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Privacy Policy

 

SCOPE

Why a Privacy Policy?

 

This Privacy Policy describes how Albéa Services S.A.S. and its affiliates, as applicable ("Albéa" or "We"), are committed to respect Your privacy, when We, as data controller, collect, process and store personal information about you, as our customer, prospect, supplier, candidates and/or Albéa website user (“You”) in connection with Your relationship with Albéa and the Albéa website (the "Website") accessible at "www.albea-group.com" (the "Personal Data").

This Privacy Policy has been designed and implemented to describe Our practices regarding the collection, use, processing, storage, disclosure and transfer of Your personal data, taking into account the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the relevant applicable laws and regulations. 

 

CUSTOMER AND SUPPLIERS

PURPOSES AND LEGAL BASES - How and why do We process Your Personal Data?

 

Albéa collects and processes Your Personal Data for the purposes of enabling Us to manage the customer and/or the supplier relationship, including in particular for:

  • Managing customer, prospect and/or supplier relationships;
  • Measuring the satisfaction of customers and the compliance of suppliers with legal standards by sending surveys;
  • Prospection and direct marketing; 
  • Managing and following-up with offers and orders; 
  • Proceed to filings in front of the competent authorities;
  • Managing payment of invoices; and
  • Managing signature of contracts and contracts data base;

The collection and processing of Personal Data is necessary to allow Us to comply with Our legal obligations and/or for the conclusion and/or performance of a contract with You, and/or, as the case may be, for Our legitimate interests, to promote Our products and services, and manage customer, prospects and supplier relationships on a global level, based on Art. 6 para. 1 lit. b), c) and/or f) of the GPDR. 

CATEGORIES OF PERSONAL DATA - What do We collect about You?

Albéa can collect Your Personal Data, notably during Your interaction with Albéa, such as in the course of business, during a professional fair or through use of Our Website, either (i) directly, from You, or from Your employer, or (ii) indirectly, from authorized third parties such as agents, distributors etc. 

Albéa collects, processes, and uses the following categories of Personal Data about You for the purposes set out above:

  • Identification information (notably surname, name, gender); 
  • Contact information such as professional email, phone number, fax, professional address, job title, job function, seniority in function, contact type (direct marketing contact, customer survey contact etc.), product interest, 
  • CRM/SRM information, such as who is your lead contact at Albéa and/or who is our lead contact within your organization;
  • Purchase, invoicing and tax information to manage orders with suppliers; 
  • Survey ratings and comments; and
  • IP Address.

RECIPIENTS - With whom do We share Your Personal Data?

Albéa may disclose, on a need-to-know basis, Your Personal Data to:

  • Albéa personnel of the relevant entities within the Albéa Group, according to product lines and geographic regions, as well as sales and purchasing functions, project management functions, technical functions, communications functions, information technology department, regulatory affairs functions;
  • Albéa personnel of the relevant entities within the Albéa Group managing orders and suppliers, such as buyers, approvers and accountants;
  • processors of Albéa providing services to Albéa for its customer, prospect and/or suppliers relationship management, including processors hosting Your Personal Data;

With respect to the disclosure of Personal Data described above, Albéa: 

  • follows processes and procedures to ensure disclosures are only made to internal personnel who are authorized to receive this information and who need the information to perform their job responsibilities; 
  • will provide Personal Data only to third party providers that are authorized to receive and process this information and who have contractually agreed to (i) use appropriate technical and other measures to secure this information and (ii) process this information as instructed by Albéa and as necessary to perform their services to Albéa; and
  • will comply with applicable laws and regulations.

In the event that We are sold or all or part of Our business is otherwise transferred to a third party, the Personal Data We have collected and maintained about You may be transferred to that third party, subject to applicable legal requirements.

We may also disclose information about You in instances where We have a good faith belief that We are required to do so by law, including pursuant to a court order or in circumstances where We believe that such action is necessary to prevent fraud or cybercrime or to protect the rights, property, or Our or any person’s safety, in each case as required or permitted by applicable laws and regulations.

RETENTION PERIODS - For how long will We keep Your Personal Data?

We will retain Your Personal Data for the duration Our relationship with You, and as necessary to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes and to the extent permitted or required by law.

 

CANDIDATES 

PURPOSES AND LEGAL BASES - How and why do We process Your Personal Data?

Albéa collects and processes Your Personal Data for the purposes of enabling Us to review and assess your candidature and to manage the recruitment process

The collection and processing of Personal Data is necessary to allow Albéa for the preparation of the conclusion and/or performance of the employment contract with You, and, as the case may be, for Our legitimate interests and for the legitimates interests of other companies of the Albéa Group to globally and efficiently manage recruitment processes, based on Art. 6 para. 1 lit. b), c) and/or f) of the GPDR. 

Unless otherwise specified at the time of collection, the provision of Your Personal Data is thus mandatory. If You do not provide Personal Data, We will not be able to perform the recruitment processes with respect to You. 

CATEGORIES OF PERSONAL DATA - What do We collect about You?

Albéa can collect Your Personal Data during Your job interview and recruitment processes, either (i) directly, from You, or (ii) indirectly, from authorized third parties such as job boards.

Albéa collects, processes, and uses the following categories of Personal Data about You in connection for the purposes set out above:

  • Identification information (notably surname, name, gender); 
  • Contact information;
  • Professional information; 
  • Information from previous recruitment sessions.

RECIPIENTS - With whom do We share Your Personal Data?

We may disclose, on a need-to-know basis, Your Personal Data to:

  • relevant personnel appointed for a certain job listing;
  • HR managers;
  • other affiliates of the Albéa group of companies if you have opted in to be visible for other jobs.

With respect to the disclosure of Personal Data described above, We: 

  • follow processes and procedures to ensure disclosures are only made to internal personnel who are authorized to receive this information and who need the information to perform their job responsibilities; 
  • will provide Personal Data only to third party providers that are authorized to receive and process this information and who have contractually agreed to (i) use appropriate technical and other measures to secure this information and (ii) process this information as instructed by Albéa and as necessary to perform their services to Albéa; and
  • will comply with applicable laws and regulations.

In the event that Albéa is sold or all or part of its business is otherwise transferred to a third party, the Personal Data Albéa has collected and maintained about You in connection with your potential recruitment may be transferred to that third party, subject to applicable legal requirements.

Albéa may also disclose information about You in instances where We have a good faith belief that We are required to do so by law, including pursuant to a court order or in circumstances where We believe that such action is necessary to prevent fraud or cybercrime or to protect the rights, property, or safety of Albéa or any person, in each case as required or permitted by applicable laws and regulations.

RETENTION PERIODS - For how long will We keep Your Personal Data?

If you are not hired, we will retain You Personal Data for 2 years from the date of collection of information. If you are hired, we will retain Your Personal Data for the duration of Your employment contract.

We may also retain Your Personal Data, if necessary, to comply with our legal and regulatory obligations, resolve disputes, to the extent permitted or required by law. 

After this period, Your Personal Data will be erased from all Albéa systems.

 

WEBSITE USERS

PURPOSES AND LEGAL BASES - How and why do We process Your Personal Data?

 

Albéa collects and processes Your Personal Data for the purposes of measuring the audience of our Website, optimizing our Website and analysing the use that is made of the Website.

The collection and processing of Personal Data is made on the basis of Our legitimate interest in the functional management of our commercial activity in order to better know our customers and/or prospects and improve their experience on the Website, on the basis of the legitimate interest of the controller referred to in Article 6 ¡1 f) of the GDPR.

CATEGORIES OF PERSONAL DATA - What do We collect about You?

We can collect Your Personal Data through use of Our Website.

We collect, process, and use the following categories of Personal Data about You for the purposes set out below:

  • Information relating to use of the Website. Information relating to use of the Website means all information collected through the Website such as, for example, actions taken on the Website (e.g. log files identifying clicks made on the Website) and information on how You use the Website.
  • IP address. When you use the Website, we may automatically record your IP address (the unique address that identifies your computer on the Internet) which is automatically recognized by our server.
  • Cookie. A "cookie" is a small text file that we may use to collect information about your activity on the Website. For example, when someone visits a page of the Website, a cookie is placed on the user's machine (if the user accepts cookies) or is read if the user has already visited the Website. Cookies can also be used to track users on the internet. Most browsers can be set to notify you when you receive a cookie; you may also decide to block cookies from your browser by modifying its settings or by using our cookie consent tool but, in this case, you will not be able to take advantage of the custom features used by other users who visit the Website. Some of the cookies we use may be flash cookies or Adobe cookies. To learn more about the conditions of use of cookies, see our Cookies Policy. 
  • Web beacons (also called "GIF web beacons" or "web beacons"). Web beacons are tiny, uniquely identifiable images that function like cookies and allow us to count users who visit certain pages of the Website and help us determine the effectiveness of promotional or advertising campaigns. When used in HTML emails, web beacons can tell the sender if and when the mail was opened. Unlike cookies, which are stored on the user's computer hard drive, web beacons are embedded in web pages invisibly.

RECIPIENTS - With whom do We share Your Personal Data?

Albéa may disclose, on a need-to-know basis, Your Personal Data to:

  • Albéa personnel of the relevant entities within the Albéa Group and subcontractors in charge of the management of this Website;

With respect to the disclosure of Personal Data described above, Albéa: 

  • follows processes and procedures to ensure disclosures are only made to internal personnel who are authorized to receive this information and who need the information to perform their job responsibilities; 
  • will provide Personal Data only to third party providers that are authorized to receive and process this information and who have contractually agreed to (i) use appropriate technical and other measures to secure this information and (ii) process this information as instructed by Albéa and as necessary to perform their services to Albéa; and
  • will comply with applicable laws and regulations.

In the event that Albéa is sold or all or part of its business is otherwise transferred to a third party, the Personal Data Albéa has collected and maintained about You may be transferred to that third party, subject to applicable legal requirements.

Albéa may also disclose information about You in instances where We have a good faith belief that We are required to do so by law, including pursuant to a court order or in circumstances where We believe that such action is necessary to prevent fraud or cybercrime or to protect the rights, property, or safety of Albéa or any person, in each case as required or permitted by applicable laws and regulations.

RETENTION PERIODS - For how long will We keep Your Personal Data?

We will retain Your Personal Data for the duration of a maximum of thirteen (13) months. After this period, Your personal information will be deleted from all Albéa systems or anonymized.

 

TRANSFERS

Are Your Personal Data transferred to other countries and why?

 

We may transfer Your Personal Data to affiliates within the Albéa Group, including to entities that are located outside of the European Economic Area, in countries where the level of data privacy protection is not considered as equivalent to the one applicable in European countries. We have entered into data transfer agreements based on the European Commission model clauses with such affiliates to cover the protection of Your Personal Data. 

In addition, We may use, for the purposes listed in this Privacy Policy, third party service providers which may also be located outside of the European Economic Area, specifically data processors located in the United States, for the provision of applications and software. We enter into contractual agreements based on the European Commission model clauses to secure the transfer of data to such data processors or have checked that such data processors comply with and adhere to the Privacy Shield, which has been considered by the European Commission to provide a sufficient level of protection for the transfer of personal data to the United States.

Any onward transfer (including Albéa affiliates outside the EEA) is subject to compliance with applicable onward transfer requirements, as required by applicable law.

 

DATA SUBJECTS' RIGHTS

What are Your rights on Your Personal Data?

 

If You have questions about what Personal Data Albéa has collected about You, or if You want to exercise any of Your other rights under applicable data protection laws and regulations You should contact:

You have the right (i) to access Your Personal Data and information about the processing carried out by Albéa, (ii) to request correction, supplementation or deletion of Personal Data about You that is inaccurate, incomplete or outdated, (iii) to request restriction of the collection, processing or use of Personal Data about You, (iv) to request data portability, (v) to give instructions related to the retention, erasure and communication of Your Personal Data after Your death, or (vi) to obtain a copy of the appropriate safeguards implemented with respect to cross-border data transfers set out above.

You also have the right, in certain circumstances, to object for legitimate reasons to the processing of Your Personal Data.

You will also be given the right to opt-out of any direct marketing communications, by following the instructions linked from such communications by email.

Please help us to keep Your Personal Data accurate by informing us of any change of name, address, or circumstance.

In case of complaints You also have the right to lodge a complaint with the relevant data protection authority. 

 

SECURITY

How do We protect Your Personal Data?

 

We take reasonable measures to ensure protection against any unauthorized access to, and unlawful use of, Your Personal Data, and against loss, destruction, or damage to Personal Data. We use physical, logical, and technical measures, as well as organizational and procedural controls to safeguard Your personal data, all of which are subject to regular review. 

When contracting with a third-party service provider to process Your Personal Data, we ensure that they are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on Our instructions and implement all technical measures necessary on an ongoing basis to keep Your Personal Data secure.

 

INFORMATION AND UPDATES

How are You informed and who do You contact if You have any privacy questions?

 

If You have any questions, comments, or concerns about Your Personal Data or about this Policy please contact:

The last update of this Notice is February 1st 2019. 

You are invited to consult this Privacy Policy regularly as it may be updated periodically to take account of changes in the law, regulations, or company practices.