Privacy policy

Updated October 2018

1. Preamble

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regards to processing of personal data and on the free movement of such data, otherwise known as General Data Protection Regulation (hereafter GDPR) lays down the legal framework applying to personal data processing.

The GDPR strengthens the rights and obligations of data controllers, subcontractors, data subjects and recipients of data.

In the context of our business activities, we need to process personal data.

To facilitate the understand of this policy, please be advised that:

According to Article 12 of the GDPR, data subjects must be informed of their rights in a concise, transparent, readily intelligible and easily accessible form.

2. Purpose

The purpose of this policy is to comply with the obligation to provide information of Europa Group in application of the GDPR (Article 12) and to formalise Europa Group's clients and prospects' rights and obligations with regards to the processing of their personal data.

3. Scope

This policy is intended to apply in the context of the implementation of the processing of clients and/or prospects' personal data.

Europa Group makes every effort to process data within the framework of a structured internal governance. Having made this clear, this policy relates only to the processing for which Europa Group is accountable and therefore does not relate to the processing not created or exploited outside of governance rules established by Europa Group (so-called “shadow IT”).

Personal data processing may be managed directly by Europa Group or through a subcontractor specifically designed by Europa Group.

This policy exists independently from any other document that may apply as part of the contractual relationship between Europa Group and its clients and prospects.

4. General principles & data collection

No processing is undertaken by Europa Group with regards to clients and prospects' data if it does not pertain to personal data collected by or for our services or processed in relation to our services and if it does not meet RGDP general principles.

Use cases of Europa Group are as follows:

This list is intended to be as exhaustive as possible, any new instances of use and any modification or deletion of an existing data handling process will be brought to the attention of clients and prospects through a change in this policy.

5. Legal basis

Legal basis
Example
Execution of a contract via the general terms and conditions of sale
Registration for an event, order form, etc.
Legitimate interest
The video protection camera images are kept for a maximum of one month, etc.
Consent
Newsletter, cookie management, contact request, satisfaction survey, communication of offers and news, etc.

 

6. Types of collected data

Non-technical data (according to instance of use):

Technical data (according to instance of use):

7. Data sources

Our clients or prospects' data are generally collected directly from them (direct collection).

Collection can also take place indirectly:

Europa Group will ensure that third parties, organisations or companies are in compliance with the GDPR and that the persons concerned are informed of our policy of personal data management.

Cookies

8. Data recipients - Authorization & traceability

Europa Group ensures that the data is accessible only to authorized internal or external recipients.

Internal recipients

Recipients from clients and prospects' personal data at Europa Group are bound by a duty of confidentiality.

Europa Group authorises recipients to access specific data based on an authorisation policy.

External recipients

Recipients from clients and prospects' personal data at Europa Group are bound by a duty of confidentiality.

Europa Group cannot assume any liability for any damage resulting from unlawful access to personal data.

Any access related to clients and prospects' personal data processing can be traced.

Furthermore, personal data may be shared with any lawfully entitled authority. In such a case, Europa Group cannot be held responsible for the conditions under which the personnel of such authorities accesses and processes these data.

9. Retention period

The data retention period is set by Europa Group with regards to legal and contractual restrictions by which it is bound, and by default according to its needs and notably according to the following principles:

Processing
Retention period
Client data
For the duration of contractual relations with Europa Group, increased by 3 years for management and prospection purposes, without prejudice to retention obligations or the limitation period
Member and website user data
Until unsubscribing from the member area and 1 year after the last intervention
Prospect data
3 years from collection by Europa Group or from the last contact initiated by the prospect
Technical data
1 year
Cookies
13 months
Banking data
Deleted as soon as the transaction is successfully completed, unless client gives explicit consent In case of transaction dispute, retention for 13 months as archive according to debit card
Anti-money laundering
5 years

 

Past the set time limits, data are either deleted or retained after being made anonymous, notably for statistical use. They can be kept in case of pre-litigation and litigation.

Clients and prospects are reminded that data deletion and anonymization are irreversible and that Europa Group will be unable to recover them thereafter.

10. Right to request confirmation and access rights

Clients and prospects have the right to request confirmation from Europa Group whether data pertaining to them are being processed.

Clients and prospects also have the right to access their data. This right is conditional on compliance with the following rules:

Clients and prospects have the right to request a copy of their personal data being processed by Europa Group. However, in case an additional copy is being requested, Europa Group may charge the cost of producing these copies to the clients and prospects who request them.

If clients and prospects request their copy of their data electronically, the requested information will be provided electronically in a commonly used form, unless otherwise requested.

Clients and prospects are hereby informed that this access right cannot apply to confidential information or data, or those which cannot be disclosed by law.

The access right must not be exercised in an abusive way, meaning in a regular manner with the express purpose of disrupting the applicable department.

11. Update - Actualization and modification

Europa Group complies with updating requests:

12. Right to erasure

Clients and prospects' right to erasure will not apply in case data is processed to comply with a legal obligation.

Outside of this situation, clients and prospects have the right to request the erasure of their data in the following limiting situations:

In accordance with personal data protection legislation, clients and prospects are hereby informed that this individual right can be exercised exclusively by the person concerned with respect to their own information: for security reasons, the applicable department will therefore verify your identity to avoid communicating any of your confidential information to someone other than you.

13. Right to limitation

Clients and prospects are hereby informed that this right is not intended to apply to the extent that Europa Group is processing data in a lawful manner and that all personal data collected are required to carry out the commercial contract.

14. Right to portability

Europa Group gives the right to data portability in the specific case where data shared by clients or prospects themselves, on online services offered by Europa Group itself and based on the individual’s express consent. In that case the data will be shared in a commonly used, machine-readable structured format.

15. Automated individual decision

Europa Group does not make automated individual decisions.

16. Post mortem right

Clients and prospects are hereby informed that they have the right to give guidelines regarding the post-mortem storage, erasure and sharing of their data. Sharing specific guidelines post-mortem and exercising their rights is to be done by e-mail at the following email address: data.officer@europa-group.com or by postal mail at the following address: Europa Group – Data Management - 19 allées Jean Jaurès 31000 Toulouse, FRANCE. The request shall be accompanied by a copy of a signed proof of identity.

17. Voluntary or compulsory nature of answers

Clients and prospects are informed on each personal data collection form of the voluntary or compulsory nature of their answers by an asterisk.

If answers are compulsory, Europa Group explains to clients and prospects the consequences of a lack of answer.

18. Usage right

Clients and prospects grant Europa Group a right to use and process their personal data for the above-outlined purposes.

However, all enhanced data resulting from processing and analysis from Europa Group, otherwise named enhanced data remain the exclusive property of Europa Group (usage analyses, statistics, etc.).

19. Subcontracting

Europa Group hereby informs its clients and prospects that it may mandate any subcontractor of its choice in the context of processing their personal data.

In such a case, Europa Group will ensure that the subcontractor fulfills their obligations with respect to the GDPR.

Europa Group commits to signing a written contract with all of its subcontractors and imposes the same personal data protection obligations to its subcontractors than it imposes on itself. Furthermore, Europa Group reserves the right to carry out an audit of its subcontractors to ensure their full compliance with GDPR provisions.

20. Security

It is up to Europa Group to define and implement technical security measures, physical or logical, that it deems appropriate to prevent data destruction, loss, alteration or unauthorized disclosure of data in an accidental or unlawful manner.

These measures mainly include:

21. Data breach

In case of personal data breach, Europa Group undertakes to notify the CNIL under the conditions outlined by the GDPR.

If said breach exposes clients and prospects to serious risk and that data was not protected, Europa Group:

22. Processing register

Europa Group, as data controller, commits to maintaining an up-to-date register of all data processing activities.

This register is a document or application enabling the identification of the overall processing undertaken by Europa Group, as processing controller.

Europa Group commits to providing the supervisory authority on first request the information permitting that authority to ensure compliance with the current existing data protection law (“Réglementation informatique et libertés”).

23. Right to file a claim with the CNIL

Clients and prospects concerned by personal data processing are hereby informed of their right to file a claim with a supervisory authority, namely the CNIL in France, if they believe that personal data processing pertaining to them does not comply with the GDPR, at the following address:

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

24. Evolution

This policy may be modified or adjusted at any time in case of changes in legislation, case law, in decisions or recommendations from the CNIL, or changes in custom.

Employees will be informed of any new revision to this policy through any means Europa Group deems appropriate, including electronically (for instance through e-mailing or online).

25. For more information

For any additional information, you may contact the following department: data.officer@europa-group.com

For any general information on personal data protection, you may visit the CNIL website: www.cnil.fr