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In accordance with the French Data Protection Act and the General Data Protection Regulation, the purpose of this Privacy Policy is to inform you of how your personal data is processed.
Personal data is any data that directly or indirectly identifies a natural person, such as surname, first name, e-mail address (hereinafter “Personal Data”). The processing of Personal Data (hereinafter the “Processing”) corresponds to any operation or set of operations applied to Personal Data (e.g. collection, recording, modification, consultation).
1. The data controller
The data controller responsible for your Personal Data is SOFRAME.
Postal address: 29 rue du 14 Juillet 67980 HANGENBIETEN
E-mail address of the Data Protection Officer: dataprotection@soframe.com.
Representative of the Data Controller: Patrick BOURREAU
2. Why do we process your personal data?
We process your Personal Data for the following purposes:
a. commercial actions
The objectives of the commercial actions are, in particular, commercial prospecting, sending invitations to trade fairs, seminars or conferences, and sending greeting cards.
b. management of the “contact” and ” careers” sections
The purpose of the Processing of Personal Data under the headings “Contact Us” and “Careers” is to respond to you in the most appropriate way.
c. acces and management of the customer area
The aim is to allow customers to order spare parts and receive quotes via the site..
d. the management of tracking files (cookies)
Some cookies, such as those for statistical purposes, collect Personal Data. For more information about cookies, you can read our Cookie Usage Policy.
e. management of requests to exercise your rights regarding your personal data
The purpose of the Processing of Personal Data in this context is to respond to your requests to exercise your rights..
f. to satisfy legal and/or regulatory obligations
In the event that we are required to comply with legal and/or regulatory obligations, the purposes for which your Personal Data is processed will be specified on a case-by-case basis. They may be used in particular for the purposes of establishing, exercising or defending legal rights.
g. management of customer data and contacts in the pre-contractual or contractual context (including administrative and accounting management)
The purpose of the Processing of Personal Data in this context is to enable exchanges between the parties involved in the negotiation or execution of contracts.
3. What personal data do we process?
| Finalités | Personal data processed |
|---|---|
| Commercial actions | Surname – first name – e-mail address – telephone number – company – function – language of communication . |
| Management of the “Contact Us” and ”Careers” sections | Surname – first name – company – e-mail address – telephone number – message content. |
| Cookie management | Personal data relating to the devices used or to the network such as IP address – connection data – data revealing your click path on our site – time spent on a page of our site – geographical area – connection mode – keywords typed in the search engine. |
| Management of requests to exercise rights concerning Personal Data | Surname – first name – company – e-mail address – telephone number – message content. In the event of a request for a right relating to your Personal Data, we will require proof of your identity in order to avoid any breach that could harm you or a third party. |
| To satisfy legal and/or regulatory obligations | Potentially all the Personal Data mentioned. |
| Management of customer data and contacts in the context of the pre-contractual or contractual relationship (including administrative and accounting management) | Surname – first name – company – postal address for invoicing and delivery – e-mail address – telephone number – fax – language of communication – function – authorisations if applicable – copy of the national identity card of the legal representative. |
4. What are the legal grounds for processing personal data?
There is a legal basis for the processing of Personal Data for each purpose.
| Purposes | Legal bases |
|---|---|
| Commercial actions | The legal basis is our legitimate interest to carry out commercial actions in order to keep in regular contact with customers and prospects. |
| Management of the “Contact Us” and ”Careers” sections | The legal basis is our legitimate interest. Your Personal Data is necessary to respond to you in the best possible way. |
| Cookie management (only for cookies collecting Personal Data) | The legal basis is the consent of the persons concerned. Without your consent, cookies collecting Personal Data will not be installed on your machine. Only the cookies necessary for the proper functioning of the site will be used. |
| Management of requests to exercise rights concerning Personal Data | The legal basis lies in legal and regulatory obligations. |
| To satisfy legal and/or regulatory obligations | The legal basis lies in legal and regulatory obligations. This purpose is only intended to be realised in the event of litigation or in response to legal or regulatory obligations. |
| Management of customer data and contacts in the context of the pre-contractual or contractual relationship (including administrative and accounting management) | The legal basis is the performance of a contract to which you are a party or the execution of pre-contractual measures. |
5. Who are the recipients of your personal data?
The recipients of your Personal Data may be other entities of the LOHR group, as well as service providers who may process all or part of your Personal Data to the extent necessary for the performance of their tasks (hosting, service providers, etc.)
Only the departments authorised to process your Personal Data will receive it.
The data is hosted on the SdV-PLURIMEDIA server.
Your Personal Data is processed in France or in the EEA (European Economic Area), where the regulations on the protection of Personal Data are in line with those applied in France.
If, exceptionally, your Personal Data is processed outside the EEA, we will take the necessary steps to ensure that such Processing is carried out with a level of protection equivalent to that in force within the European Union.
Your Personal Data may be disclosed to third parties if we are required to do so by law, special regulation or administrative or judicial order.
6. How long will your personal data be kept?
Your Personal Data is kept for the time necessary to fulfil the purposes for which it is processed..
In the event of a request concerning a right or any other request, your Personal Data is processed for the time necessary to respond.
With regard to the management of customer data and contacts within the framework of the pre-contractual or contractual relationship, the Personal Data are kept in an active database for a maximum of the entire duration of the contractual or pre-contractual relationship plus the duration of the legal requirements in force.
Concerning the management of cookies, the duration of the conservation of Personal Data in an active database is: maximum 13 months from the acceptance of the cookies or from the withdrawal of the consent.
For all of the above purposes, the Personal Data is then placed in an intermediate archive and permanently deleted when any legal action is time-barred.
Prior to this, your Personal Data may be used for evidential purposes in the event of litigation or may be used to meet legal and/or regulatory obligations.
7. What are your rights ?
You have rights to your Personal Data.
The right of access allows you to request a copy of your Personal Data.
The right of rectification vous permet la mise à jour des Données Personnelles périmées, erronées ou de compléter des informations vous concernant si celles-ci sont incomplètes.
The right to object allows you, provided that you can prove reasons relating to your particular situation, to object to the use of Personal Data for a specific purpose.
The right to restrict Processing complements the exercise of one or more other rights (hereinafter the “Request”) and allows you to freeze the use of your Personal Data for the time necessary to process the Request.
The right to portability allows you to receive the computerized Personal Data, in a structured, commonly used computer format and if you wish, to transfer it to any other Data Controller.
The right to deletion allows you to delete your Personal Data.
Once you have given your consent you have the right to withdraw it at any time.
The table below shows the rights for each purpose.
| Purposes | Your rights |
|---|---|
| Commercial actions | You have the right to access, rectify, limit, delete and object. |
| Management of the “Contact Us” and ”Careers” sections | You have the right to access, rectify, limit, delete and oppose the processing of your personal data. |
| Cookie management | You have the right of access, rectification, limitation, portability and the right to withdraw your consent at any time. |
| Management of requests to exercise rights concerning Personal Data | You have the right of access, rectification and limitation. |
| To satisfy legal and/or regulatory obligations | You have the right of access, rectification and limitation. |
| Management of customer data and contacts in the context of the pre-contractual or contractual relationship (including administrative and accounting management) | You have the right of access, rectification, portability, limitation, deletion and objection. |
In accordance with the Data Protection Act, you also have the right to give instructions concerning the fate of your Personal Data in the event of your death.
To exercise your rights, you can send your request by e-mail to dataprotection@soframe.com.
In order to respect the rights and freedoms of third parties, all requests must be accompanied by proof of identity. This proof will be deleted once the request is closed.
In any case, you have the right to make a complaint to the Commission Nationale de l’Informatique et des Libertés (CNIL): 3, Place de Fontenoy, 75007 Paris.