Privacy policy
EUROPOLY attaches particular importance to the protection of personal data, collected and processed in compliance with applicable laws and regulations. These include, in particular, the French Data Protection Act of January 6, 1978, as amended, and European Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the ” RGPD“) (together the “RGPD Legal Framework“).
This privacy policy (the “Privacy Policy“) is designed to protect your personal information. “) presents and summarizes EUROPOLY’s commitments in terms of personal data protection, it being specified that the RGPD Legal Framework is applicable to any processing of personal data, understood as any operation on one or more pieces of information (first and last name, telephone number, email, date of birth, etc.) that directly or indirectly identify a natural person (” personal data” “data subject“).
1. Data controller
The data controller is EUROPOLY SARL, a limited liability company registered in the Lyon Trade and Companies Register under number B 423 528 124, whose registered office is located at 399 Rue de la Garennière, 69440 Mornant (“EUROPOLY“).
2. Personal data processed and means of collection
The personal data processed by EUROPOLY, via the “europoly.com” website (the “website“) and/or by any other means, are as follows:
- Identification: surname, first name, title, gender;
- Academic and professional data and/or employment information (contained in the CVs of potential candidates) ;
- Contact details: e-mail address, postal address, telephone number ;
- Any other personal data that may be transmitted spontaneously by the persons concerned, in particular in the bodies of messages via the Site’s forms and/or when making contact.
This personal data is collected by the following means:
- Cookies: when browsing the Website, cookies may be installed on the terminal of the person concerned (see the Cookies Appendix below for more information),
- Website contact form,
- When making contact and in our professional relations.
Where applicable, the compulsory or optional nature of the data to be supplied is indicated at the time of collection by an asterisk (*). The requirement to provide mandatory data (i) is of a regulatory or contractual nature or (ii) conditions the processing of the request, including the conclusion and performance of the contract where applicable. Failure to provide this data will make it impossible to process the request and/or conclude/execute the contract. By voluntarily providing data, including optional data, data subjects expressly agree to their data being processed in accordance with the purpose indicated at the time of collection and under the conditions of the Privacy Policy.
We may also collect personal data about you indirectly when you share content, comment or respond to our publications or announcements on social networks.
3. Purposes for which personal data is processed
EUROPOLY processes personal data for the following purposes:
- Communication with the people concerned to respond to their requests for information and/or quotes,
- Create a customer file and manage customer relations,
- Contract conclusion, execution, processing, management, invoicing and payment,
- Processing unsolicited applications, communicating with the candidate and, if necessary, creating a candidate file,
- Handling warranty claims,
- The provision by third parties of technical, logistical or other functions on its behalf (in particular electronic payment solutions, transport, accounting, etc.),
- Improving our offering by inviting customers to take part in surveys, studies and satisfaction surveys,
- Drawing up sales statistics,
- Commercial prospecting,
- Sending newsletters,
- Managing the exercise of rights by data subjects,
- The protection of its legitimate interests (in particular debt collection and the exercise of any legal rights),
- Fulfilment of legal and regulatory obligations (such as document retention and accounting and/or tax obligations).
Cookies: the purposes of each cookie used on the Site can be consulted on the consent management platform.
Should the data subject’s personal data be processed for different purposes, EUROPOLY undertakes to inform the data subject and, where required by the RGPD Legal Framework, to obtain his or her prior consent.
4. Legal basis for personal data processing
The processing of personal data is carried out by EUROPOLY in accordance with the regulations in force, and in particular with the RGPD Legal Framework. As such, they are founded on one or more of the following legal bases:
- The free, specific, informed and unambiguous consent of the people concerned,
- Where this is necessary for the performance of EUROPOLY’s contractual obligations towards the persons concerned or for pre-contractual measures taken at their request,
- Where necessary to comply with EUROPOLY’s legal and regulatory obligations (such as the fight against fraud),
- When this is necessary for EUROPOLY’s legitimate interests (such as carrying out satisfaction surveys in order to improve its offers),
- When this is necessary to exercise or defend a legal right of EUROPOLY (such as debt collection, civil or criminal liability action, etc.).
Cookies: for more information, please consult the Cookies Appendix.
5. Retention periods for personal data
In accordance with current regulations, and in particular the RGPD Legal Framework, the retention periods for personal data depend on the purpose pursued by the processing concerned. As a result, personal data is kept for no longer than is necessary for the purposes for which it is processed, and in any event for no longer than the legal maximum periods.
Thus :
- Contact/prospect data: for the time required to process the request, then for a maximum of three years from the date of collection or last contact at the initiative of the person concerned,
- Customer data: for the duration of the relationship, then until a deletion request is sent or after a certain period of inactivity, set at a maximum of 3 years,
- Supplier/partner data: for the duration of the business relationship, then for the duration of the applicable statute of limitations.
Lastly, it is specified that certain personal data are kept for longer periods, to ensure (i) compliance with applicable legal and regulatory obligations (such as document retention, invoicing or fraud prevention), and/or (ii) establishing, exercising or defending EUROPOLY’s legal rights during the applicable limitation period.
6. Measures applicable to the processing of personal data - Transfers outside the EU
All necessary measures are put in place to guarantee the confidentiality, integrity and security of personal data, including with regard to subcontractors, in view of the risks involved, in order to prevent personal data from being distorted, damaged or accessed by unauthorized third parties.
Personal data is stored in the European Union. However, when personal data is transferred to certain recipients, it may be transferred outside the European Union. In this case, the appropriate measures resulting from the RGPD Legal Framework are taken to ensure that the recipients concerned provide a level of security comparable to that resulting from compliance with the RGPD Legal Framework and present the guarantees required in this respect.
7. Recipients of personal data
Personal data is processed internally.
However, personal data may be passed on to external recipients, solely for the purposes mentioned above and to the extent strictly necessary to carry out the tasks entrusted to them and/or in accordance with legal and regulatory provisions.
These include the following recipients:
- Subcontractors, in particular of the following categories: carriers, accounting firms, technical service providers for the Site and information systems;
- Cookie publishers / partners (on this point, please consult the Cookies Appendix),
- Social and tax organizations.
Where applicable, personal data may be communicated to third parties authorized by legal and regulatory provisions, in the context of an express, reasoned request from the judicial authorities.
8. Rights of persons concerned
Under the RGPD Legal Framework, data subjects have the following rights: rights to.accessquestioning rectificationerasing limitation and withdrawal of consent to processing andopposition to processing for legitimate reasons and at any time in the context of commercial prospecting, as well as the rights to portability of personal data and define post-mortem directives concerning the fate of personal data.
These rights can be exercised at the following addresses:
info@europoly.com
EUROPOLY SARL
399 Rue de la Garennière
69440 Mornant
The request must contain the surname, first name, e-mail address or postal address, in order to identify the person concerned and send a reply. For security reasons and to avoid fraudulent requests, proof of identity may be requested if these elements are insufficient. In accordance with the law, except in special justified circumstances, this request will be answered within one month of receipt.
Finally, data subjects have the right to lodge a complaint with the CNIL or any other competent supervisory authority in their country of residence.
This complaint can be made to the French CNIL at the following addresses:
CNIL – 3 PLACE DE FONTENOY, TSA 80715, 75334 PARIS CEDEX 07
Cookies appendix
1. What are cookies?
The Site uses tracking technologies that perform write and/or read operations on the user’s terminal and collect data. For ease of use, the term “cookies” refers to all tracking technologies that may be used.
There are several categories of cookies, which serve different purposes:
- Technical cookies: these help to make the Site usable by activating basic functions such as page navigation. The Site cannot function properly without these cookies,
- Audience measurement cookies: these cookies help to measure the number of visitors, to understand their interaction with the Site and to improve it;
- Social network cookies: these cookies are linked to services provided by third-party sites, such as the “Like” and “Share” application buttons or multimedia content players. The social network providing such an application button is likely to identify the user thanks to this button, even if the user does not use the button when consulting the Website;
- Advertising cookies: these cookies are used to present advertisements that may correspond to the user’s centers of interest, personalizing advertising and Wesite content.
Cookies may be placed by EUROPOLY or by third parties. In the latter case, EUROPOLY has no direct control over these cookies, although the user is informed and consents are obtained before they are placed on the Website. The user is invited to refer to the privacy policies of third-party cookie publishers.
2. Rights concerning cookies
a) Consent to cookies
In accordance with the applicable provisions and recommendations of the CNIL, no cookies are deposited unless the user has given prior consent (except for strictly necessary cookies). Conformément aux dispositions applicables et aux recommandations de la CNIL, aucun cookie n’est déposé sans que l’utilisateur n’ait donné son consentement préalable (à l’exception des cookies strictement nécessaires).
The period of validity of the user’s consent to cookies is a maximum of 13 months, after which consent is requested again.
Certain cookies are considered strictly necessary for the provision of the service and are exempt from consent, in particular :
- Those retaining the choice expressed by users on the deposit of cookies;
- Those intended for authentication to a service ;
- Those used to balance the load of equipment providing a communication service;
- Certain audience measurement cookies (if they meet certain conditions).
b) Opposition to cookies
In any event, users may withdraw their consent at any time by objecting to the deposit of cookies.
