DATA PROTECTION POLICY

1. FIELD OF APPLICATION OF THE PERSONAL DATA PROTECTION POLICY

The present personal data protection policy applies to all personal Data Processing, put in operation by the Person Responsible for data processing via Internet Sites.

The objective of the present personal Data protection policy is to inform you regarding the commitments made by the Person Responsible for its processing, so as to ensure the respect of your personal Data.

Définitions :

Personal Data (or ‘Data’): all information referring to a physical person identified or identifiable, directly or indirectly, notably by reference to a user identification (identifiant).

Personal Data Processing: any operation or any set of operations whether carried out or not with the aid of automated procedures and applied to Data or sets of personal Data.

Internet Sites : www.aryes-vini.com

Person Responsible for processing: Those responsible for processing data are the companies FILEUROPE, CMP and FARAME

2. DATA COLLECTED

In general, you can visit Internet Sites without it being necessary to communicate Data.

However, so as to be able to provide you with certain services, the Person Responsible for Data Processing may ask you to supply certain Data, for example, to respond to a request for contact or to follow up on a job application file.

May notably be collected all or part of the following Data when you use Internet Sites :

  • Data relating to your identity (name, first name, e-mail address, telephone number)
  • Data relating to your personal life and your professional life that you choose to communicate to us, notably in the context of job applications.
  • In all cases, we limit ourselves to collecting and processing Data that is pertinent, adequate, not excessive and strictly necessary to accomplish the end results that will have been determined beforehand.
  • We may also use cookies that correspond to small text files of letters or numbers downloaded to your computer terminal when you access Internet Sites (see paragraph relating to cookies).

3. PURPOSES OF DATA PROCESSING CARRIED OUT BY FILEUROPE, CMP AND FARAME AND THE LEGAL BASIS FOR THIS PROCESSING

The Person Responsible for Data Processing commits to collecting and processing your personal Data in a faithful, lawful and transparent manner.

In accordance with the purposes listed hereafter, the usage of your Data by the Person Responsible for processing is authorised by legal and statutory requirements as it is :

  • Necessary for the respect of our legal and statutory obligations with regard to public institutions or competent authorities (Art.6, 1, c) of the Règlement général sur la protection des données or General Rules for Data Protection, hereafter referred to as the RGPD) or,
  • Necessary for the conclusion or fulfilment of a contract (Art.6, 1, b) of the RGPD) or,
  • In certain cases, necessary for our legitimate interests in pursuing the aims described hereunder (Art.6, 1, a) of the RGPD) or,
  • In certain circumstances, carried out with your consent (Art.6, 1, a) of the RGPD in relation to art.7 of the RGPD).

The processes carried out by the Person Responsible for processing correspond to explicit, legitimate and pre-determined aims.

Your Data may notably be used for the following purposes:

  • Follow up on your job application file lodged on line on Internet Sites;
  • Response to your requests for contact or sending of commercial documentation.
  • The purpose of this collection will be precisely indicated to you at the moment of said collection.

4. THE LENGTH OF DATA CONSERVATION

The length of time of conservation of your Data depends on the processing aims for which they are used.

Processing and follow up of job applications :
We commit to cancelling your Data within a maximum period of 2 years after our last contact with you.

Communication, management of your requests for contact :
We commit to cancelling your Data within a maximum period of 3 years after our last contact with you.

Beyond this period, Data may be rendered anonymous and kept exclusively for statistical purposes and will give rise to no usage or expression whatsoever, of whatever nature that may be.

5. THE CATEGORIES OF RECIPIENTS FOR DATA COLLECTED

The Person Responsible for Data processing will only communicate your personal Data to authorized and pre-determined recipients.

No transfer involving a third party for commercial usage will be made without your previous consent.

The recipients of your data are the services linked to the Person Responsible for Data Processing, as well as, as the case may be, authorized personnel :

  • Of our subsidiaries, for reasons of internal administration or employment;
  • Of our suppliers or service providers and notably their technical service providers, to supply you with the service or information you have requested (mail shot, data storage…). By virtue of their contract, these service providers are not authorized to use or divulge this information, except insofar as necessary to supply the services or to conform to legal requirements;
  • Of a legal or administrative authority when the Person Responsible for Data Processing is so required by Law.

By application of the pertinent regulation, any sub-contractor who might process personal Data on behalf of the Person Responsible for Data Processing commits in particular :

  • To process Data only for the specific purpose(s) subject of this sub-contracting,
  • To process Data in accordance with the instructions of the Person Responsible for Data Processing,
  • To guarantee the confidentiality and security of Data.

6. TRANSFERS OF DATA

In the case of your Data being transferred outside the European Union, we ensure that :

  • Data is transferred to countries recognized as offering an equivalent level of protection.
  • Data is transferred to entities certified in relation to the Privacy Shield.

For Data transferred outside the countries recognized by the CNIL (French Commission for Data Protection Legislation) as having a sufficient level of protection, recourse is had to one of the mechanisms ensuring appropriate guarantees such as foreseen by applicable regulations, and in particular the adoption of standard contractual clauses.

7. COOKIES

Please find our policy regarding cookies in the legal notices.

8. YOUR RIGHTS REGARDING DATA COLLECTED BY US

8.1. Your rights

You have available to you the following set of rights regarding the Data we collect :

Right of access to your Data: You have the right to obtain confirmation that your Data has or has not been processed, and when it has been, the right to have access to said Data. This right also includes that of obtaining a copy of the Data subject to processing/usage (Art.15 RGPD).

Right to request rectification of your Data if in error: You have the right to request that your Data be rectified, updated or completed when found to be inexact, erroneous, incomplete or obsolete (Art.16 RGPD).

Right to request erasure of your Data: According to article 17 of the RGPD, you have the right to request erasure of your Data only for the motives foreseen by the applicable regulation and in particular when :

  • Data is no longer necessary with regard to the purposes for which it was collected or processed in another manner;
  • You withdraw the consent on which processing is based, and there exists no other legal foundation for this processing;
  • You oppose the processing and there exists no legitimate imperative motive for this processing;
  • You consider that your Data is subject to unlawful usage;
  • Your Data must be erased in order to respect a legal obligation.

Right to limit Data processing concerning you: According to article 18 of the RGPD, you have the right to obtain from the Person Responsible for processing the limiting of use of your Data only for the motives foreseen by the applicable regulation and in particular when :

  • You contest the exactitude of Data concerning you;
  • You consider that the processing is unlawful and you oppose the erasure of your Data;
  • The Data is still necessary to you for the statement, exercise or the defence of legal rights although FILEUROPE, CMP, FARAME no longer have need of them.

Right for you to oppose processing by withdrawing your consent (it being recalled that this withdrawal will not affect or prejudice the lawfulness of processing based on the consent arrived at before such withdrawal) (Art.7, 3 RGPD).

Right to benefit from the portability of your Data: you have the right to recover the Data supplied by you to FILEUROPE, CMP, FARAME, in a structured, currently used and machine-readable format, and the right to transmit this Data to another person responsible for data processing (Art.20 RGPD).

Right to register a claim with the CNIL: If you consider that the Person Responsible for processing does not respect the obligations regarding your personal Data, you can at any moment address a complaint or a request to the competent authority. In France, the competent authority is the CNIL, to which you can address a request electronically by clicking on this link: https://www.cnil.fr/fr/plaintes/internet.

8.2. Arrangements for Exercise of Rights

You can exercise the previously mentioned rights by written, detailed request to the following address: FILEUROPE, ZI N°4, 88 700 Rambervilliers

By reason of the obligation for security and confidentiality in the processing of Data incumbent upon the Person Responsible for processing, you are informed that your request will be dealt with under reserve that you provide proof of your identity, notably by the production of a scan of your valid document of identity or a signed photocopy of your valid document of identity.

The Person Responsible for processing will determine within a period of one month from receipt of the formulated request if the latter is receivable or not. In the case of said request being receivable, FILEUROPE, CMP, FARAME will provide the information sought or will set in operation the rights invoked within the afore-mentioned period.

If, taking into account the complexity of the request or the number of requests received, the afore-mentioned period cannot be respected, the Person Responsible for processing will inform you before the expiry of that period of the postponement of the decision for a maximum of two months.

The Person Responsible for processing informs you of his or her right, if the case may be, to oppose manifestly abusive requests (as a function of their number, repetitive or systematic nature).

In the case of the Person Responsible for processing not providing a follow-up to your request, we will inform you within the afore-mentioned periods of the motives for our decision in reminding you of your possibility to make a claim via the CNIL.

9. SECURITY OF PERSONAL DATA

We put in operation all necessary security measures so as to prevent in all ways possible any alteration or loss of your Data or any unauthorised access thereto.

In the event of us becoming aware of illegal access to Data concerning you, we commit to notifying you of the incident as soon as possible if this corresponds to a legal requirement.

10. UPDATING OF THE PRESENT POLICY

The present policy may be updated at any moment, notably by the application of legal and/or statutory requirements and/or possible recommendations made by the CNIL. As of now, we invite you to regularly consult this page.

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