1) PREAMBLE

Groupe Sclavo places the protection and respect of privacy among its highest priorities. The Group is committed to complying with all obligations applicable to data protection and respect for the rights and freedoms of individuals (in particular the “European Data Protection Regulation” or “RGPD”), the opinions and recommendations of the CNIL as well as the European Data Protection Committee.

2) ROLE

For a better understanding of the present policy, it is specified that :

  • The “data controller”: Groupe Sclavo.
  • The “processor”: refers to any natural or legal person who processes personal data on behalf of Groupe Sclavo.
  • Data subjects”: refers to customers and/or prospective customers of services offered by the Group on its own behalf or on behalf of third parties or employees working for Groupe Sclavo.
  • Recipients”: refers to the natural or legal persons who receive personal data from Groupe Sclavo.
  • Data recipients may be Le Groupe employees or external bodies (third-party event organizers, partners, exhibitors, banks, authorities, etc.).

3) PURPOSE

The purpose of this policy is to satisfy the obligation of information and to formalize the rights and obligations of Groupe Sclavo towards its customers and prospects with regard to the processing of their personal data for all the services of the www.groupesclavo.fr website.

4) SCOPE

This policy applies to all processing of personal data relating to customers and/or prospects carried out on the www.groupesclavo.fr website.

5) WHY DO WE PROCESS YOUR DATA?

Each processing operation is implemented within the framework of the present protection policy and in compliance with the various regulations that apply to the Sclavo Group. No processing of personal data of customers and prospects is implemented if it does not comply with the general principles of the RGPD.

 

The purposes are as follows:

  • Collect people’s contact details via a contact form;
  • Communicate information about our products and services;
  • Managing the commercial relationship ;
  • Prospecting and business development;
  • Manage registration and participation in an event or study;
  • Drawing up statistics ;
  • Rights and claims management ;
  • Manage unsubscribe and unsubscribe requests.
  • Application management

6) THE LEGAL BASIS FOR PROCESSING YOUR DATA

The legal basis for the processing of personal data is as follows:

  • Legitimate interest: processing is necessary to pursue the legitimate interests of the organization processing the data or of a third party, in strict compliance with the rights and interests of the persons whose data is processed; this applies in particular to commercial prospecting.
  • Consent: This is linked to the prior authorization obtained from individuals in order to carry out studies.

7) TYPES OF DATA COLLECTED

The Personal Data collected or held is that which is strictly necessary for the activities of the Sclavo Group.

In this context, the Group collects the following categories of data.

  • Identification data such as first name(s), last name(s), date and place of birth…
  • Data enabling the person to be contacted through various media, such as postal address, e-mail address, telephone number(s).

8) DATA COLLECTED THROUGH COOKIES AND TRACERS

We use tracking technologies, in particular cookies, to collect information about your browsing on our site. We invite you to consult the Cookies section for detailed information on the use of cookies and the options available to you.

The use of cookies for commercial purposes is also defined in the cookie management policy on our website.

9) DATA ORIGINS

Data relating to our customers or prospects is collected either directly from them or via the contact form.

10) DATA RECIPIENTS – AUTHORIZATION & TRACEABILITY

Data collected by the Group may be shared in whole or in part depending on the purpose.

 

A) INTERNAL RECIPIENTS

  • Empowered staff in marketing, sales, customer relations and prospecting, administrative, logistics and IT departments, as well as their line managers.
  • Authorized personnel from departments responsible for internal control procedures.
  • Recipients of customer and prospect personal data within the Group are bound by an obligation of confidentiality.
  • The Sclavo Group decides which recipients will have access to which data, based on an authorization policy.

 

B) EXTERNAL RECIPIENTS

  • Legal entities that have signed a contract with Groupe Sclavo (subcontractor).
  • Service providers and subcontractors performing services on our behalf and for whom the compliance of commitments with the RGPD has been verified.
  • Duly authorized judicial and/or administrative authorities and regulated professions (e.g. notaries, lawyers, bailiffs).

 

All accesses concerning processing of personal data relating to customers and prospects are subject to traceability measures.

In addition, personal data may be communicated to any authority legally empowered to have access to it. In this case, the Group is not responsible for the conditions under which the staff of these authorities have access to and use the data.

11) SHELF LIFE

The data retention period is defined by the Group in the light of its legal and contractual obligations and, failing that, according to its needs and in particular according to the following principles:

  • Customer data : For the duration of the contractual relationship and, in particular, of the event organized by Le Groupe, plus 3 years for promotional and prospecting purposes, without prejudice to retention obligations or limitation periods.
  • Data relating to members and users of the website: Until unsubscribed from the member area and 1 year after the last intervention.
  • Data relating to prospects: 3 years from the date of collection by Le Groupe or the last contact from the prospect.

 

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. In the event of pre-litigation or litigation, data may be kept for the duration of the dispute, plus the legal time limits for contesting the claim.

12) STORAGE

Personal data is stored in our databases or in the databases of our subcontractors.

13) DATA SECURITY

Groupe Sclavo is responsible for defining and implementing the physical or logical technical security measures it deems appropriate to protect against the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of data. The Group requires the same measures from its business partners and subcontractors.

In this respect, Groupe Sclavo takes all necessary precautions, with regard to the nature of the data and the risks presented by the processing, in order to preserve the security of the data and, in particular, by applying physical protection measures to the premises, authentication procedures with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data…

14) TRANSFER OUTSIDE THE EUROPEAN UNION

You are informed that your personal data will not be transferred to countries outside the European Union.

15) COMMERCIAL SOLICITATION

If you give your consent during registration Groupe Sclavo may send you newsletters and other promotional messages by email, post and SMS. These newsletters will keep you informed of Groupe Sclavo news, products and services.

16) PERSONAL RIGHTS

Customers and prospects have the right to request confirmation from Groupe Sclavo as to whether or not data concerning them is being processed. In particular, everyone has the right to be informed, in a comprehensible and easily accessible manner, about the processing of their data.

In accordance with the applicable regulations, you have various rights which you may exercise at any time:

You have a right of access, a right of rectification, a right to the deletion of the data concerning you, as well as the right to request the portability of the data you have provided to us.

You have the right to object, on legitimate grounds, to the processing of your data, or to request the restriction of such processing.

You also have the right to object at any time and without cause to the processing of your data for direct marketing purposes, as well as to profiling when carried out for the same purpose.

You have the right to stipulate what happens to your personal data after your death.

17) EXERCISE YOUR RIGHTS

These rights may be exercised exclusively by e-mail to the following address: communication@groupesclavo.fr or by post to :

Groupe Sclavo, 3, rue du Docteur Pierre Richelmi, 06300 Nice – FRANCE

As required by law, we must be able to verify the identity of the person asserting his or her rights. It is therefore necessary to send us a copy of your identity document or any other element that can provide certain proof of your identity.

We wish to point out that the exercise of some of these rights may, on a case-by-case basis, make it impossible for the data controller to provide the service in the cases strictly provided for by the regulations in force.

Your request will be answered within one month of receipt of your complete request. We reserve the right to refuse requests that are manifestly unfounded or excessive.

18) DATA BREACH

In the event of a personal data breach, Le Groupe undertakes to notify the CNIL in accordance with the conditions prescribed by the RGPD.

If the said breach poses a high risk to customers and prospects and the data has not been protected, Le Groupe.

  • We will notify the customers and prospects concerned;
  • Communicate the necessary information and recommendations to customers and prospects.

19) RIGHT TO LODGE A COMPLAINT WITH CNIL

Customers and prospects concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely the CNIL in France, if it considers that the processing of personal data concerning them does not comply with European data protection regulations, at the following address:

CNIL – Service des plaintes
3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Tél : 01 53 73 22 22

20) SUBCONTRACTING

The Group informs its customers and prospects that it may involve any subcontractor of its choice in the processing of their personal data.

In this case, The Group ensures that the processor complies with its obligations under the RGPD.

The Group undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does itself. In addition, Le Groupe reserves the right to audit its subcontractors to ensure compliance with the provisions of the RGPD.

21) EVOLUTION

Any new version of this policy will be brought to the attention of site users by any means defined by Groupe Sclavo, including electronically (for example, by e-mail or online).