+377 97 97 79 29
info@miells.com
14 avenue de la Costa, 98000 MonacoPrivacy Policy for MIELLS.COM
Miells Christie’s International Real Estate
Last update : December 30, 2025
1. Preambule
As part of its real estate agency activities, SAM MIELLS, hereinafter “the Agency”, is required to collect and process personal data of its clients and prospects.
Aware of the importance of ensuring data confidentiality and respect for the privacy of its clients and prospects, the Agency undertakes, in accordance with the provisions of Law No. 1.565 of December 3, 2024 relating to the protection of personal data, to implement adequate measures to ensure the protection, confidentiality and security of the personal data collected. This policy aims to inform clients and prospects about the commitments made by the Agency to ensure respect for their personal data as well as their rights concerning the processing of such data. This policy may evolve according to the legal and regulatory context.
2. Scope of Application
This policy applies to all processing of personal data of clients and prospects, implemented by the Agency.
3. Data Controller
In its capacity as Controller of the processing of personal data, the Agency is required to comply with the obligations incumbent upon it.
The Agency’s contact details are as follows: SAM MIELLS – Palais de la Scala – 1 Avenue Henry Dunant – 98000 Monaco
Tel : +377.97.97.79.29
E-mail : info@miells.com
4. Data Collected and Processed, Purposes and Legal Bases for Processing
The Agency ensures that it only collects personal data from its clients and prospects that is strictly necessary for the purposes of the processing operations implemented, details of which follow:
4.1 Data Collected at the Agency
| Processing Purpose | Data Categories | Legal Basis for Processing |
| Management and execution of prospecting, targeted marketing and personalized communication operations | – Identification data (title, surname, first name, contact details (email, postal address and telephone)) – Data relating to the real estate project and/or characteristics of real estate properties – Data relating to family, personal and professional situation – Data relating to financial and asset situation – Any other personal data necessary for the purpose of processing. | Consent / Legitimate interest in promoting the Agency’s services |
| Conducting studies, reporting and statistics | Title, surname, first name, contact details, data relating to the real estate project and/or characteristics of real estate properties and any other personal data necessary for the purpose of processing. | Legitimate interest in improving the performance and quality of the Agency’s services |
| Management and processing of requests to exercise rights relating to personal data of data subjects | Title, surname, first name, contact details, subject of request, copy of exchanges and any other personal data necessary for the purpose of processing. | Legal obligation |
| Organisation of preparatory steps for the marketing of properties promoted by the agency (property descriptions, organisation of viewings …) | Identification data (title, last name, first name), contact details (email, postal address and telephone number) Data relating to the real estate project and/or the characteristics of the properties Descriptive data relating to the property Data relating to financial and asset situation Any other personal data necessary for the purpose of the processing | Legitimate interest in promoting the Agency’s services |
| Preparation and drafting of pre contractual and contractual documents with a view to their signature by the clients | Identification data (title, last name, first name), contact details (email, postal address and telephone number) Data relating to the real estate project and/or the characteristics of the properties Descriptive data relating to the property Data relating to family, personal and professional situation Data relating to financial and asset situation Any other personal data necessary for the purpose of the processing. | Performance of a contract to which the data subject is a party or implementation of pre contractual measures taken at their request |
| Management and processing of complaints | Title, surname, first name, contact details, subject of complaint, copy of exchanges and any other personal data necessary for the purpose of processing. | Legitimate interest in improving the quality of the Agency’s services |
| Proper execution of pre-contractual and contractual documents signed by clients | Identification data (title, surname, first name, contact details (email, postal address and telephone)) – Data relating to the real estate project and/or characteristics of real estate properties – Data relating to family, personal and professional situation – Data relating to financial and asset situation – Any other personal data necessary for the purpose of processing. | Performance of a contract to which the data subject is party or pre-contractual measures taken at their request |
| Compliance with legal and regulatory obligations resulting in particular from real estate agency activities | Identification data (title, last name, first name), contact details (email, postal address and telephone number) Data relating to the real estate project and/or the characteristics of the properties Data relating to family, personal and professional situation (In particular any possible links with the political sphere) Data relating to financial and asset situation (origin of assets and of the funds involved in the transaction…) Any other personal data necessary for the purpose of the processing (reputation…) | Legal obligation |
| Organization and management of public and private events organized by the Agency | Identification data (title, surname, first name, contact details (email, postal address and telephone)) | Consent / legitimate interest in promoting the Agency’s services |
4.2. Data Collected via the Agency’s Website
| Processing Purpose | Data Categories | Legal Basis for Processing |
| Responding to information requests sent via the Website forms | Title, surname, first name, contact details, data relating to the real estate project and/or characteristics of real estate properties. | Consent |
| Relationship management and follow-up of your requests in our CRM | Legitimate interest | |
| Sending newsletters and communications about our services | Title, last name, first name, contact details, data relating to the real estate project and/or the characteristics of the properties, technical and browsing data (pages visited, device used, IP address, cookies, geographic data, behavioural data, traffic volume, traffic source) and any other personal data necessary for the purpose of the processing. | Consent |
| Management and execution of prospecting, targeted marketing and personalized communication operations | Consent / Legitimate interest in promoting the Agency’s services | |
| Audience analysis (GA4) | Technical and browsing data (pages visited, device used, IP address, cookies, geographic data, behavioural data, traffic volume, traffic source) and any other personal data necessary for the purpose of the processing. | Consent (via cookie banner) |
In the absence of consent, no navigation data is collected for analytical purposes.
All personal data is collected from the data subjects or when the information is publicly available.
5. Data Recipients
As a general principle, your personal data are processed by the agency’s internal staff within the scope of their duties and functions. This includes in particular:
Staff members (this category broadly includes employees, interns, temporary workers…) authorised within the agency and carrying out missions related to marketing, communication, commercialisation, client and prospect relations, administrative, legal and financial matters, business development, IT, projects, recruitment and human resources.
External recipients may also receive certain personal data. This includes in particular:
Services or entities responsible for administrative, legal, tax and financial oversight (statutory auditors, services or entities responsible for internal or external procedures, legal advisors, financial advisors, accountants, organisations authorised to carry out inspections…)
The agency’s partners, service providers, suppliers, insurers, brokers or any other partners offering services to the agency’s contacts.
Social and tax authorities, judicial auxiliaries and ministerial officers receiving certain personal data in the context of their duties.
In the context of our legal or regulatory obligations, your personal data may be communicated to competent authorities entitled to access them, in particular in the event of police, judicial or administrative requisitions.
The data communicated to the recipients mentioned above do not necessarily include all the data in our possession, but only those necessary for the purpose related to the recipient involved.
6. Storage and Transfer of Your Personal Data
Your personal data are preferably processed within the Principality.
SAM MIELLS may be required to transfer certain data to its service providers or partners located outside the Principality.
The majority of MIELLS’ partners involved in the processing of personal data are located in jurisdictions providing an adequate level of protection as referred to in Article 97 of Law No. 1.565 of 3 December 2024 (European Union, Switzerland…).
However, for the purposes of carrying out certain processing activities, your personal data may also be transferred to third party entities established in jurisdictions that do not provide an adequate level of protection.
In such cases, contractual clauses or other required safeguards are implemented beforehand in order to ensure appropriate protection of your personal data in accordance with Monegasque legislation.
7. Retention of Personal Data
The retention of your personal data takes place in two stages:
- An active database from which your data are regularly used by the agency’s staff and operationally processed in order to achieve the purpose for which they were collected (for example processing contractual information for the proper performance of the contract).
- An intermediate archiving phase once the purpose for which the data were collected has been fulfilled (for example the end of a rental agreement). The data are no longer actively used by the agency’s departments but may still be accessed due to their administrative interest (management of potential disputes, evidentiary purposes under AML CFT P C regulations or any other legal, regulatory or evidentiary obligation).
By way of example and without limitation:
| Type de données | Base active | Base intermédiaire (relation agence/client) | |
| Management of a rental | Last name, first name, financial data and any other data necessary for the performance of the contract. | Duration of the contractual relationship | 5 years after the end of the contractual relationship |
| Management of a sale | Last name, first name, financial data and any other data necessary for the performance of the contract. | Duration of the commercial transaction | 5 years after the end of the commercial transaction |
Management of AML CFT P C obligations | Last name, first name, identity data, contact details, profession, origin of assets and supporting documents, economic or criminal sanctions, freezing of funds and any other information necessary to comply with legal obligations. | Duration of the business relationship | 5 years after the end of the business relationship, which may be extended by 5 years by the agency when necessary to prevent or detect acts falling within the scope of AML CFT P C regulations or when requested by the AMSF, the Prosecutor General or the investigating judge. |
| Management of prospecting activities | Profile name, social media account, last name, first name, email, telephone number | 3 years from the last expression of interest from the prospect | 5 years from the end of the active retention period in order to address potential needs related to disputes, legal evidence… |
| Audience analysis | Pages visited, device used, IP address, cookies, geographic data, behavioural data, traffic volume, traffic source and any other personal data necessary for the purpose of the processing. | 13 months from their first insertion, without extension during subsequent visits | 5 years from the end of the active retention period in order to address potential needs related to disputes, legal evidence… |
| Accounting documents | Financial data, transaction dates, identification of the parties, amounts | 10 years from the end of the financial year |
Personal data processed in the context of managing requests to exercise rights or complaints is retained for the period strictly necessary to process the request, then for an additional reasonable period allowing the processing to be justified and to respond to any legal or litigation obligations.
Beyond the above mentioned retention periods, the personal data of the Agency’s clients and prospects are deleted or anonymised.
8. Data Security
Organisational and technical security measures are implemented in a manner appropriate to the structure of the agency, the categories of personal data processed, the state of the art, the implementation costs, as well as the nature, scope, context, risks and purposes of the processing. These measures vary depending on the likelihood and severity of the risks in order to protect the rights and freedoms of individuals, your personal data against any potential breach, notably resulting from loss, alteration or disclosure to unauthorised third parties, and more generally to preserve the confidentiality of such personal data and ensure a level of security appropriate to the risk.
However, these measures cannot impose an obligation of result on the agency due to the inherent difficulties and proven risks associated with operating activities on the internet.
In the event of difficulties, the agency will use its best efforts to contain the risks and ensure the implementation of appropriate measures in accordance with legal and regulatory obligations (corrective measures, notification to the APDP and, where necessary, to the data subjects…).
Only authorised recipients who are entitled to process your personal data and those who need to know them in the course of their activities or duties have access to them (see above).
When processors are involved in the processing chain, the agency ensures beforehand that contractual compliance with personal data protection regulations is respected, particularly regarding security, confidentiality, the exercise of rights and any other required obligations.
9. The Rights of the Data Subject and the Exercise of Their Rights
9.1. The Rights of the Data Subject
By virtue of the provisions of Law No. 1.565 of December 3, 2024, the Agency’s clients and prospects, whose data has been collected, have the ability to exercise the following rights:
- The right to information;
- The right of access to their data;
- A right to rectification of their data;
- The right to erasure of their data;
- The right to restriction of processing;
- The right to object to the processing of their data;
- The right to data portability;
- The right to withdraw their consent;
- A right to lodge a complaint with the Personal Data Protection Authority (APDP).
9.2. Exercise of the Rights of the Data Subject
These rights may be exercised with the Agency that collected the personal data in the following manner:
By post, by writing to the address: SAM MIELLS – Palais de la Scala – 1 Avenue Henry Dunant – 98000 Monaco
By electronic means, at the address: privacy@miells.com
The request must indicate the surname, first name, postal address, email of the applicant and if possible be accompanied by any element justifying their identity.
The Agency provides a response within 1 month from receipt of the request to exercise the right. In certain cases, related to the complexity of the request or the number of requests, this period may be extended by an additional 2 months.
The exercise of these rights may be limited, in particular where the agency is subject to legal and regulatory obligations (AML CFT P C obligations…), where reasons of public interest or the agency’s legal defence oppose it, or where the request made is manifestly unfounded or excessive (repetitive requests…).
In the event of no response or an unsatisfactory response, the data subject has the option to contact the Personal Data Protection Authority (APDP) at www.apdp.mc.
10. Cookie management
During your visit to the website, information relating to your browsing on the site may be recorded on your device through the use of “Cookies” and other trackers or similar technologies. These storage and information retrieval files may include, for example, a history of your visits to the website, a language preference, a location…
Cookies are placed on your device subject to the choices you have expressed regarding cookies, which you may modify at any time.
The cookies that may be used include in particular:
Session cookies which disappear as soon as the user leaves the browser or the website
Persistent cookies which remain until their expiry date or validity period, or until the user deletes them using the features of their browser (deletion of browsing data…)
10.1. Methods for obtaining consent
The installation and storage of cookies on your device generally require the collection of your free, informed, specific and unambiguous consent. By way of exception, technical files necessary for the proper functioning of the website do not require your consent. (Usercentrics Consent Management Platform)
As soon as the homepage of the MIELLS website is displayed, this consent request is presented through the appearance of a banner notifying the options for granting or refusing consent.
The banner clearly and equivalently displays the following options:
- Accept all
- Refuse
These options are presented in the same manner in order to ensure that consent is freely given.
Your full information is ensured through links directing you to the “Privacy Policy”, the “Legal Notice” and “Cookie Settings”.
The “Cookie Settings” link specifies the type of cookies and their functionality. It also allows you to personalise your consent through a drop down menu listing the different cookies.
You may modify your preferences at any time by clicking on the “Cookie Settings” link located in the footer of the website.
10.2. Cookies used by the Website
The cookies used by the Agency on its website are intended to establish statistics and traffic volumes relating to the use of the various elements of the website (audience measurement cookies).
| Nom du cookies | Finalités | Durée de vie |
| Doubleclick Ad | Advertising, analysis, optimisation | Until the objective pursued by the processing is achieved |
| Google Ads | Advertising, analysis, service provision, statistics | Until the objective pursued by the processing is achieved Anonymised log data, 9 months after consent Anonymised cookie data, 18 months after consent |
| Google Analytics | Marketing, analysis | Until the objective pursued by the processing is achieved |
| Hubspot | Marketing, statistics, analysis, optimisation | Until the objective pursued by the processing is achieved |
| Google Tag Manager | Tag management, marketing, analysis | Until the objective pursued by the processing is achieved |
| Usercentrics consent Management Platform | Consent Management Platform, compliance with legal obligations, storage of consent | 1 year |
10.3. Cookie Settings with the Consent Manager
We respect your privacy. When you browse the Agency’s website, cookies are placed on your browser to measure the site’s audience and carry out personalized advertising targeting operations. Your choices regarding cookies are saved for 12 months.
To modify your preferences subsequently, click on the “Configure cookies” link located in the page footer.
“Continue without accepting” “Configure cookies” “Accept all”
10.4. Settings for Your Browser Software
You can configure your browser software so that cookies are saved on your device or, conversely, that they are rejected, either systematically or according to their issuer.
Cookie configuration differs depending on the browser used:
- For Edge™: https://support.microsoft.com/en-gb/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d
- For Firefox™: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
- For Opera™: https://help.opera.com/en/latest/web-preferences/#cookies
- For Safari™: https://support.apple.com/en-euro/105082
- For Chrome™: https://support.google.com/chrome/answer/95647?hl=en&sjid=10176154467335366257-EU
10.5. Opt-Out List for Managing Cookie Placement
You also have the option to object to the placement of cookies by accessing the website: https://www.youronlinechoices.com/uk/your-ad-choices/
10.6. Third-Party Editor Links
The Agency uses Google Analytics audience measurement cookies which can be configured at the following address: https://tools.google.com/dlpage/gaoptout?hl=en
11. Conditions for Modification of the Privacy Policy
The Agency reserves the right to modify this Policy at any time to ensure its compliance with current law for its clients and prospects.
Clients and prospects are invited to review this Policy each time they use the Agency’s services, without the need for formal notification.
Any modification will be published on this page, with an update date. In the event of any dispute regarding the interpretation of the content of the Privacy Policy, only the French version shall prevail. This policy was last updated on March 3, 2026.
