General personal data protection policy of Euro Bouchage in France
V0. Established on 28 February 2019 - Published on 18 March 2019
With a view to sharing this policy with the various stakeholders, Euro Bouchage has defined this General Data Protection Policy so that any natural person - whether employee or not - having or not having recourse to the expertise of Euro Bouchage in the context of the provision of services and products, can, at any time, become aware of the commitments made and the practices applied by Euro Bouchage with regard to the personal data entrusted to it.
1. General preliminary commitment in principle
Euro Bouchage undertakes to process all data collected in a manner that complies with the texts applicable to data protection (Law no. 78-17 of 6 January 1978 as amended and the General European Regulation 2016/679 of 27 April 2016 on data protection, these two texts being hereinafter referred to as the “Regulation”).
This general data protection policy concerns :
- Beneficiaries of Euro Bouchage products and services
- Professionals, partners of Euro Bouchage
- Individual customers or prospects of Euro Bouchage
- Employees of Euro Bouchage
- Candidates intending to join Euro Bouchage
- Internet users browsing the Euro Bouchage website
2. For understanding the provisions of this general policy, Euro Bouchage wishes to clarify the following definitions :
- Processing of personal data is an operation, or an organised set of operations carried out on personal data (collection, structuring, storage, modification, communication, etc.).
- Personal data is information that makes it possible to identify a human being (natural person), either directly (e.g. surname/first name) or indirectly (e.g. telephone number, contract number, pseudonym).
- The data subject is the person who can be identified by the data used in the processing of personal data.
- The controller is the one who decides how the processing of personal data will be implemented, in particular by determining what the data will be used for and what tools will be used to process them.
- The processor is the one who carries out operations on the data on behalf of the controller. It signs a contract with the controller who entrusts it with certain tasks and ensures that it has the technical and organisational guarantees, enabling it to process the personal data entrusted to it in accordance with the regulations.
- The recipient is the one who receives authorised communication of the personal data.
3. What are Euro Bouchage's commitments as controller ?
Euro Bouchage is responsible for the processing carried out as part of its business activities and in this capacity, makes the following commitments :
- Personal data are only used for explicit, legitimate and specified purposes (objectives) in relation to its various business activities as mentioned each time the data are collected, in accordance with Article 29 of the European Regulation.
- In application of the principle of minimisation, only personal data that are strictly useful are collected and processed.
- The data are not retained beyond the time necessary for the operations for which it was collected, taking into account the nature of the operations and the requirements of the law i.e. legal requirements.
- We do not communicate or transfer personal data to third parties, but only to authorised recipients within the strict framework of the purposes defined beforehand and as communicated at the time of data collection.
- We entrust personal data to service providers that are processors chosen on the basis of appropriate technical and organisational guarantees, in order to guarantee the protection of the data entrusted to them under the instructions of Euro Bouchage.
- Data subjects are informed in advance and regularly, in a clear and transparent manner, in particular about the purpose for which their data will be used, the optional or mandatory nature of their answers in the forms, the rights they have with regard to data protection and the ways in which they can effectively exercise these rights.
- Whenever required by the Regulation, explicit, informed, active and unequivocal consent of the data subject shall be obtained for the processing of his or her personal data.
- Appropriate logical, technical, organisational and legal security measures have been defined on the basis of a risk analysis of the various types of personal data processing operations concerned, and are implemented by Euro Bouchage, its support services and its processors under contract to ensure the protection of personal data.
- Whenever the risks presented by a processing operation require it, Euro Bouchage carries out an analysis of the impact on the privacy and protection of the personal data of the data subjects in order to adopt measures adapted to these risks.
- Euro Bouchage and its processors are committed to ensuring that any possible and exceptional violation of data and to taking all protective and corrective measures following a violation by informing the CNIL (French data protection authority) and, where appropriate, the data subjects in a timely manner.
At Euro Bouchage, all employees and contributors are made aware or are in the process of being made aware of the principles of data protection as contained in the regulations, through regular scheduled training sessions adapted to their activity and their responsibilities.
Employees have access only to the information necessary for their activity. Sensitive data are subject to specific authorisations and controls.
4. Is there a Data Protection Officer (DPO), what are his/her functions and contact details ?
Euro Bouchage has appointed a Data Protection Officer to ensure compliance with the Regulations and rules described in this General Data Protection Policy.
The data protection officer ensures the following in particular :
- the creation and updating of a register of personal data processing implemented by Euro Bouchage
- ensuring that practices comply with regulations and any changes thereto
- making all Euro Bouchage teams aware of the requirements and good practices in terms of the protection of personal data,
- the effective exercise of the rights of data subjects.
The Data Protection Officer can be contacted using the following details :
Via a form on our website
By post :
Data Protection Officer
ZA les vignes – Rue de la mariette
27320 Droisy - FRANCE
5. For what purposes are the data you entrust to us used ?
Euro Bouchage uses personal data for the following main purposes :
- The management of its customer portfolio and prospects,
- The management of human resources and recruitments,
- The management of external professional contacts, including information on professionals,
- The statistical analysis of its activities,
- Commercial canvassing of professionals and other natural persons, subject to their consent.
The above processing operations are necessary for the performance of a contract concluded between a data subject and Euro Bouchage or in order to pursue a legitimate interest such as fulfilling a legal obligation or informing professional contacts about Euro Bouchage's activities, or in certain cases are based on the explicit consent of the data subject.
6. Who are the recipients of the data you entrust to us ?
On a case-by-case basis of the processing described in the article "Use of data" above, Euro Bouchage determines the recipients of the data according to their tasks and their authorisations to receive the data in compliance with the determined purposes. Applying the principle of minimisation, and as far as possible, only those persons who have been determined to have a "need to know" have access to the data.
7. How long do we keep the data you entrust to us ?
Euro Bouchage has laid down precise rules concerning the retention time of the personal data of data subjects, in order to limit retention to a strictly necessary period.
At the end of the period thus fixed, and as the case may be, the personal data shall be subject, in compliance with the applicable Regulation, to any of these measures :
- Irreversible anonymisation
8. What security measures do we implement to protect the data you entrust to us ?
Data security relates to the measures taken to protect data from the following :
- the destruction, loss, alteration, unauthorised disclosure of personal data transmitted, stored or processed, or unauthorised access to such data, whether accidental or unlawful.
In order to guarantee the security of personal data, Euro Bouchage and its processors implement the appropriate technical and organisational measures taking into account the state of knowledge, costs, nature, scope, context and purposes of processing in order to guarantee a level of security appropriate to the risks.
In particular and whenever necessary, the following measures have been taken :
- means to ensure the continued confidentiality, integrity, availability and resilience of systems and processing operations;
- the deployment of means to restore the availability of, and access to, personal data within an appropriate timeframe in the event of a physical or technical incident;
Thus, Euro Bouchage and its processors are equipped with adapted systems that comply with standard professional practices and the required standards, to guarantee the protection of your personal data.
The websites and all mobile applications offered by Euro Bouchage are secured, in particular for websites by a “secure hypertext transfer protocol” whenever necessary.
9. Your rights over the data you provide to us
Each data subject has the following rights :
- to access your data (right of access) : the data subject may ask Euro Bouchage directly whether it holds any information about him or her and ask for the list of data to be communicated to him or her,
- to request their rectification (right of rectification) : the data subject may request the rectification of inaccurate information concerning him/her. The right of rectification supplements the right of access,
- to request the erasure of his/her data (right to be forgotten) : the data subject may request the erasure of information concerning him/her, for a reason provided for by the Regulation,
- to request the restriction of the processing of his/her data (right to restriction) : the data subject may obtain the limitation of the processing of his/her data, for a reason provided for by the Regulation,
- to request the portability of his/her data (right to portability) : the data subject may request to receive the data he/she has provided to Euro Bouchage, or ask Euro Bouchage to transmit them to another controller for a reason provided for by the Regulation,
- to define advance directives relating to the fate of his or her data after his death.
The data subject may also object, on legitimate grounds, to the processing, dissemination, transmission, storage or hosting of his or her data.
For more information on the meaning of the rights; the CNIL has created a section dedicated to understanding these rights: https://www.cnil.fr/fr/comprendre-vos-droits.
To exercise these rights, the data subject can contact the Euro Bouchage data protection officer :
Via a form on our website
By post :
Data Protection Officer
ZA les vignes – Rue de la mariette
27320 Droisy - FRANCE
In order to facilitate the procedures and in particular to speed up the processing time, Euro Bouchage requests each data subject, when sending a request to exercise their rights, to :
- Indicate which right(s) they wish to exercise,
- Clearly mention their surname / first name / contact details where they wish to be contacted for the responses,
- Attach a copy of a proof of identity.
10. We act within the strict limits of the consent you give us
All processing of personal data is carried out by Euro Bouchage in compliance with the consent of the data subjects, and in some cases provided for by the Regulation, the express consent of the data subject is required.
Whenever the express consent of the data subject is required by the Regulation, it is collected in advance by Euro Bouchage and the data subject may at any time withdraw his or her consent by contacting the Euro Bouchage controller or its DPO.
11. Your right to lodge a complaint with the CNIL
Each data subject has the right to lodge a complaint with a data protection supervisory authority.
In France, this authority is the CNIL, the contact details of which are :
Website : https://www.cnil.fr/
Phone : 01 53 73 22 22
Postal address :
3 Place de Fontenoy
75334 PARIS CEDEX 07 - FRANCE
12. Are your data transferred outside the European Union ?
As a matter of principle, Euro Bouchage does not transfer personal data outside the European Union.
When such transfers of data outside the EU are essential for the quality of the services provided by Euro Bouchage, our General Terms and Conditions of Sale mention them along with the partners to whom this data are transferred and their country.
Euro Bouchage undertakes, in such a case, to have had the said partner sign a transfer agreement outside the EU that complies with the requirements of the Regulation.
13. Changes to the personal data protection policy
The data protection policy is subject to change. In the event of a change in the information mentioned in this policy, Euro Bouchage undertakes to modify it and to inform the data subjects, prior to the implementation of the changes that could have an impact on personal data.