{"id":3569,"date":"2023-12-19T13:36:06","date_gmt":"2023-12-19T12:36:06","guid":{"rendered":"https:\/\/seenet-securite.fr\/?page_id=3569"},"modified":"2023-12-19T13:38:16","modified_gmt":"2023-12-19T12:38:16","slug":"rgpd","status":"publish","type":"page","link":"https:\/\/seenet-securite.fr\/en\/rgpd\/","title":{"rendered":"RGPD"},"content":{"rendered":"

General provisions<\/h2>\n

PREAMBLE<\/h4>\n

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, otherwise known as the General Data Protection Regulation (hereinafter RGPD) sets out the legal framework applicable to the processing of personal data. The RGPD strengthens the rights and obligations of data controllers, processors, data subjects and data recipients.<\/p>\n

Subsequently, and in order to implement the RGPD changes, the French Data Protection Act no. 78-17 of January 6, 1978 was amended by Act no. 2018-493 of June 20, 2018 by Ordinance no. 2018-1125 of December 12, 2018.<\/p>\n

The regulations applicable to the protection of personal data include the following:<\/p>\n

RGPD; ;
\nthe French Data Protection Act (Loi Informatique et Libert\u00e9s), updated by the above-mentioned texts; ;
\nCnil recommendations.
\nFor a better understanding of the present policy, it is specified that :<\/p>\n

Data controller\u00ab refers to the natural or legal person who determines the purposes and means of processing personal data. For the purposes of this policy, the data controller is SENEF ;
\ndata subjects\u00ab are those persons who can be identified, directly or indirectly, by reference to the personal data collected by the data controller, i.e., for the purposes of this policy, all SENEF contacts related to its customers and prospects, regardless of their status (employee or manager).
\nArticle 12 of the RGPD requires that data subjects be informed of their rights in a concise, transparent, comprehensible and easily accessible manner.<\/p>\n

DEFINITIONS<\/h4>\n

\u00abpersonal data\u00bb<\/strong> Any information relating to an identified or identifiable natural person (data subject); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity; ;
\n\u00abenriched data\u00bb<\/strong> Enriched personal data: enriched personal data is the opposite of \u00abraw\u00bb personal data supplied by the data subject. This is data generated by the data controller. It may also be data deduced and\/or derived by the data controller on the basis of data \u00absupplied by the data subject\u00bb; ;
\n\u00abpersonal data processing\u00bb<\/strong> processing\" means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction; ;
\n\u00abpersonal data breach\u00bb<\/strong> Security breach: a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.<\/p>\n

SUBJECT<\/h4>\n

To ensure the smooth running of our business, we are required to process personal data relating to our contacts with customers, prospects and partners in the context of commercial relations and contracts concluded with the latter.<\/p>\n

The purpose of this policy is to meet our obligation to provide information and to remind our customers, prospects and partners of their rights with regard to the processing of their personal data.<\/p>\n

GENERAL PRINCIPLES<\/strong><\/p>\n

No processing is carried out by our company concerning data about you if it does not relate to personal data collected by or for its services or processed in connection with its services and if it does not comply with the general principles of the GDPR.<\/p>\n

Any new processing, modification or deletion of existing processing will be brought to the attention of our contacts with our customers and prospects by means of an amendment to this policy.<\/p>\n

Identifying treatments<\/h2>\n

CATEGORIES OF DATA COLLECTED AND ORIGIN OF DATA<\/h4>\n

Data is mainly collected directly from our contacts with customers and prospects.<\/p>\n

Consequently, we only collect and use the data necessary for the conclusion or performance of contracts with our company, namely :<\/p>\n

Identity of contact person(s) in charge of a file or contacted for prospecting purposes (e.g. title, surname, first name); ;
\nProfessional contact details of the person(s) in charge of a file or contacted for prospecting purposes (e.g. professional email, professional postal address, professional fixed or mobile telephone number, fax number); ;
\nProfessional details of the contact person(s) in charge of a file or contacted for prospecting purposes (e.g. position, grade, function); ;
\nTechnical data depending on use (identification or connection data such as IP address or logs); ;
\nImages of the contact person(s) in charge of a file or contacted for prospecting purposes (e.g. in the case of access to our premises).<\/p>\n

PURPOSES OF PROCESSING<\/h4>\n

Pre-contractual exchanges<\/strong>
\nWe process the data of people who interact with us when we have approached the structure to which they belong for prospecting purposes or when they have contacted us to enter into a contract with us.<\/p>\n

Contract and follow-up<\/strong>
\nWe process the data of our customers' contact persons as part of our contractual relations with them.<\/p>\n

Billing, payment and accounting<\/strong>
\nWe process the data of our contacts with customers and prospects for the purposes of invoicing and paying for orders.<\/p>\n

Customer\/prospect relationship management<\/strong>
\nWe process the data of our contacts with customers and prospects in order to communicate with them in the context of questions they may ask us in connection with the current or future performance of a contract with our company.<\/p>\n

Customer and prospect directory management<\/strong>
\nWe keep an up-to-date directory of our customers and one of our prospects, which includes the names of our main contacts.<\/p>\n

Organization of events by our company<\/strong>
\nWe process the data of our contacts with customers and prospects when we invite them to events that we organize or co-organize.<\/p>\n

Third-party access management<\/strong>
\nWe process the data of our contacts accessing our premises in order to secure access to them (e.g.: keeping a register, access badges, etc.).<\/p>\n

Video surveillance of third-party personnel<\/strong>
\nCertain specific areas of our premises, such as gates and fences, are subject to video surveillance, resulting in the processing of the data of third parties who may be filmed.<\/p>\n

Statistics<\/strong>
\nWe may carry out statistical analysis of our customers' and prospects' data.<\/p>\n

SHELF LIFE<\/h4>\n

We define the length of time we keep data on our contacts with customers and prospects in the light of the legal and contractual constraints imposed on us and, failing that, according to our needs.<\/p>\n

As a matter of principle, data relating to our customers and prospects must be kept for the time strictly necessary to manage the commercial relationship. More specifically, we undertake to respect the following retention periods:<\/p>\n

Customer contracts<\/strong>
\n5 years from their conclusion
\n10 years for contracts over 120 euros concluded electronically<\/p>\n

Commercial correspondence<\/strong> (purchase orders, delivery notes, invoices, etc.)
\n10 years from the end of the financial year<\/p>\n

Images from video protection cameras<\/strong>
\nFor up to one month<\/p>\n

Building access<\/strong>
\nFor up to one month<\/p>\n

Technical data<\/strong>
\n1 year from collection<\/p>\n

Cookies<\/strong>
\nSee the Cookies Policy<\/p>\n

The periods indicated in the table above are necessarily extended for the legal period of prescription as evidence in the event of litigation. In the latter case, the retention period is extended for the duration of the dispute.<\/p>\n

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. Data may be kept for pre-litigation and litigation purposes.<\/p>\n

Please note that deletion or anonymization are irreversible operations and that SENEF is no longer able to restore them.<\/p>\n

LEGAL BASIS<\/h4>\n

The processing of the data of our contacts with our customers and prospects as presented above is based on the following conditions of lawfulness, which differ depending on whether the processing concerns customers or prospects:<\/p>\n

Customers<\/strong><\/p>\n

Pre-contractual or contractual performance<\/p>\n

Prospects<\/strong><\/p>\n

Pre-contractual performance or legitimate interest of SENEF<\/p>\n

DATA RECIPIENTS<\/h4>\n

Recipients of data are natural or legal persons who receive personal data. Data recipients may therefore include both SENEF employees and external organizations.<\/p>\n

We ensure that data collected and processed in the context of our relations with our customers and prospects is only accessible to authorized internal and external recipients, and in particular to the following recipients:<\/p>\n

the staff of the departments responsible for managing relations with our customers and prospects and their line managers; ;
\nsupport staff, i.e. administrative, logistics and IT services and their line managers; ;
\nour service providers or support services (e.g. IT service provider); ;
\nthe competent authorities, should we be required to share certain data with judicial officers, departments responsible for internal control procedures, etc. ;
\nin the event of a visit to our premises, the reception staff, who collect the data of all visitors in a register.
\nAs far as internal recipients are concerned, we decide which recipient will have access to which data according to an empowerment policy, and ensure that they are subject to an obligation of confidentiality.<\/p>\n

With regard to external recipients, we inform you that the personal data of our contacts with our customers and prospects may thus be communicated to some of our service providers or to any authority legally empowered to know (tax and social authorities in particular). In this case, SENEF is not responsible for the conditions under which the personnel of these authorities have access to and use the data.<\/p>\n

Managing people's rights<\/h2>\n

ACCESS AND COPY RIGHTS<\/h4>\n

Our customers and prospective customers have the right to ask us whether we actually process data concerning their members (staff, managers, etc.) in the context of contracts concluded with them or prospecting messages we send them.<\/p>\n

They may also ask us to provide them with a copy of their members' data being processed.<\/p>\n

However, in the event of a request for additional copies, we may require our customers and prospects to bear the cost of this new copy.<\/p>\n

If requests from our customers and prospects are made electronically, the information requested will be provided in a commonly used electronic form, unless otherwise requested.<\/p>\n

Our customers and prospects are hereby informed that this right of access does not apply to confidential information or data that may not be disclosed by law.<\/p>\n

The right of access must not be exercised in an abusive manner, i.e. on a regular basis with the sole aim of destabilizing the proper performance of our services.<\/p>\n

RIGHT OF RECTIFICATION<\/h4>\n

Our customers and prospects have the right to ask us to rectify any of their personal data that may be obsolete or incorrect.<\/p>\n

RIGHT TO ERASURE<\/h4>\n

Our customers may only invoke the right to erasure of their personnel data in the following cases:<\/p>\n

the contract has been terminated and no longer has any effect between our company and its customer; ;
\nmembers of staff whose data is processed and who are no longer employed by one of our customers and therefore wish to be removed from our customer database.
\nOur prospects may invoke the right to erasure of their personal data insofar as they have the right to object to the receipt of prospecting messages.<\/p>\n

RIGHT TO LIMITATION<\/h4>\n

Our customers and prospects are informed that this right is not intended to apply insofar as the conditions required by the applicable regulations are not met with regard to our processing of the personal data of the members of their staff with whom we exchange information.<\/p>\n

RIGHT TO PORTABILITY<\/h4>\n

Our customers and prospects are informed that this right is not intended to apply insofar as the conditions required by the applicable regulations are not met with regard to our processing of the personal data of the members of their staff with whom we exchange information.<\/p>\n

RIGHT OF OBJECTION<\/h4>\n

Customers and prospects have the right to oppose any commercial prospecting by post, telephone or e-mail, including profiling insofar as it is linked to such prospecting.<\/p>\n

In the specific case of electronic canvassing, customers and prospects may at any time object to such canvassing, either by clicking on the link in the e-mail or by modifying the preferences in the customer account on our website (to be completed). By SMS, it is possible to object to all canvassing by sending \u00abstop\u00bb to the number given in the message received.<\/p>\n

EXERCISING THE RIGHTS OF OUR CONTACTS<\/h4>\n

To exercise their rights, customers and prospects should contact us either in writing, by post or by e-mail at the following addresses: dpo-groupesenef@racine.eu.<\/p>\n

We do our best to respond to requests within a reasonable time and, at best, within one month of receipt of the request.<\/p>\n

However, should the processing of requests prove complex, or should we be faced with a large number of requests to exercise rights simultaneously, the processing time may be extended to two months.<\/p>\n

Additional provisions<\/h2>\n

OUTSOURCING<\/h4>\n

We may use any subcontractor of our choice to process the personal data of our customers and prospects.<\/p>\n

Within the meaning of the RGPD, a processor is any natural or legal person who processes personal data on behalf of the controller. In practice, this therefore means the service providers with whom SENEF works and who intervene in SENEF's personal data.<\/p>\n

In this case, we ensure that the processor complies with its obligations under the RGPD.<\/p>\n

We undertake to sign a written contract with all our subcontractors and impose on them the same data protection obligations that we impose on ourselves. In addition, we reserve the right to audit our subcontractors to ensure that they comply with the provisions of the RGPD.<\/p>\n

PROCESSING REGISTER<\/h4>\n

In our capacity as data controller, we undertake to keep an up-to-date register of all processing activities carried out where required by law.<\/p>\n

This register is a document or application that lists all the processing operations carried out by SENEF as data controller.<\/p>\n

We undertake to provide the CNIL, at its first request, with information enabling it to verify the compliance of data processing with current data protection regulations.<\/p>\n

SAFETY MEASURES<\/h4>\n

We implement such physical or logical technical security measures as we consider appropriate to protect against the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of data.<\/p>\n

These measures include the following:<\/p>\n

Data access authorization management ;
\nInternal safeguards ;
\nIdentification process ;
\nConducting security audits and penetration tests ;
\nAdopting an information systems security policy ;
\nThe adoption of business continuity\/disaster recovery plans; ;
\nThe use of protocol or security solutions.
\nIn any event, we undertake, in the event of a change in the means used to ensure the security and confidentiality of personal data, to replace them with means of superior performance. No change may lead to a reduction in the level of security.<\/p>\n

DATA BREACH<\/h4>\n

We undertake to notify the CNIL of any data breach that we may suffer, in accordance with the conditions laid down in the regulations governing personal data.<\/p>\n

Our contacts with customers and prospects are informed of any data breach that could pose a high risk to their privacy.<\/p>\n

Contact<\/h2>\n

DATA PROTECTION OFFICER<\/h4>\n

We have appointed a Data Protection Officer who can be contacted at the following address for any questions relating to data processing: dpo-groupesenef@racine.eu.<\/p>\n

RIGHT TO LODGE A COMPLAINT WITH CNIL<\/strong><\/p>\n

Our contacts at our service providers have the right to lodge a complaint with a supervisory authority, namely the Cnil in France, if they consider that the processing of personal data concerning them does not comply with European data protection regulations, at the following address:<\/p>\n

CNIL - Complaints department
\n3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
\nTel: 01 53 73 22 22<\/p>\n

EVOLUTION<\/h4>\n

The present policy may be modified or amended at any time in the event of changes in legislation, case law, CNIL decisions and recommendations or usage.<\/p>\n

Any new version of this policy will be brought to the attention of our customers and prospects by any means we choose, including electronically (for example, by e-mail or online).<\/p>\n

FOR MORE INFORMATION<\/h4>\n

For further information, please contact our Data Protection Officer at the following e-mail address: dpo-groupesenef@racine.eu.<\/p>\n

For more general information on the protection of personal data, please visit the Cnil website at www.cnil.fr.<\/p>\n<\/div><\/div><\/div><\/div><\/div>","protected":false},"excerpt":{"rendered":"","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"inline_featured_image":false,"footnotes":""},"class_list":["post-3569","page","type-page","status-publish","hentry"],"yoast_head":"\nRGPD - Seenet S\u00e9curit\u00e9<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/seenet-securite.fr\/en\/rgpd\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"RGPD - Seenet S\u00e9curit\u00e9\" \/>\n<meta property=\"og:url\" content=\"https:\/\/seenet-securite.fr\/en\/rgpd\/\" \/>\n<meta property=\"og:site_name\" content=\"Seenet S\u00e9curit\u00e9\" \/>\n<meta property=\"article:modified_time\" content=\"2023-12-19T12:38:16+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/seenet-securite.fr\/wp-content\/uploads\/2023\/12\/seenet-securite.jpg\" \/>\n\t<meta property=\"og:image:width\" content=\"299\" \/>\n\t<meta property=\"og:image:height\" content=\"100\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data1\" content=\"18 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/seenet-securite.fr\\\/rgpd\\\/\",\"url\":\"https:\\\/\\\/seenet-securite.fr\\\/rgpd\\\/\",\"name\":\"RGPD - 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