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Personal data protection policy

 

In accordance with law number 78-17 of 6 January 1978 (modified) concerning information technology, data files and personal liberty, modified (hereafter referred to as the “Informatique et Libertés” law) and European Regulation number 2016/679 of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and the free circulation of such data (hereafter referred to as the “GDPR”), in his capacity as the Data Controller the Publisher guarantees respect for the Website Users’ privacy.

The Data Controller is the natural or artificial person, the public authority, service or other body which, whether alone or jointly with others, determines the purposes and means for the processing.

In this case, it is Workman Turnbull (hereafter referred to as the “Data Controller”).

The term Personal Data (hereafter referred to as the “Data”) refers to any information relating to an identified or identifiable natural person. The term “identifiable natural person” refers to a natural person who may be identified, directly or indirectly, including with reference to a username, name, identification number, location data, online identifier or one or several specific items of information relating to his physical, physiological, genetic, mental, economic, cultural or social identity as defined in the applicable regulation.

For which purposes is your data collected ?

The User, a natural person, is hereby informed that the information he supplies via the Website on the basis either of pre-contractual measures or the implementation of a contract for customer relationship management purposes, or on the basis of the Data Controller’s legitimate interests in order to be able to respond to his request, is intended for the Data Controller’s own departments and for subcontractors strictly authorised by the Data Controller for the management of relations with customers and prospects.

The Data Controller may also collect and record users’ personal data to administer and manage the Website. All of this Data shall be processed on the basis of clear and explicit end purposes in accordance with the applicable Regulation.

Which data is processed ?

  • Data concerning your identity: this Data includes in particular your last name, your first name, your job title, your company name, your email address and your telephone number;
  • Data concerning navigation on the Website (timestamps, the users’ IP addresses, technical data concerning the equipment and the browser used by the users, cookies) and concerning digital platforms via share and media buttons (cookies and other tracers);
  • Data concerning the management of contacts with users (time stamping and purpose of the request, monitoring, outcomes, statistics);
  • Data concerning publication management (subject, deliverable, follow-up, statistics);
  • Data concerning the management of technical services (time stamping and purpose of the request, follow-up, outcomes, statistics);
  • Audience statistics for websites and concerning the use of the online services proposed by the Data Controller.

What is the source of the data collected ?

The Data Controller collects data directly from the Users of the Website (examples: navigation, contact form, etc.).

For whom is your data intended ?

Your Data is processed by the Data Controller’s in-house teams. Additionally, only service providers and those members of their personnel possessing authorisation to this effect are authorised to access your Data, with regard to the specific services assigned to them, which they must perform exclusively on the Data Controller’s behalf in strict compliance with security and privacy obligations.

The information may therefore be forwarded to the following recipients:

Company & purpose Location Personal data protection measure
SiteGround, Host London, United Kingdom

Server : United States

GDPR

Standard contractual clauses

Plus2, Developer London, United Kingdom GDPR

How is your data protected? When required by the applicable Regulations, the Data Controller may forward your Data to any organisations and authorities legally authorised to access it (including the judicial and administrative authorities).

The Data Controller will take all necessary precautions to protect the security and privacy of your Data in order among other things to prevent it being deformed, damaged, divulged or accessed by unauthorised third parties.

What are your rights ?

The User of the Website is informed that he has a right to access, rectify and delete his data, to limit its use, a right to data portability (where applicable) and a right of objection regarding the Data concerning him.

The User of the Website also has a right to specify instructions concerning the fate of his personal data after his death. Accordingly, the User has the right to leave instructions (with the DPO and the Publisher) concerning the retention, deletion and communication of his data after his death.

In the absence of any instructions or any reference to the contrary in these instructions, the User’s heirs may exercise the said rights concerning his personal data after his death upon production of a death certificate. The heirs may proceed with the closure of the deceased’s user account, oppose any continued processing of the personal data concerning him or update the said data.

  • The User and/the heirs may exercise these rights by emailing the Publisher’s DPO department at the following email
    address: dpo@workmanturnbull.fr or by post by writing to the following address: Workman Turnbull, 47 rue de la Chaussée d’Antin, 75009 PARIS

The User also has a right to submit a complaint to the CNIL (French data protection authority). Additionally, each email sent by the Publisher informs you of how to stop receiving emails from him.

The Users of the Website are required to comply with the provisions of the “Informatique et Libertés” law (the French data protection act) and the GDPR, including in particular a ban on collecting or misappropriating any personal data to which they have access.

The retention period for you data

The Data Controller retains your Data for a period not exceeding that required for the purposes stated in this Policy. Beyond this period, your Data may be archived to ensure compliance with the legal obligations to which the Data Controller is subject or be deleted.

Data making it possible to establish proof of a right or a contract, or stored to ensure compliance with a legal obligation by the Data Controller is archived in compliance with the applicable provisions.

  • Data concerning interactions with service providers are stored for five years at the end of the contract concerned.
  • Data from logs is stored for six months.
  • Data necessary to the production of audience statistics and statistics recording the use of online services are stored for 25 months in a form which does not make it possible to identify the data subjects by their IP address, and includes an identifier (concerning the cookie) stored for a maximum period of 13 months unless data subject objects to this.

Data transfers

The processing of your Data for the purposes stated in the Policy may make it necessary to transfer and/or forward and/or store your Data outside the European Union. In this event, you will be provided with specific information on this point by the Data Controller.

Modifications to the data protection policy

Any modifications to this Policy by the Data Controller will be the subject of an update on the Website.

You are invited to regularly consult this Policy to familiarise yourself with any updates or modifications.

If any clauses in this Policy are declared null and void or incompatible with the regulations, it will be considered as non-existent but will not result in the invalidation of the Policy’s other clauses.

Cookie management

The Publisher’s website https://www.workmanturnbull.fr places “cookies” ie.
small files, on your hard disk to facilitate your access to the proposed services.

Further information: cookie management policy.

You can update your cookie management settings at any time and modify your choices concerning the acceptance or refusal of cookies by clicking on the PRIVACY tab (on the bottom right of your screen).