting and loyalty operations ;
Sales catalogs sent to customers and prospects	Consent	Internal CMP and subcontractor	3 years after last contact
Prevent overdue payments and fight against crazy bids with the TEMIS shared file
Consultation of and access to the shared file of restrictions on access to auctions (see complete specific information notice below*)	Legitimate interest in preventing unpaid bills and fighting crazy bidding	all auction sales structures operating in France and subscribing to the TEMIS service.	Between 6 and 36 months from registration of last incident

Personal data must be provided in order to register for auctions, to bid in online auctions and to purchase and pay for lots. 

Data relating to prospective customers and online and in-store buyers is also processed for the following purposes, detailed in the sections below:

• Manage commercial email prospecting campaigns;
• Combating money laundering and the financing of terrorism;
• Meet regulatory requirements for internal control in financial institutions (internal audit, risk management and periodic control);
• Manage claims and litigation.

* Specific information TEMIS file

Crédit Municipal de Paris subscribes to the TEMIS Service, which enables it to consult and feed the File of restrictions on access to auction sales ("TEMIS File") implemented by the company Commissaires-Priseurs Multimédia (CPM), registered in the Paris Trade and Companies Register under number 437 868 425.

The TEMIS File records payment incidents (late payments and non-payments), regardless of whether bidders participate in the auction in person or remotely, and can be consulted by all auction sales structures operating in France and subscribing to the service. The list of TEMIS Service subscribers can be consulted at www.interencheres.com, in the "Buy by auction" menu, under the "Auctioneers" heading.

The bidder is hereby informed that should he fail to regularize his bidding slip within the period mentioned on the slip, Crédit Municipal de Paris may initiate a procedure to register him in the said file. Crédit Municipal de Paris will inform the bidder individually by e-mail if the bidder has been registered on the TEMIS file.

The registration of a bidder on the TEMIS file may have the following consequences:

• Limit the bidder's ability to bid with other professionals who subscribe to the TEMIS service;
• Make access to Crédit Municipal de Paris auctions conditional on the use of certain means of payment or the presentation of specific guarantees;
• Temporarily refuse the bidder participation in Crédit Municipal de Paris auctions.
• Temporarily suspend access to the "live" service of the www.interencheres.com platform managed by CPM, in accordance with the platform's general terms and conditions of use.

The personal data recorded in the TEMIS file concerning bidders who have not paid their auction slip (identity, contact details, amount of the slip and length of unpaid period) are processed under the joint responsibility of Commissaire-Priseur Multimédia and TEMIS service subscribers, including Crédit Municipal de Paris. The implementation of the TEMIS File and its use by Crédit Municipal de Paris is necessary for the purposes of its legitimate interest in preventing unpaid bills and fighting against wild bidding.

Bidders are hereby informed that the duration of their registration on the TEMIS Register is determined by the number of auction slips that remain unpaid with the Professional Subscribers to the TEMIS Register, by their cumulative amounts and by whether or not they have been regularized. The duration of registration in the TEMIS File is reduced if the Bidder regularizes all payment Incidents. It is increased when the Bidder is concerned by several unpaid slips registered in the TEMIS File. The registration of an auction slip as an Incident of Payment is automatically deleted after a maximum period of 24 months when the Bidder is the subject of only one registration, and 36 months from the date of the last Incident when the Bidder is the subject of several registrations.

Bidders wishing to know whether they are registered in the File, to contest their registration or to exercise their RGPD rights may send their requests in writing, providing proof of their identity, to the Crédit Municipal de Paris Data Protection Officer at the address: See email. Bidders also have the right to lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL) concerning their registration in the TEMIS File.

To find out more about the TEMIS File, bidders are invited to consult CPM's privacy policy, which is available at https://temis.auction/statics/politique-protection-dp-temis.pdf.

The personal data collected concerning the customer as part of the management of the banking relationship are used under the responsibility of Crédit Municipal de Paris for :

• Open, maintain and close accounts;
• Make mandatory declarations.

Here are the details of the purposes, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Managing solidarity savings contracts
Recording and updating of account holder information, management of deposits and withdrawals, creation and dispatch of periodic statements and closings;Closing of accounts.	Performance of the solidarity savings contract	Internal CMP and authorized third parties	10 years after the closing of the last solidarity savings contract, in accordance with article L.131-2 of the French Code of Financial Jurisdiction (preservation of accounting vouchers by the authorizing officer BOFIP-GCP-17-0009 dated 19/06/2017).
Draw up anonymous statistics and monitor the activity of the Solidarity Savings Service	Legitimate interest	Internal CMP	Anonymous statistics
Mandatory declarations
Declaration to the Fonds de Garantie des Dépôts et de Résolution (Deposit Guarantee and Resolution Fund); Declaration to the bank account file of the Direction Générale des Finances Publiques (FICOBA); Declarations to the tax authorities.	Legal obligations	Internal CMP, Authorized third parties	10 years after the closing of the last savings contract, in accordance with article L.131-2 of the French Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)

Personal data must be provided to open passbooks and term accounts.

Data relating to Solidarity Savings customers is also processed for the following purposes, detailed in the sections below:

• Manage commercial email prospecting campaigns;
• Combating money laundering and the financing of terrorism;
• Meet regulatory requirements for internal control in financial institutions (internal audit, risk management and periodic control);
• Manage claims and litigation.

The personal data concerning the customer collected within the framework of the conservation and expertise of objects are used under the responsibility of Crédit Municipal for the management of the expertise and conservation contracts.

Here are the details of the purposes, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Management of appraisal and conservation contracts
Keeping and monitoring contracts for the conservation of objects (deposit, storage, register of visitor access to storage premises, organization of presentation shows, removal);Management of appraisal contracts (temporary custody of objects for expert appraisal).	Performance of the expertise or conservation contract	Internal CMP and authorized third parties	10 years after the close of the last conservation and appraisal contract in accordance with article L.131-2 of the Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)
Compile anonymous statistics and monitor the activity of the Sales, Expertise and Consulting Department.	Legitimate interest	Internal CMP	Anonymous statistics

The provision of personal data is mandatory for the conclusion of contracts for the conservation and appraisal of objects.

Data relating to Expert appraisal and object conservation customers is also processed for the following purposes, detailed in the headings below:

• Manage commercial email prospecting campaigns;
• Combating money laundering and the financing of terrorism;
• Meet regulatory requirements for internal control in financial institutions (internal audit, risk management and periodic control);
• Manage claims and litigation.  

Personal data concerning beneficiaries collected as part of the Parcours Budget are used under the responsibility of Crédit Municipal de Paris for :

• File management Budget ;
• Managing personal finance coaching ;
• Organizing individual and group training and awareness-raising sessions;
• Draw up anonymous statistics and monitor activity.

Here are the details of the purposes, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Management of Parcours Budget files
Budget diagnosis and advice (diagnosis of the situation, setting up and monitoring budgets, optimizing expenses and charges, assistance in obtaining entitlements and advice on financial management, etc.).Interventions with creditors (transmission of budget reports to creditors, calculation and application for rescheduling, debt modification, etc.) ;Assistance with applications for overindebtedness files with the Banque de France (assistance with file preparation and follow-up).	Exercising the CMP's social mission of public interest	Internal CMP and third parties, with the free prior consent of the beneficiary: (1) banks lending microcredit, (2) creditors, (3) partner instructors monitoring microcredit, (4) partner structures that have referred the beneficiary to the CMP.	5 years after closure of the Parcours Budget file, in accordance with the four-year statute of limitations under public law, as set out in law no. 68-1250 of December 31, 1968. The data is then anonymized. The remaining set of anonymous data is kept for statistical purposes only.
Personal finance coaching management
Individual personal finance coaching (assessment and diagnosis of current situation, definition of objectives, monitoring of success indicators)	Legitimate interest	Internal CMP and prescribing partner	Support is provided for a maximum of 12 months. As this service is invoiced, the data is kept for 10 years after the end of the accompaniment, in accordance with article L.131-2 of the Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017).
Organization of individual and group training and awareness-raising sessions
Training management (organizing and sending invitations to participants, monitoring attendance, feedback and satisfaction)	Legitimate interest	Internal CMP and prescribing partner
Statistics and business management
Compile anonymous statistics and monitor the activity of the Inclusion and Financial Culture Department.	Legitimate interest	Internal CMP	Anonymous statistics

The provision of personal data is mandatory for the smooth running of the Budget Path, particularly in the case of microcredit applications, overindebtedness filings and intervention with creditors.

Personal data collected in connection with pawnbroking, savings account management, auctions, appraisals and the safekeeping of objects is also used to meet CMP's legal obligations to combat money laundering and the financing of terrorism, and for the internal control of financial institutions (internal audit, risk management and periodic control).

Here are the details of the processing operations, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Combating money laundering and the financing of terrorism
Gathering and storing the information needed to know the customer and the origin of funds; classifying customers with regard to money laundering and terrorist financing risks.	Legal obligation of customer due diligence and the fight against money laundering and the financing of terrorism (L561-1 et seq. of the French Monetary and Financial Code)	Internal CMP, subcontractor and authorized third parties (Direction Générale du Trésor, ACPR's TRACFIN unit)	10 years after the closure of the last contract, in accordance with article L.131-2 of the French Code des juridictions financières (conservation des pièces justificatives comptables de l'ordonnateur BOFIP-GCP-17-0009 du 19/06/2017)
Monitoring of certain accounts and contracts; Management of alerts and suspicious transaction reports; Application of financial sanctions and asset freezes.			5 years from the end of the asset freeze measure or the end of the business relationship for customers who have been audited and closed without further action. 10 years from the end of the business relationship for customers subject to monitoring and enhanced scrutiny (L561-12 of the Monetary and Financial Code).
Internal control of financial institutions (internal audit, risk management and periodic control)
Management of audit and internal control operations; Management and measurement of credit and operational risks (including fraud risk).	Legal obligations relating to the internal control of financial institutions (Decree of November 3, 2014, Article 17).	Internal CMP and authorized third parties (ACPR)	2 years after Autorité de Contrôle Prudentiel et de Résolution (ACPR) inspections

Personal data collected in connection with pawnbroking, savings account management, auctions, appraisals and the conservation of objects is also processed, under the responsibility of Crédit Municipal de Paris, for the purposes of commercial prospecting campaigns.

Here are the details of the processing operations, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Management of sales prospecting campaigns
Organization of commercial prospecting campaigns (audience selection, preparation and dispatch of e-mails, management of opposition requests, follow-up and statistics).	Legitimate interest for customer data and consent for prospect data	Internal CMP, subcontractor and authorized third parties	3 years after last contact

In the context of prospecting campaigns, the e-mail addresses of customers and prospects concerned are transferred to the United States, to the servers of the provider of the prospecting campaign management platform. Transfers are governed by the European Commission's Standard Contractual Clauses, available for consultation at the following address: https: //mailchimp.com/fr/legal/data-processing-addendum/.

All CMP premises and their surroundings are under video surveillance to ensure the safety of people and property, in particular for :

• Secure access to the building;
• Ensure the safety of staff and customers;
• Protect assets (buildings, objects, equipment, cash) ;
• Identify potentially suspicious or dangerous behavior;
• Pinpoint the origin and perpetrator of an incident;
• Transmit evidence to law enforcement agencies for criminal investigations.

In the event of an incident, images may be viewed by authorized Crédit Municipal de Paris staff and law enforcement agencies.

The processing of video surveillance images is carried out on the basis of the data controller's legitimate interests (protection and security of people and property).

Video surveillance images are kept for 30 days.

A cookie is a string of information, generally small in size and identified by a name, which may be transmitted to your browser by a website to which you are connected. Your web browser will store it for a certain period of time and send it back to the web server each time you reconnect.
Two types of cookies are deposited on the various CMP sites, used for :

• Optimal site operation and display (language preference, screen size, cookie consent, etc.);
• Measuring site traffic using Google Analytics (counting the number of visits, source of visits, analyzing site traffic to improve performance). In this respect, the data generated by Google Analytics cookies concerning the use of CMP sites will be transmitted and stored by Google on its servers in the United States and will be reused in accordance with their privacy policy (https://policies.google.com/privacy?hl=fr-CA#whycollect).
  No targeted advertising or profiling operations based on browsing data are implemented by CMP.
  Cookies are stored on the browser for 13 months after they have been deposited on the user's terminal.
  You may object to cookies necessary for the operation of the sites and delete them using your browser settings, however your user experience may be degraded.
  Similarly, you may object to cookies intended to measure traffic to CMP sites using your browser settings. In this case, we will not be able to know if and when you have visited our sites.
  To find out more about browser settings, visit the CNIL's "cookies: tools for controlling them" page (https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser).

The personal data of website users is also used to manage responses to various questions and contact requests made by users to the CMP online or by e-mail.
In particular, the CMP has equipped its website with a conversational agent enabling users to easily find answers to the most frequently asked questions and to ask new questions. The personal data (surname, first name, e-mail address) of users who ask a new question are processed under the CMP's responsibility by TeamBrain, the service provider and subcontractor, for the sole purpose of managing the conversational agent.
The data are accessible, within the limits of their authorizations, to the people responsible for answering questions.
The personal data of users who ask a new question via the conversational agent on the CMP website are kept for 1 month, after which they are deleted.

In the event of claims and disputes

Crédit Municipal de Paris uses personal data to manage claims and disputes.

Goals	Foundation	Recipients	Shelf life
Claims and litigation management
Investigation and response to claims, mediation and litigation; file for monitoring claims and processing times.	CMP's legitimate interest	Internal CMP and authorized third parties	If the claim or dispute concerns a customer: same period as for the customer file. Other claims or disputes: limitation period applicable to the dispute.

The provision of personal data, in particular those provided in the online complaint form, is mandatory in order to respond to the request.

When recruiting an agent for the CMP

The personal data of candidates for employment with the CMP is processed under the responsibility of Crédit Municipal de Paris as part of the management of staff recruitment
Here are the details of the processing operations, their basis as well as the recipients and associated retention periods:

Goals	Foundation	Recipients	Shelf life
Managing the recruitment of CMP staff
Receipt and registration of applications sent via online forms or directly by post, implementation of recruitment procedures in liaison with line management, response to applicants.	Execution of pre-contractual measures and establishment of the contractual relationship between the CMP and job or internship applicants	Internal CMP	For successful candidates: storage of data in the individual file of civil servants, stored electronically in accordance with the decree of December 21, 2012; For unsuccessful candidates: 5 years from the date on which the position was filled (in the event of legal recourse in view of the statute of limitations set out in article L.131-13 of the General Civil Service Code).

You have the right to access, rectify, oppose, limit, delete and port your personal data, in the cases provided for by the regulations. To better understand your rights, go to "Understanding your rights"(https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles) on the CNIL website.
Subject to production of valid proof of identity, you can exercise these rights in several ways:

• By sending an e-mail to the Data Protection Officer at the following address: See email;
• By sending a letter to the following address: Crédit Municipal de Paris, Délégué à la Protection des Données, 55 rue des Francs-Bourgeois 75181 Paris Cedex 04.
  Please specify in your request which data or processing operations it relates to.
  A reply will be sent to you within a maximum of one month of receipt of the request.
  The right of access in the context of the fight against money laundering and terrorist financing, has a special procedure, called "indirect".
  In accordance with the provisions of Article L. 561-45 of the French Monetary and Financial Code, the right of access to processing carried out for the purposes of applying the provisions relating to the fight against money laundering and the financing of terrorism is exercised with the Commission Nationale de l'Informatique et des Libertés (CNIL) via an indirect right of access procedure.
  To find out more about the procedures for exercising indirect right of access, visit the CNIL website(https://www.cnil.fr/fr/cnil-direct/question/le-droit-dacces-indirect-comment-ca-marche).

What can I do?

You have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority responsible for ensuring compliance with personal data protection obligations, by visiting the "complaints" section(https://www.cnil.fr/fr/plaintes)of the CNIL website.