The group CCI EUROLAM is particularly committed to the respect of privacy and the protection of data of a personal nature. The Data Protection Policy applies to any data processing of a personal nature, implemented by the group CCI EUROLAM, as Processing Manager, within the European Union, relating to people outside the group namely customers, prospective customers, partners, recruitment candidates, suppliers and service providers.
The purpose of this Personal Data Protection Policy is to provide the people concerned with the important information on how CCI EUROLAM processes their personal data, and on how the people concerned can exercise their rights. It also aims at meeting the requirements of the new regulations concerning the protection of personal data (Regulation No. 2016/679) which comes into effect as of 25 May 2018.
1. Who is responsible for personal data processing?
Each legal entity of the group CCI EUROLAM, within the European Union, which collects or uses your personal data for the needs of its own business, is responsible for the processing and undertakes to implement appropriate measures to ensure the protection, the confidentiality and the security of the personal data of anyone whose data is collected, in accordance with the legal requirements, namely European Regulation 2016/679 concerning the protection of personal data (“GDPR”) and the national laws applicable in the European Union.
2. For what reasons/objectives and on what legal basis is personal data processed?
The group CCI EUROLAM ensures that it collects and processes personal data which is pertinent, appropriate, not excessive and strictly necessary to meet the required objectives.
The group CCI EUROLAM processes your personal data for different reasons/objectives, for example for file management, the follow-up of customer and contact relations within the scope of its commercial activity and/or to keep you informed of current events through its newsletters, by email or by letter. According to the objective, the processing of your personal data is founded either on the execution of the contract (customer relation management and follow-up), or on the legitimate interest of CCI EUROLAM (replying to contact forms on internet sites, or the sending of information, newsletters or invitations to events ) or in compliance with a legal obligation (managing the requests of the people concerned relating to the exercise of their rights concerning their personal data).
3. What categories of personal data are processed?
The notion of “personal data” refers to any information relating to an identified or identifiable individual.
This data is necessary to process files in the scope of the commercial activity.
According to the case, CCI EUROLAM can maybe process personal data such as: surname, forenames, professional postal address, professional landline and/or mobile phone number, fax number, professional email address);
4. Cookies
The group CCI EUROLAM’s internet site does not use any “cookies”.
5. Who can the personal data be transferred to?
The group CCI EUROLAM only communicates your personal data to authorized, specific recipients, in accordance with the provisions of the applicable regulations.
The group CCI EUROLAM can namely give access to your personal data to the companies in its group as well as to any of its possible third party service providers, acting as sub-contractors, to perform IT services (namely hosting, storage or IT maintenance services). These third party service providers, who only act on the instructions of the group CCI EUROLAM, will just have access to your personal data in order to perform the objectives under way at the time the said data was collected and they will be required to respect the same security and confidentiality obligations as the group CCI EUROLAM
In any event, the group CCI EUROLAM undertakes not to sell the personal data to third parties whose activity or objective is to acquire new prospective customers so as to send out commercial canvassing.
Nonetheless the group CCI EUROLAM might have to communicate the personal data in order to comply with a legal obligation, on the demand of an administrative or judicial body which request it or in a case of legitimate interest as for example in order to defend its rights.
6. How long is the personal data retained?
Your personal data is retained the time necessary to carry out the objectives for which it was collected and for the minimal data retention period provided for by legislation.
Your personal data will be retained and used for different lengths of time according to the aforementioned objectives. To be more specific:
The personal data needed to manage files in the scope of our commercial activity is retained and used for the whole processing period of the said files.
Without prejudice to the possibility of opposing such processing at any time, the personal data which is processed in order to send out information, announcements, wishes, newsletters as well as invitations to events organized by the group CCI EUROLAM, is retained for up to three years as from the last contact with the person.
Personal data can be filed beyond the retention period described here above in order to meet a legal retention obligation, to assert a right in Court.
7. Security
The group CCI EUROLAM implements all the technical and organisational measures needed in order to ensure the security as well as the confidentiality of the processing of your personal data.
In order to ensure the security of your personal data, namely in order to prevent it from being altered or damaged, or to prevent unauthorized third parties having access to it, the group CCI EUROLAM takes all the necessary precautions as regards the nature of the data and the risks presented by the processing (namely by the physical protection of the premises, the setting up of methods for authentication with personal, secure access thanks to confidential login names and pass words).
8. What are your rights concerning the processing of your personal data?
In accordance with the regulations, you have the right to have access to and rectify your personal data, to oppose its processing or to obtain its limitation, deletion or portability when applicable. Furthermore, you can at any time withdraw your consent for the processing based on this, or ask to no longer receive our communications concerning the information, announcements, wishes, newsletters as well as the invitations to events organized by the group CCI EUROLAM, by using the link provided for this in each email that the group CCI EUROLAM sends you. You can submit a complaint to the CNIL[1] if you consider that your rights are not being respected. For more details on your rights, please see the list here below.
According to the processing, you benefit from the following rights:
Right of opposition: you have the right to oppose the processing of your personal data at any time: as regards the sending of information, announcements, wishes, newsletters as well as invitations.
Right of access: you have the right to obtain confirmation of whether or not your personal data is processed by the group CCI EUROLAM.
Right of rectification: you have the right to obtain the rectification of inexact or incomplete information concerning you.
Right to withdraw your consent: you can, for the processing based on consent, withdraw at any time the consent you have given for processing.
Right to delete or the right to oblivion: you have the right to obtain the deletion of your personal data by the group CCI EUROLAM when one of the following grounds applies: (I) the data isn’t necessary for the objectives for which it was collected; (II) you withdraw your consent for processing and no other legal basis for processing exists; (III) you oppose the processing of your personal data and no legitimate imperative reason for the processing exists; (IV) the data is the object of illicit processing; (V) the data has to be deleted to respect a legal obligation.
Right of portability: you have the right to obtain personal data that you provided to the group CCI EUROLAM in a structured format, used frequently and legible by machine so that you can transfer it to another processing manager. This right is applicable when the processing is based on your consent or on the execution of a contract and when it is carried out thanks to automated processes.
The right to submit a complaint to the Commission Nationale de l’Informatique et des Libertés (CNIL) (The French National Commission for Information Technology and Civil Liberties).
9. How to exercise your rights concerning your personal data?
Generally speaking, in order to exercise your rights and for any other question or difficulty concerning the processing of your personal data and your rights, you can contact the group CCI EUROLAM:
By letter: CCI EUROLAM, 9 rue Marcelin Berthelot 92762 Antony Cedex France.
By email: gdpr@ccieurolam.com