PROTECTION OF PERSONAL DATA POLICY
Update: January 2019
The company Etablissements J. Soufflet, in its capacity of Controller, attaches great importance to protection of and respect for your private life. The present policy is intended to inform you of our practices concerning collection, use and sharing of the information which you supply to us when visiting the website of the Soufflet Group, www.soufflet.com (hereinafter the "Website"). We ask you to read the present document attentively in order to familiarise yourself with and understand our practices regarding processing of your Personal Data which we implement.
All Personal Data collected in connection with the use of our Website is processed and kept pursuant to European Regulation 2016/679 of 27 April 2016, known as the "GDPR"and to law No. 78-017 of 6 January 1978 relative to Computing, Files and Freedom, amended, and all other laws or regulations which may complete or replace the above-mentioned texts (hereinafter the "Applicable Regulations").
Hereunder, the terms "Personal Data", "Processing", "Controller", "Group of undertakings" and "Processor" have the definitions given to these terms in article 4 of the GDPR. More specifically:
"Controller": refers to the company J. Soufflet, a joint-stock company under French law, the registered office of which is located at quai du Général Sarrail, 10400 Nogent sur Seine, France, registered in Troyes Trade and Companies Register as number 642 880 785;
"the Soufflet Group": refers to the group constituted by the company Etablissements J. Soufflet and all companies coming within its scope of consolidation, both in France and internationally (subsidiaries or companies controlled within the meaning of article L.233-1 and L.233-3 of the French Commercial Code).
- Collection of Personal Data
The Controller shall ensure that it collects and processes only Personal Data which is strictly required in light of the purpose for which it is processed.
Collection of the Personal Data in connection with the use of our Site does not under any circumstances form a condition for conclusion of any contract with the Soufflet Group.
The Personal Data collected to allow access to and use of the Website is as follows:
- When you browse the Website, it records your login data (cookies). It also identifies your location data if you have previously activated the location functions. In respect of the location data, this is not recorded or stored in the Controller's information systems: it disappears when you leave our Website.
- When you wish to make contact with the Soufflet Group you can send us your surname and first name, your personal email and your telephone number, using a contact form available on our Website. On the Website you can also be sent newsletters: if you wish to subscribe to this service we collect, with your consent, only your professional or personal email.
When browsing on our Website you can obtain information concerning the activities of the Soufflet Group, its history, its key figures, its governance and its locations, and also information concerning its undertakings, its values and its current news, including its institutional publications. The Website also contains redirection links to other Soufflet Group sites, some of which offer online sales services. A heading dedicated to careers, for example, enables you to view pending job offers within the Soufflet Group: using a redirection link available on the Website you can apply for these offers on a space dedicated to this end.
Finally, our Website uses plug-ins (or extension modules) of social networks, in particular Facebook, Twitter, LinkedIn, YouTube, etc. (hereinafter and jointly "Social Networks").
If you do not want this personal information to be sent from our Website to the Social Networks, it is recommended in this case:
- that you do not interact with these Social Networks by clicking on the available plug-ins on our Website;
- that you deactivate the account on the Social Network in question before visiting and browsing the Website;
- that you browse in "Private" mode using your browser.
The Personal Data collected while you are browsing on the Website is used to allow satisfactory operation of our Website, to facilitate your browsing on it, and finally to provide you with relevant data when you return to our Website
Similarly, we use audience measuring cookies to learn how many visits have been made to our Website, the number of pages seen and the frequency of returns of Visitors of our Website. When you browse on our Website, the saving and reading of cookies enable your browsing to be analysed and the audience of our Website to be measured.
You can manage the cookies used in our Website by configuring your workstation or your browser as described in detail below (cf. below, point 5 "Cookies").
Similarly, and provided you do not object, you can receive from our Website newsletters, information content concerning various professional subjects, press communiqués of the Soufflet Group, all in an exclusively and strictly professional context.
- Legal basis of the Processing
Processing of your Personal Data is based on:
- Your consent if you have expressed a wish to complete the contact form, or to send your email in order to receive newsletters from our Site;
- Our legitimate interest and more specifically the economic interest of the Soufflet Group: the Website contributes to the promotion and improvement of the services and products of the Soufflet Group and benefits both the Visitors and the Soufflet Group, but does not breach the fundamental rights and freedoms of the natural persons who visit it.
Cookies are data stored in the terminal equipment of a Web surfer used by the Website to send data to the Web surfer, enabling this Web browser to send information back to the original site (for example a session identifier, the choice of language or a date).
Cookies enable status information to be conserved, for the period of validity of the cookie in question, when a browser visits the various pages of a Website, or when this browser returns to this site subsequently.
Only the issuer of a cookie can read or modify the information contained in it. There are various types of cookies:
- Session cookies, which disappear as soon as you leave the site;
- Function cookies, which stay on your terminal until their lifetime expires, or until you delete them using your browser's functions;
- Audience measuring cookies, which enable data concerning the frequentation of a Website to be obtained and traffic-related data to be analysed.
You are informed that during your visits to our Website cookies can be installed on your terminal equipment.
The cookies used by the Website are as follows:
- Session cookies, which record technical information when you go from one page to another on our Site. These cookies have a limited lifetime, and expire when you close your browser;
- Function cookies which, in particular, enable us to recognise you during your next visit to the Website, and to personalise the Website accordingly;
- Audience measuring cookies: these cookies are used to collect information, anonymously, on the Visitors of the websites. We use this information to compile reports and to help us to improve the Website.
To manage the audience cookies, we use the services provided by the American companies Google Inc. and Microsoft Corporation. In tangible terms, the data collected through the cookies is sent and stored by these companies. The companies Google Inc. and Microsoft Corporation are members of the Privacy Shield protecting EU/United States data. These companies thus provide an adequate level of protection of personal data, pursuant to the Applicable Regulations.
The service Google Analytics and Microsoft Azure's Application Insights, enable visits to be counted and the way in which the Website is viewed to be identified.
The data generated by these cookies concerns:
- Your use of our Website;
- Your IP address, in order to determine the city where the login occurs. This information is immediately analysed after location and is not communicated to the Soufflet Group.
You can examine the confidentiality policies of Google and Microsoft at the following links:
- Google:https://support.google.com/analytics/answer/6004245?hl=fr ;
- Microsoft Azure: https://privacy.microsoft.com/fr-FR/privacystatement.
5.2 Managing the cookies.
At any time you can choose to deactivate one or more cookies, and object to their being saved.
You have several ways of deleting cookies.
Although most browsers are configured by default and accept the installation of cookies, you have the option, if you desire, to choose to accept all cookies, or to reject them systematically, or alternatively to choose those which you accept depending on the issuer.
To delete cookies which have already been installed on your computer:
- Go to your workstation;
- Select in C:\ the Windows directory;
- Open the directory "Temporary Internet Files";
- Select all the files (CTRL A);
- Chose the "delete" option.
In respect of the management of cookies and your choices the configuration of each browser is different. It is described in your browser's help menu, which will let you know how to modify your wishes concerning cookies. If your browser is not included in the above list, please refer to the "settings" tab of your browser and to the "Options" or "Preferences" menu.
With regard to persons who have chosen to complete the contact form, their Personal Data is kept, in an active database, for a period of three (3) years from the last activity of this person on the Website. After this period this data is deleted. It will therefore be the responsibility of the person concerned to complete a new contact form to remain in relations with the Soufflet Group.
When you have chosen to subscribe to newsletters of our Site we keep your personal data, in this instance your professional or personal email address, for the full term of your subscription.
Conversely, the audience measuring statistics and the unprocessed Website Frequentation Data are not kept for more than thirteen (13) months.
However, after the above-mentioned periods, including, as required, from the time of a deletion request by a Visitor, their Personal Data may be subjected to intermediate Archiving in order to satisfy the legal obligations of the Controller and/or at the very least for the applicable limitation period (such as the limitation period under ordinary law of five (5) years enshrined by article 2224 of the Civil Code), but also in order to respond to requests made after Visitor accounts have been closed, etc.
In the event of a disputes procedure, including one relating solely to the Controller and/or the Soufflet Group, for example with regard to the authorities, the above-mentioned Personal Data and all information, documents and items containing Personal Data seeking to establish any facts which may be claimed, or concerning the identification of the claims, victims, witnesses and officers of the court (name, habitual name, first names, telephone numbers, email address) can be kept for the term of the proceedings, including for a term greater than those indicated above.
- Transferring the collected Personal Data
The Personal Data can be shared with companies in the Soufflet Group.
The information collected, and in particular the Personal Data, can be communicated to third parties acting in a capacity of processors bound by a subcontracting contract to the Controller or any other company in the Soufflet Group, in order to perform, in particular, the services relating to the processing purposes mentioned in point 3, "Purposes of processing the collected Personal Data".
These Processors act only on the Controller's instructions, and have limited access to the personal data, in connection with performance of these services, and have a contractual obligation to use it pursuant to the provisions of the Applicable Regulations. They are bound by the same obligations of security and confidentiality as the Controller.
- If required by the law, the Controller can transfer data following complaints made against the Website, and in order to comply with the administrative and judicial procedures;
- If the Controller is involved in a reorganisation operation within the Soufflet Group, in an operation of merger, acquisition, assignment of assets or collective insolvency proceedings, it may be obliged to assign or to share all or part of its assets, including the Personal Data collected in connection with the Website. If the Personal Data is transferred outside the Soufflet Group, Visitors will be informed before the Personal Data is transferred to a third party.
Finally, your Personal Data is collected, processed and hosted within the European Union, and is not transferred outside the European Union. If we are obliged to transfer your personal data outside the European Union, we shall inform you thereof beforehand. In this case we shall take the necessary measures to guarantee an adequate level of protection of your personal data, pursuant to the Applicable Regulations.
- Implementation of Visitors' rights
Pursuant to the regulations applicable to the Personal Data you have the following rights:
- Right of information and of access;
- Right of rectification;
- Right to deletion ("right to erasure of data") and, more specifically, right to send the Controller special instructions relating to the outcome of Visitors' Personal Data after their death;
- Right to limitation of Processing;
- Right to object;
- Right to portability of the Personal Data.
You can update or delete the Personal Data by sending your request to firstname.lastname@example.org, giving your surname, first name and address, and attaching to it a recto/verso copy of your identity document.
Exercise of these rights does not affect the legality of the processing undertaken before such exercise.
You also have the right to send a complaint to CNIL France if you consider that your rights have not been respected. However, we ask you to contact us before sending a complaint to CNIL (www.cnil.fr).