Privacy policy and cookies management

Privacy Policy

Company

Data Controller : S.A.M ACTIS
14 avenue de Grande Bretagne, Le George V – 98000 Monaco.

S.A.M ACTIS is the controller of the data directly or indirectly collected from visitors and users of the website. This privacy policy complies with Monaco Law No. 1.565 of 3 December 2024 relating to the protection of personal data.

Definitions

Personal Data: Personal data refers to any information that makes it possible to directly or indirectly identify a natural person.
Examples: name, registration number, telephone number, photograph, date of birth, municipality of residence, fingerprint, IP address, etc.

Processing of Personal Data: “Processing” means any operation or set of operations performed on personal data, such as collection, recording, use, transmission, or disclosure.

Data Controller: The controller of personal data processing is the person or entity that determines the purposes and means of the processing.

Processor: A legal entity that processes personal data on behalf of the data controller as part of its activities.

Data Subject: A natural person whose data is subject to processing, namely, within the scope of this policy, clients, website users, email recipients, and more generally any person whose personal data is processed by S.A.M ACTIS.

APDP: The Personal Data Protection Authority (Autorité de Protection des Données Personnelles), which is the independent administrative authority in Monaco responsible for personal data protection.

Data Collected

S.A.M ACTIS collects several types of personal data:

  • Identity data: Last name, first name, nationality, and more generally any relevant document in the context of our contractual relationships or legal obligations.
  • Address and contact details: Place of residence and contact details (email address, telephone number).
  • Browsing data: IP address, browser, duration of visit, operating system.
  • Data required to contact us: Company name, subject of the request.
  • Professional life data: CV, position held, company contact details.
  • Video surveillance data: Images, silhouettes, faces, camera identification, date and time of recording.

 

S.A.M ACTIS does not collect sensitive data. Where applicable, a specific information notice and/or consent will be provided.

Purpose of processing

S.A.M ACTIS undertakes to process only personal data that is strictly necessary for the defined purposes:

  • Allow users to request information about our services
  • Allow users to discover all of our services
  • Identification of users wishing to contact S.A.M ACTIS
  • Management of communication tools (email, telephony)
  • Management of external communications (event invitations)
  • Recruitment management
  • Wi-Fi services management
  • Management of technical security measures
  • Video surveillance management
  • Management of client and prospect databases

S.A.M ACTIS undertakes to process and collect your personal data in a lawful and fair manner.

Legal bases for Processing

S.A.M ACTIS may process your personal data on several distinct legal bases:

On the basis of a contractual or pre-contractual relationship with its candidates, prospects, and clients, such as the management of client and prospect databases or recruitment;

For the purposes of pursuing a legitimate interest of the data controller, such as managing communication tools, security measures, and video surveillance;

For processing activities not covered by the above categories, S.A.M ACTIS undertakes to obtain your consent.

Recipients and data transfers

S.A.M ACTIS may transmit your personal data to various recipients in the course of its activities:

  • The relevant internal department within S.A.M ACTIS in order to process your requests as part of contractual relationship follow-up;
  • Authorized service providers and processors required for the proper functioning of our services;
  • Monaco State services in the exercise of their official duties.

 

No transfer of personal data outside Monaco or the European Union is carried out. Where a transfer were to take place, it would comply with all applicable legal requirements.

Data Retention Period

Personal data is retained in a form that allows the identification of data subjects for no longer than is necessary for the purposes for which it was processed.

By way of example, data collected as part of a contractual relationship with a client will be retained for a period of 5 years after the end of the contract.
Your connection logs will be retained for a maximum of one year.

For further information on retention periods, you may contact our Data Protection Officer (DPO) at dpo@ACTIS.mc .

Video Surveillance

For the purpose of ensuring the security of property and individuals accessing certain premises, S.A.M ACTIS has implemented a video surveillance system.

In accordance with applicable legal provisions, images captured by video surveillance systems are retained for no longer than 30 days. Only authorized persons, acting within the scope of their duties, may view, record, and, where applicable, securely transmit these images to the competent judicial and law enforcement authorities.

Rights of Individuals

In accordance with Monaco law, you have a number of rights:

  • Right of access: You have the right to access the personal data held by the website.
  • Right to rectification: You have the right to rectify inaccurate personal data concerning you.
  • Right to erasure: You have the right to request the erasure of your personal data. However, S.A.M ACTIS may retain such data for legitimate or legal reasons.
  • Right to object: You have the right to object to the processing of your data.
  • Right to restriction: You have the right to request the suspension of the processing of your personal data where the accuracy of the data is contested, where the processing is unlawful, or where the data subject has objected to the processing.
  • Right to data portability: In certain cases, you have the right to receive the personal data you have provided to us in a structured, commonly used format and the right to transmit such data to another data controller, where technically feasible. This right applies only where the processing of your personal data is based on your consent or on the performance of a contract and is carried out using automated means.
  • Right to human oversight: You have the right not to be subject to a decision based solely on automated processing.

In addition, you have the right to lodge a complaint with the APDP: Home – APDP.

Exercising your rights

To exercise your rights, you may contact us:

  • By email: dpo@ACTIS.mc
  • By post: For the attention of the Data Protection Officer – 14 Avenue de Grande Bretagne, 98000 Monaco.

Security and Confidentiality

S.A.M ACTIS, as the data controller, determines and implements the measures necessary to protect personal data processing systems in order, as far as possible, to prevent any malicious intrusion and to avoid any loss, alteration, or disclosure of data to unauthorized persons.

We determine and implement appropriate technical and organizational measures to ensure the confidentiality of data in accordance with the requirements of the APDP and Monaco Law No. 1.565 of 3 December 2024 relating to the protection of personal data, including in particular:

  • Appointment of a Data Protection Officer (DPO): A DPO has been appointed within the ACTIS Group. The DPO is responsible for all missions provided for under Monaco law, as well as additional tasks, and is able to answer any questions regarding the application of the aforementioned regulations.
  • Awareness-raising and compliance: Training and awareness of personal data processing and commitment to compliance with Monaco law among all employees.
  • Password security: Use of complex passwords that are regularly renewed.
  • Workstation security: Implementation of all necessary measures (antivirus, anti-malware, firewall).
  • Backup and business continuity: Secure backup systems and archive management.
  • Physical security: Our premises are physically secured (access codes, alarms).

We take reasonable measures to ensure that your personal data is not lost, misused, accessed, or disclosed.

 

Mandatory Nature of Certain Information in the Website Contact Form:
Within the contact form, mandatory fields are marked with an asterisk. Failure to complete mandatory information does not give rise to any obligation on the part of S.A.M ACTIS to respond.

 

Changes to the Privacy Policy:
S.A.M ACTIS may amend this privacy policy in order to comply with new legislation. If significant changes are made, you will be informed through notices on our websites and communication channels.