The user is informed that personal data within the meaning of Law No. 78-17 of January 6, 1978 known as the “Informatique et Libertés” Act and Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter the “Regulation”) are likely to be collected and processed by Symag in its capacity as data controller.
If necessary, additional information may be communicated when the User subscribes to a particular product or service.
1. What personal data about are used, for what purposes and on what legal basis ?
The collection and/or processing of this data is necessary for the execution of the general conditions of use and the provision by Symag of its services (hereinafter the “Services”), including access to its website www.symag.com (hereinafter the “Site”).
It is specified that:
1.2 The personal data collected and processed by Symag by means of the contact form are last name, first name, company, position held, email adress and telephone number provided by the User, as well as any other information transmitted voluntarily by the User in the “message” box of the said form. These data are processed by Symag in order to allow the processing of the User’s requests made through the contact form. Where applicable this processing is based on the consent of the User of the contact form ;
1.3 Personal data collected and processed by Symag by means of the application form are the last name, first name, email adress, telephone, number filled in by the User, as well as any other information voluntarily transmitted by the User and filled in the “message” box or attached as an attachment to said form. This data is processed by Symag in order to allow the processing of the User’s applications made through the application form. This processing is based on pre-contractual measures taken at your request, in accordance with the repository of the French data protection authority (hereinafter the “CNIL”).
All processing based on Symag’s legitimate interest remains proportionate and Symag ensures, through a balancing test, that the interests or fundamental rights of the Users are preserved. The User may obtain further information concerning the balancing test by contacting Symag’s services at the contact information listed in section 6 “What are the rights of the Users and how to exercise them?” below.
When the processing is based on the User’s consent, the User may withdraw it at any time.
The User will never be asked to provide sensitive data such as health data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data or data concerning sex life or sexual orientation, unless there is a legal obligation for Symag to do so.
2. To whom is this policy adressed and from whom is the data collected ?
Symag collects data directly from the User, whether he/she is a customer, candidate or prospect (when the User contacts Symag or consults the Site or one of Symag’s applications, uses Symag’s products and services).
3. With whom is personal data shared ?
Personal data collected and processed by Symag are exclusively intended for Symag.
However, in order to fulfill some of the purposes mentioned in this policy, Symag may share the User’s personal data with service providers who provide services on behalf of Symag (e.g., IT services).
In addition, Symag may disclose personal data collected and/or processed by it to local or foreign financial, tax, administrative, criminal or judicial authorities, arbitrators or mediators, law enforcement authorities, government agencies or public bodies, to whom Symag or any member of the BNP Paribas Group are required to disclose data :
- At their request ;
- In the defence or reply to a question, action or proceeding ;
- In order to comply with any regulation or recommendation issued by a competent authority in respect of Symag or any member of the BNP Paribas Group.
Finally, Symag may have to communicate such data to certain regulated professionals such as lawyers, as well as to any current or potential buyer of companies or activities of the BNP Paribas Group or insurers.
4. International transfers of personal data
Other personal data, which is the subject of this policy, is not transferred outside the European Economic Area (EEA).
If such a transfer were to take place, to a country outside the EEA, the transfer of the User’s personal data shall be implemented on the basis of a decision issued by the European Commission, where the European Commission has recognized that the country to which the data is transferred provides an adequate level of protection.
In the event of a transfer of the User’s personal data to a country whose level of protection of such data has not been recognized as adequate by the European Commission, either Symag will rely on a derogation applicable to the specific situation (for example, if the transfer is necessary to execute a contract concluded with the User, such as in particular when making an international payment) or Symag will take one of the following measures to ensure the protection of personal data :
- standard contractual clauses approved by the European Commission ;
binding corporate rules.
To obtain a copy of these measures to ensure the protection of personal data or to receive details of where they are accessible, a written request may be addressed to Symag as indicated in Section 6 below.
5. For how long is personal data kept ?
This data is kept for the time necessary to comply with applicable laws and regulations, or for the time striclty necessary to meet the aforementioned purposes of processing, in particular :
- For a period of two years with regard to the User’s navigation data collected on the Site ;
- For a period of two years with respect to the User’s data collected by means of the contact form ;
- For a period of two years for the User’s data collected through the application form.
The mandatory or optional nature of the answers is indicated on the contact and application forms. If the mandatory fields are not filled in, Symag will not be able to respond to the User’s requests.
6. What are the rights of the Users and how to exercise them ?
The User is informed that he/she has the rights provided by the Regulation on personal data concerning him/her and more specifically the following rights :
- Right of access : the Users can obtain information relating to the processing of their data as well as a copy of them ;
- Right to rectification : if the Users consider that their personal data are inaccurate or incomplete, they have the right to obtain that these data be modified accordingly ;
- Right to erasure : the Users may request the erasure of their personal data, to the extent permitted by law ;
- Right to limit the processing of your data ;
- Right to object : the Users may, for reasons related to their particular situation, oppose the processing of their personal data. In particular, the Users have the right to object, at any time, to the processing of their data for direct marketing purposes, which includes profiling related to such direct marketing ;
- Right to withdraw their consent : when the processing of their data has been subject to their consent, the Users have the right to withdraw this consent at any time ;
- Right of data portability : where applicable, the Users have the right to request that the data they have provided to Symag be recovered or transferred to a third party if this is technically possible ;
- Right to lodge a complaint with a competent supervisory authority ;
- Right to define guidelines for the storage, erasure and/or communication of their personal data after their death.
These rights, as well as any questions concerning the use of the Users’ personal data, pursuant to this policy, may be exercised at the Users’ discretion by sending an e-mail to firstname.lastname@example.org or by mail to the attention of Symag, Direction Communication, 100 avenue de Stalingrad, 94800 Villejuif accompanied by a copy of his/her proof of identity so that Symag can identify him/her.
In accordance with the regulations in force, and in addition to the rights mentioned above, the User also has the possibility of lodging a complaint with the CNIL.
In a world where technologies are constantly evolving, Symag may need to regularly update this policy.
Symag invites the Users to read the latest version of this document online and will inform them of any significant changes through its website or through its usual communication channels.