PRIVACY POLICY

1. PREAMBLE

To use the www.groupeidec.com website, the User supplies their personal data.
The use of the website and the registration and creation of the user’s account implies the complete and full acceptance of the present privacy policy by the User.
The Privacy Policy is available on each page of the website and is also included as a reference work in the General Terms and Conditions.

2. DEFINITIONS

The terms and expressions using a capital letter at the start in this Privacy Policy have the meaning defined below, whether they are used in the singular or plural:

– “Privacy Policy”: refers to the present Privacy Policy aimed at informing the User, whether they are in the trade or a consumer (or non-professional), of the commitment made by the Company, as the entity in charge of processing data, to respect the User’s Data when he is visiting this website and allowing him, if applicable, to exercise the rights conferred on him by the modified version of the French Data Protection Act.

– “User Account”: refers to the personal area of a professional created once they have registered and is accessible via the website.

– “Data”: refers to all sorts of personal data from the User that is collected and processed when they visit the website, and in particular ask to be contacted, register for the Newsletter, send in a job application or create a User Account;

– “In charge of processing”: refers to the Company which determines the final use and means of processing the data revealed through the use of the website.

– “User” refers to any person visiting the website.

3. OBJECT

The Privacy Policy aims to define the Company’s commitment as the body in charge of processing the data from the user that has been collected and processed when managing requests to be contacted, registration for the Newsletter, job applications, commercial prospection and the creation of a User Account.

4. COLLECTED DATA

As the body in charge of processing data, the Company collects and processes three types of data:

4.1 Personal data

When requesting to be contacted, when registering for the Newsletter or creating a User Account, the Company requires the applicant to supply them with personal data.

On the contact form, only the fields marked with an asterisk (*) are compulsory in order to allow the Company to contact the User, to send them the Newsletter or to create a User Account.

If these fields are not filled in, the request from the User may not be dealt with.

The answers from the User in the fields not marked by an asterisk (*) are optional.

4.2 Professional data

To make a request to be contacted, to send in a job application and create a User Account, the Company requires personal data to be supplied.

On the job application, only the fields marked with an asterisk (*) are compulsory so that the application may be considered by the Company and if applicable be contacted by the Company.

If these fields are not filled in, the application from the User may not be dealt with.

The answers from the User in the fields not marked by an asterisk (*) are optional.

4.3 Connection data

The Company also collects the IP address and connection details and cookies, specifically examined under article 9 in the Privacy Policy when he visits the website.

The user is informed prior to using the website that their data is collected and processed and (ii) he must give his approval by ticking the box in the information and consent panel and when data is collected via the Contact Form.

5. USE OF PROCESSED DATA

When a request to be contacted is made, a job is applied for, a registration set up for the Newsletter or when a User Account is created, the User is informed that their data is collected and processed for:

· The reception, management and processing of requests to be contacted;

· Managing job applications;

· Commercial prospection;

· The establishment of customised preferences.

6. PURPOSE OF THE PROCESSING OF DATA

The data is strictly reserved for use by the Company, its staff, whether they are employed or not and the technical staff that has been appointed, while respecting the purposes defined in article 5.

The Company may communicate some of the data to its sub-contractors with the aim of processing the requests from the Users, including professional bodies that the Company appoints to sell its property programmes, and this is subject to the approval of the User when the data is collected via the contact form. The sub-contractors are obliged to respect data privacy and security, when this is supplied to them and may only use it in the framework of the mission they have been given or the services they have been asked to fulfil.

The Company guarantees that the User’s Data will not be sent to any unauthorised third party without the consent of the User.

The Company does not sell or rent out User Data to third parties.

Under particular circumstances, the Company may have to reveal the data, if requested by legal and administrative authorities.

7. DATA RETENTION

The data is kept by the Company which does not exceed the period strictly necessary for the purposes for which the data has been collected and defined above, and in any case may not be kept:

· For more than sixty (60) days after a request from the User to the Company for the data to be removed or transferred;

· More than two (2) years after the final contact with the User, who has sent in a job application to the Company;

· Longer than the commercial relations with the User for data concerning prospective clients and more than three (3) years after the data has been collected or after the final contact with the User for data concerning prospective non clients;

· Beyond the length of the contract concerning data from the Company’s Partners.

At the end of the retention period laid down in article 7, the data will be archived in a secure way for the length of time necessary and/or the obligation resulting from applicable legal or regulatory arrangements.

8. THE USER’S RIGHTS

The User has the following rights:

– Rights of access, which means he can obtain confirmation from the person in charge of processing their data that the data is or is not being processed and when it is, access to this data, and the various information including the purpose of the processing, the category of data that concerns them, who will be receiving this data etc.

– A right to rectify data concerning them as soon as possible, when the data is inexact, incomplete, out of date or not clear, or when the collection and processing has not been permitted;

– A right to oppose the processing of the data by the person in charge of processing or to transfer the data, except when there are legal or other such motives which dictate otherwise in the interests of the User.

– A right to wipe their data for the following reasons:

· The data is no longer required for the purpose for which they were collected or processed by the Company;

· The User withdraws his consent to allow the processing, when there is no other legal reason for the processing of the data;

· The User opposes the processing of the data and no superior reason can be given to justify the processing;

· The Data was processed illegally;

· The Data must be wiped in order to respect the legal obligation which the Company must respect;

· The Data was collected, when the person concerned was under age.

– a right for the User to plan ahead during his lifetime to define the conditions which apply after his death concerning the retention and use of the data the Company has collected and processed;

– A right to transfer and recover the Data allowing the User to receive the data he transferred to the Company in a structured format that is commonly used and can be read by a machine, and to transfer them to another body responsible for processing them, without the Company who initially received this data having the right to refuse or hinder this process.

If the User wishes to avail himself of one of the aforementioned rights, he should address his request:

· By e-mail to the following address: webmarketing@groupeidec.com ;

· By the postal service to the following address: Groupe Idec – Service Marketing & Communication – 37 avenue Pierre 1er de Serbie – 75008 PARIS, FRANCE;

If the User decides to exercise one of his rights by electronic mail, the Data will be supplied if applicable by e-mail from the Company if that is possible, unless the User specifically requests that this should not be the case.

9. DATA SECURITY

The Company adopts sufficient, adequate and relevant security measures to ensure data security, with in particular, means to prevent them from being changed, damaged and to prevent access by any third party:

If the Company is aware of a breach, or when data becomes vulnerable or there is a breach in security or when he is informed of such, he must inform the controlling authority of:

· the nature of the breach, the vulnerability or security breach including if possible, the categories and approximate number of people affected by the breach, the vulnerability or attack and the categories and approximate number of recorded data that has been affected;

· the probable consequences of the breach in personal data;

· the measures taken or planned by the Company to remedy the fault, the vulnerability or the security breach, including when applicable, the measures to limit any harmful effects.

· If it is not possible to supply all this information at the same time, it can be supplied in stages in a reasonable time period.

The Company will not inform the controlling authority of any faults, vulnerability or security breach that is unlikely to lead to a risk to the rights and freedoms of the User.

11. COOKIES

Cookies are small files sent to the browser and recorded on the hard disk of the computer, smartphone, touch screen tablet, etc., when the User is connected to the Website.

Cookies merely stock an identification code excluding any personal data concerning the User. Therefore, the storage of cookies during the use of the website does not allow us to identify the user personally, but it does record information concerning his surfing that the Company can read when the User visits the website again.

The length of time these cookies are stored may not exceed thirteen (13) months from their initial storage on the User’s equipment.

There are several types of cookies which can be recorded by the User’s browser:

· They can record any information concerning his visit to the website, such as in particular the pages he visited and the time when they were consulted;

· To improve the user’s experience of the website;

· To establish statistics and visitor numbers and information about the use of various elements on the website (features and content viewed, date and time of viewing…), allowing us to improve the website and make navigating the website easier;

· To recognise the User as a previous visitor, to remember their preferences which can be sent when the browser is connected to the website.

· To adapt the presentation du Site to the display specifications of the Client’s equipment (language used, display resolution, operating system, etc.) for their visits, depending on their equipment, browser software or reader.

For this reason and for cookies which are not used exclusively to make it easier to navigate around the website, an information strip will appear when the User first visits the website, in order to inform the User of the storage of cookies, (i) of their presence and their precise usage and (ii) if applicable the possibility of refusing them on your equipment and changing the settings by clicking on the link on the banner strip and (iii) by continuing to navigate around the website, they give their consent to have cookies stored on their equipment.

The User may withdraw his consent at any time by changing the preferences on their browser or with any other tools used to visit the website.

This operation will nevertheless lead to the removal of all of the cookies used by the Internet browser, including those used by other websites, and is likely to complicate surfing on the Internet.

The User may configure his browser for the cookies to be stored on his equipment or on the contrary, to refuse their storage, either systematically or depending on the publisher.

The User can also configure his browser to accept or refuse the cookies that are from time to time offered, before a cookie may be stored on his equipment.

To manage cookies and make these choices, the settings for each browser are different. They are described in the User’s browser help menu. This should enable him to know how to modify his choices in terms of the cookies.

Finally, the Company uses the services of third party partners to find out how this website is used, in order to improve the User’s experience and to offer customised advertising. These partners also use cookies that we do not control. To refuse the storage and reading of cookies and trackers, the User should enter the settings on his browser as explained above or visit the partners ‘websites directly by clicking on the following links:

12. COMMERCIAL PROSPECTION

The Company may collect and process Data for commercial prospection using electronic communications, calls or traditional mail.

Commercial prospection may be carried out directly by the Company or by Partners.

If this is the case, the User is (i) informed prior to any commercial prospection operation and (ii) must agree to it using the information and consent notice when his data is collected via the contact form.

Prior consent for commercial prospection for similar goods or services is not required when a good or service is supplied to the User to the extent that the User has the possibility of opposing free of charge the use of their Data.

Finally, the user is informed that he can register at any moment and free of charge on a call blocker list so as not to receive phone calls from the Company.

14. MODIFICATION OF THE PRIVACY POLICY

The Company reserves the right to modify the Privacy Policy and will inform the User beforehand via a special notice placed on the Website.

15. GOVERNING LAW

The Privacy policy was drawn up in French and is governed by French law.

Any dispute must pass before the relevant French court.