CMLS — Cairoli Monaco Luxury Services CMLS Monaco · International

PRIVACY POLICY

Last updated: October 2026

CMLS – Cairoli Monaco Luxury Services ("CMLS", "we", "us", "our") attaches great importance to the protection of privacy and personal data.

This Privacy Policy explains how CMLS collects, uses, stores and protects personal data relating to individuals who visit our website, contact us, request information about our services or enter into a professional relationship with us.

CMLS operates from the Principality of Monaco and processes personal data in accordance with applicable Monegasque legislation, in particular Law No. 1.565 of 3 December 2024 on the protection of personal data.

1. Data Controller

The data controller is:

CMLS – Cairoli Monaco Luxury Services
Legal form: Activité en nom propre
Monaco RCI: 14P08194
Managing Director: Cairoli Tricia
1, Rue du Tenao
98000 Monaco
Principality of Monaco

Email: info@cmls.mc

Telephone: +377 99 92 42 19

Mobile: +33 6 40 61 27 41

CMLS operates by appointment.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed by CMLS through:

  • the CMLS website;
  • contact forms available on the website;
  • email and telephone communications;
  • requests for information concerning our services;
  • professional relationships with clients, prospective clients, advisers and other contacts;
  • coordination with professionals and specialists involved in a client's affairs.

3. Personal Data We May Collect

Depending on the nature of the relationship with CMLS, we may collect the following categories of personal data:

  • first and last name;
  • email address;
  • telephone number;
  • address and residence or domicile information;
  • professional information;
  • personal, professional, financial or administrative information voluntarily provided by the individual;
  • information contained in correspondence and messages;
  • documents and information provided in connection with a professional relationship;
  • information relating to communications and the management of the relationship with CMLS;
  • technical information relating to use of the website, such as IP address, browser, device and access data, where applicable.

CMLS applies the principle of data minimisation and collects only data that is relevant and necessary for the purposes for which it is processed.

4. Special Categories of Personal Data

Due to the nature of the services provided, CMLS may, in certain circumstances, receive information falling within special categories of personal data.

Such information should not be submitted through the website or contact form unless this is necessary and appropriate for the individual's request or for the performance of a professional relationship.

Where the processing of such data is necessary, CMLS will apply the conditions and safeguards required by applicable law.

5. How We Collect Personal Data

Personal data may be collected:

  • directly from the individual through the website;
  • through the contact form;
  • by email;
  • by telephone;
  • during meetings or professional communications;
  • through documents voluntarily provided by the individual;
  • through advisers or professionals involved in the management of a matter, where such disclosure is necessary and lawful.

6. Purposes of Processing

CMLS may process personal data for the following purposes:

6.1 Managing enquiries

To receive, review and respond to enquiries submitted through the website, email, telephone or other communication channels.

6.2 Preliminary assessment

To understand the nature of an individual's requirements and assess whether CMLS services may be appropriate.

6.3 Managing professional relationships

To establish, manage and perform a professional relationship with a client.

6.4 Professional coordination

Where necessary, to coordinate activities with lawyers, accountants, tax advisers, trustees, fiduciaries, banks, family offices and other specialist professionals.

6.5 Communication

To maintain effective communication with clients and other professionals involved in a matter.

6.6 Legal and regulatory compliance

To comply with legal and regulatory obligations and with legitimate requests from competent authorities.

6.7 Security

To maintain the security, integrity and proper functioning of the website and the systems used by CMLS.

7. Legal Basis for Processing

Depending on the specific purpose, the processing of personal data may be based on:

  • the individual's consent;
  • the taking of pre-contractual steps at the individual's request;
  • the performance of a contract or professional relationship;
  • compliance with a legal obligation;
  • the legitimate interests pursued by CMLS, where such interests do not override the rights and freedoms of the individual.

Where processing is based on consent, consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before the withdrawal.

8. Disclosure of Personal Data to Third Parties

CMLS may disclose personal data, to the extent necessary, to parties involved in the management of a client's affairs, including:

  • lawyers;
  • accountants;
  • tax advisers;
  • notaries;
  • trustees and fiduciaries;
  • banks and financial institutions;
  • family offices;
  • specialist professionals;
  • competent public authorities and institutions;
  • technical, IT and administrative service providers.

Personal data will only be disclosed where necessary for a legitimate purpose and in accordance with applicable confidentiality obligations.

CMLS does not sell or commercially exploit personal data belonging to its clients or website users.

9. International Data Transfers

Given the international nature of CMLS's activities and its relationships with clients and professionals located in different jurisdictions, certain processing activities may involve the transfer of personal data outside the Principality of Monaco.

Such transfers will be carried out in accordance with applicable Monegasque legislation.

Where the recipient country benefits from an adequate level of protection, the transfer may be carried out in accordance with the conditions established by law. Where adequate protection is not available, CMLS will, where required, implement appropriate safeguards or rely on the derogations provided by applicable law.

10. Data Retention

CMLS retains personal data for as long as necessary to fulfil the purposes for which it was collected.

The applicable retention period may depend on:

  • the nature of the enquiry;
  • the duration of the professional relationship;
  • applicable legal and regulatory obligations;
  • the need to document activities performed;
  • the need to protect CMLS's legal rights and legitimate interests.

Once the applicable retention period has expired, data will be deleted, destroyed or anonymised unless continued retention is required or permitted by law.

11. Data Security

CMLS implements appropriate technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • loss;
  • destruction;
  • alteration;
  • unlawful disclosure;
  • unauthorised processing.

Security measures are proportionate to the nature of the data, the purposes of processing and the risks involved.

12. Confidentiality

CMLS places particular importance on the confidentiality of information received from its clients and contacts.

Information is made accessible only to persons who need it in connection with their respective professional functions and responsibilities.

Where CMLS coordinates several professionals on behalf of a client, information will only be shared to the extent necessary to perform the relevant activities and in accordance with applicable confidentiality obligations.

13. Data Subject Rights

Under Law No. 1.565 of 3 December 2024, individuals have, subject to the conditions and limitations provided by applicable law, the following rights:

  • the right to be informed;
  • the right of access to their personal data;
  • the right to rectification of inaccurate or incomplete data;
  • the right to erasure of personal data;
  • the right to restriction of processing;
  • the right to object to processing;
  • the right to data portability, where applicable;
  • the right not to be subject to certain decisions based solely on automated processing which produce legal effects or significantly affect the individual, as provided by law.

14. Exercising Your Rights

To exercise your rights or obtain information regarding the processing of your personal data, you may contact CMLS:

CMLS – Cairoli Monaco Luxury Services
1, Rue du Tenao
98000 Monaco
Principality of Monaco

Email: info@cmls.mc

Your request should contain sufficient information to enable CMLS to identify you and understand the nature of your request.

CMLS may request additional information where this is necessary to verify the identity of the person making the request.

15. Complaints

You may contact CMLS with any question or concern regarding the processing of your personal data.

If you believe that the processing of your personal data infringes applicable legislation, you may also lodge a complaint with the competent Monegasque data protection authority:

Autorité de Protection des Données Personnelles (APDP)
Le Concorde – 4th Floor
11, rue du Gabian
98000 Monaco
Principality of Monaco

Tel.: +377 97 70 22 44
Email: apdp@apdp.mc

16. Contact Form

When you use the contact form on the website, CMLS may collect the information entered into the form, including:

  • name;
  • email address;
  • telephone number;
  • content of the message;
  • any other information voluntarily provided by the user.

This information is used to process and respond to the enquiry.

17. Cookies and Similar Technologies

The website may use cookies and similar technologies that are necessary for its operation, security and, where applicable, the analysis of website usage.

Any non-essential cookies, analytics, advertising or tracking technologies will be used in accordance with applicable law and, where required, with the user's prior consent.

The actual configuration of cookies depends on the technical tools installed on the website. CMLS may therefore publish or update a separate Cookie Policy.

18. Children

CMLS's services are not specifically directed at children.

CMLS does not knowingly collect personal data from children through the website for purposes other than those permitted by applicable law.

19. Changes to this Privacy Policy

CMLS may update this Privacy Policy from time to time to reflect changes in legislation, regulation, technology or the way in which the business operates.

The updated version will be published on the website together with the date of the latest update.

20. Contact

For any questions concerning this Privacy Policy or the processing of personal data, please contact:

CMLS – Cairoli Monaco Luxury Services
Activité en nom propre
Monaco RCI: 14P08194
Managing Director: Cairoli Tricia
1, Rue du Tenao
98000 Monaco
Principality of Monaco

info@cmls.mc
+377 99 92 42 19
+33 6 40 61 27 41