Privacy Policy

Website : www.philocale.fr

This Privacy Policy (hereinafter the “Privacy Policy”) is an extension of the Website’s General Terms and Conditions of Use (hereinafter the “Terms”), to which it is inextricably linked. Its purpose is to inform users of the www.philocale.fr website about the methods of collecting, processing, storing, and protecting their personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data (hereinafter “GDPR”) and French Law No. 78-17 of 6 January 1978, as amended, known as the “Data Protection Act”. By accessing the Website and using its services, the user acknowledges having read the Terms and Conditions and this Privacy Policy, and accepts them without reservation.

1. Data Controller

The data controller for personal data collected via the Website is:

PHILOCALE, a single-member limited liability company (EURL) with a capital of €30,000, registered with the Orléans Trade and Companies Register under number 491 498 820, whose registered office is located at 58, rue de la Bretonnerie, 45000 Orléans, France, represented by Maître Matthieu SEMONT, auctioneer (CVV accreditation no. 2009-702).

Contact: contact@philocale.fr – +33 2 38 53 71 66

2. Data collected and purposes of processing

PHILOCALE only collects data that is strictly necessary to achieve the purposes described below.

2.1 Online Estimate or Inventory Request Form

When the User submits an online estimate or inventory request via the dedicated form on the Site, PHILOCALE collects the following data:

Name, surname;
email address;
telephone number;
postal address; and,
descriptions and photographs of the items to be appraised.

Purpose: to process the User’s request for an estimate and to contact the User.

Legal basis: execution of pre-contractual measures taken at the request of the Site User (GDPR, art. 6,1, b)).

Storage period: three (3) years from the last exchange with PHILOCALE.

2.2 General Contact Form

When the User uses the Site’s general contact form, PHILOCALE collects the following data:

Name, surname;
email address;
telephone number; and,
the content of the User’s message.

Purpose: To process your information request and manage our relationship with the firm.

Legal basis: PHILOCALE’s legitimate interest in responding to inquiries (GDPR, Art. 6, 1, f)).

Retention period: Three (3) years from the date of your last contact with PHILOCALE.

2.3 Online payment or advance deposit

When the User pays for their invoice or makes a deposit to bid on the Site, the payment details (bank card number, expiry date, and security code) are collected and processed directly by the Firm’s payment service provider, Monetico, a simplified joint-stock company with a capital of €53,212,140, whose registered office is located at 4, rue Frédéric-Guillaume Raiffeisen — 67000 Strasbourg, registered with the Strasbourg Trade and Companies Register under number B 312 730 674. PHILOCALE does not store the User’s bank details on its own servers at any time.

PHILOCALE only records the transaction data (amount, date, and reference) necessary for its accounting management and in accordance with legal obligations.

Purpose: Processing payment, managing accounting obligations, and complying with legal requirements.

Legal basis: Performance of a contract (GDPR, Art. 6.1(b)) and legal obligation (GDPR, Art. 6.1(c)).

Retention period: Ten (10) years from the end of the relevant financial year for the transaction.

2.4 Scheduling an Appointment for Lot Collection

When the User schedules an appointment on the Website via the Calendly platform to collect their Lot, PHILOCALE collects the following data:

first and last name;
email address;
receipt number; and
selected time slot.

Calendly LLC is a data processor for PHILOCALE for this functionality. The processing of this data is governed by a data processing agreement between PHILOCALE and Calendly, in accordance with Article 28 of the GDPR. As Calendly LLC is established in the United States, the transfer of your data is governed by standard contractual clauses adopted by the European Commission.

Purpose: scheduling appointments for Lot collection.

Legal basis: performance of pre-contractual or contractual measures (GDPR, Art. 6, 1, b))

Retention period: three (3) years from the date of the appointment.

2.5 Instagram Integration (Meta API)

The Site integrates a preview of posts from the Study’s Instagram account via the Meta Platforms Ireland Limited API. This integration may result in Meta collecting the User’s browsing data (IP address, cookie identifiers) in accordance with Meta’s privacy policy.

PHILOCALE does not directly collect or process the data resulting from this integration. Users are encouraged to consult Meta’s privacy policy, available at www.facebook.com/privacy/policy.

Purpose: Displaying recent posts from the Study for informational purposes.

Legal basis: PHILOCALE’s legitimate interest in communicating about its activities (GDPR, Art. 6, 1, f)).

2.6 Anti-Money Laundering (AML/CFT) Obligations

In accordance with its legal obligations regarding anti-money laundering and counter-terrorist financing (AML/CFT), PHILOCALE is required to verify the identity of individuals participating in its auctions, pursuant to Articles L. 561-1 et seq. of the French Monetary and Financial Code. These verifications are carried out through direct contact with the auction house and not via the Website.

Data collected: identity document (copy), proof of address if applicable.

Purpose: compliance with AML/CFT legal obligations.

Legal basis: legal obligation (GDPR, Art. 6, 1, c)).

Retention period: five (5) years from the end of the business relationship (Article L. 561-12 of the French Monetary and Financial Code).

2.7 Browsing Data and Cookies

When browsing the Site, technical data may be automatically collected, including your IP address, browser type and version, pages viewed, and connection dates and times. This data is collected via cookies and trackers, the details of which are outlined in Article 5 of this policy.

Purpose: Site security, audience measurement, and improvement of the user experience.

Legal basis: Legitimate interest (strictly necessary cookies) or consent (audience measurement and social media cookies).

Retention period: Maximum thirteen (13) months for cookies; one (1) year for connection data.

3. Data Disclosure

The personal data collected via the Site is intended for the following individuals and entities, strictly within the limits of the purposes described above:

PHILOCALE staff (auctioneers, experts, administrative staff) authorized to process inquiries.
PCI-DSS certified payment service provider, responsible for the secure processing of financial transactions.
Calendly LLC (subcontractor), for managing appointment scheduling.
OVH SAS (hosting provider), for hosting the Site and associated data within the European Union.
Meta Platforms Ireland Limited (for Instagram integration), subject to applicable consent.
Competent authorities (Tracfin, tax authorities, judicial authorities), in the event of a legal obligation or requisition.

PHILOCALE does not sell, rent, or transfer your personal data to third parties for commercial purposes.

4. Data Transfer Outside the European Union

The personal data of Site Users is hosted within the European Union, on the servers of OVH SAS (Roubaix, France).

Some of our third-party service providers may be located outside the European Union, including:

Calendly LLC (United States): transfers are governed by standard contractual clauses adopted by the European Commission, in accordance with Article 46 of the GDPR.

Meta Platforms Ireland Limited (Ireland, with data transfers to the United States): transfers are governed by the EU-US Data Privacy Framework and standard contractual clauses.

You can obtain a copy of the safeguards implemented for these transfers by sending a request to contact@philocale.fr.

5. Cookies and Trackers

A cookie is a small text file placed on your device (computer, tablet, smartphone) when you browse the Site. Cookies ensure the proper functioning of the Site, improve its performance, and offer you tailored features.

5.1 – Strictly Necessary Cookies

These cookies are essential for the Site to function. They enable, in particular, the security of forms and the management of your cookie preferences. They do not require your prior consent.

5.2 – Audience Measurement Cookies

These cookies allow us to analyze Site traffic (pages visited, visitor origin, session duration) in order to improve the content and user experience offered. They are only placed after obtaining your consent.

Retention period: thirteen (13) months maximum.

5.3 – Social Media Cookies (Meta/Instagram)

The integration of PHILOCALE’s Instagram feed on the Site may result in Meta Platforms Ireland Limited placing cookies that allow Meta to identify you during your browsing. These cookies are only placed after obtaining your consent.

Retention period: according to Meta’s settings, up to a maximum of thirteen (13) months.

5.4 – Managing your preferences

On your first visit to the Site, an information banner allows you to accept or refuse non-essential cookies. You can change your choices at any time:

via the cookie manager accessible from the banner or the footer of the Site;

via your internet browser settings (Internet Explorer, Firefox, Chrome, Safari, Opera, etc.). Please note: disabling cookies via your browser may affect the operation of certain Site features; and,

for Meta cookies, via your Instagram or Facebook account settings.

6. Your rights regarding your personal data

In accordance with Articles 15 to 21 of the GDPR and the French Data Protection Act, you have the following rights concerning your personal data:

Right of access (Art. 15 GDPR): to obtain confirmation as to whether or not personal data concerning you is being processed and, where applicable, to obtain a copy of that data, as well as information on the methods of processing.
Right to rectification (Art. 16 GDPR): to obtain the correction of inaccurate or incomplete personal data concerning you.
Right to erasure (Art. 17 GDPR): to obtain the deletion of your personal data, subject to any legal retention obligations imposed on PHILOCALE.
Right to restriction of processing (Art. 18 GDPR): to obtain the temporary suspension of the processing of your personal data in certain cases provided for by the GDPR.
Right to data portability (Art. 20 GDPR): to receive your data in a structured, commonly used, and machine-readable format and to transmit it to another data controller, where the processing is based on your consent or on a contract.
Right to object (Art. 21 GDPR): to object at any time, on grounds relating to your particular situation, to the processing of your data based on PHILOCALE’s legitimate interest. You have an absolute right to object to the processing of your data for direct marketing purposes.
Right to withdraw your consent: where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before the withdrawal.
Right to define post-mortem directives (Art. 85 IF Law): to define directives concerning the storage, erasure, and communication of your data after your death.

6.1 – How to Exercise Your Rights

To exercise one or more of these rights, you can send your request:

by email: contact@philocale.fr (attaching a copy of your identity document if necessary to verify your identity).

by mail: PHILOCALE, 58 rue de la Bretonnerie, 45000 Orléans, France (attaching a copy of your identity document).

PHILOCALE undertakes to respond to your request within one (1) month of receipt. This period may be extended by two (2) additional months in the case of a complex request or a large number of simultaneous requests, in which case you will be informed within the initial one-month period.

6.2 – Right to lodge a complaint with the CNIL

If you believe that the processing of your personal data does not comply with the GDPR or the French Data Protection Act, you have the right to lodge a complaint with the competent supervisory authority in France:

National Commission for Information Technology and Civil Liberties (CNIL)

3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07

Telephone: +33 1 53 73 22 22

Website: www.cnil.fr

7. Data Security

PHILOCALE implements appropriate technical and organizational measures to ensure a level of security commensurate with the risk, in accordance with Article 32 of the GDPR. These measures include, in particular:

encryption of communications between your browser and the Website via the SSL/TLS protocol (HTTPS);

secure online payments via a PCI-DSS certified provider, without PHILOCALE storing complete bank details;

strict access controls to data, limited to authorized personnel within the Firm;

regular data backups; and

regular updates of the systems and software used.

In the event of a personal data breach likely to pose a risk to your rights and freedoms, PHILOCALE undertakes to notify the CNIL (French Data Protection Authority) of this breach within seventy-two (72) hours of its discovery, in accordance with Article 33 of the GDPR. If the breach is likely to result in a high risk, you will be informed as soon as possible, in accordance with Article 34 of the GDPR.

8. Changes to the Privacy Policy

PHILOCALE reserves the right to modify this Privacy Policy at any time, particularly to reflect changes in applicable regulations, decisions of the CNIL (French Data Protection Authority) or the Court of Justice of the European Union, or changes to the data processing activities implemented.

The current version is available on the Website on the date of your visit. In the event of a substantial change, you will be notified by any appropriate means (information banner on the Website, email if your email address is known to PHILOCALE). The date of this update is indicated at the top of this document.

9. Contact

For any questions regarding this Privacy Policy or the protection of your personal data, you can contact PHILOCALE:

By email: contact@philocale.fr

By mail: PHILOCALE, 12 rue Jean Nicot, 45140 Saint-Jean-de-la-Ruelle (auction house)

By phone: +33 2 38 53 71 66

Last updated: June 1, 2026