Personal data processing policy applicable to contacts, customers, prospects, online service users www.catuelec.com

The following policy applies to the processing of personal information by the SICAME GROUPa French simplified joint-stock company with a capital of 77 657 824,00 €, registered under number 815 119 623, at the Trade and Companies register of ARNAC POMPADOUR, having its head office (1, AVENUE BASILE LACHAUD - 19230 ARNAC POMPADOUR), and represented by Vincent ROY duly empowered in his capacity as President (hereafter referred to as the processing manager).

1 – General provisions

The following provisions apply to all the processing of personal information by the processing manager, unless stipulated otherwise in the specific provisions.

> Legal framework – compliance with the RGPD and French Law

The processing manager declares that it is in charge of processing personal information in compliance with the regulations (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016, pertaining to the protection of individuals with regard to processing private information and the free movement of such data (hereafter referred to as RGPD) and French Law no. 78-17 dated 6th January 1978 pertaining to Information Technology, Databases and Civil Liberties (as amended).

> Processing manager and other players

The processing manager is identified above. Contact details: 01 42 31 46 00 - webmaster@catuelec.com - www.catuelec.com.

The DPO of the SICAME Group may be directly contacted via the following e-mail address: inforgpd@sicamegroup.com

> Recipients of private information

The concerned entities are those whose private information is collected, in compliance with the RGPD requirements.

 

> Transfer of data

The SICAME Group and its subsidiary companies may transmit your private information to service providers as part of the contractual relations. These providers must keep your information safe for the period required to process it.

> Retention period of private information

We shall store private information for the period required to execute the contract, in compliance with the legal obligations relating to storage and documentation.


> Rights of the individual whose personal information is collected

The individual whose personal information is collected has the right:

– to ask the processing manager for access to private information, to rectify or delete the data, or to limit the processing of data for the data subject,

– to oppose the processing,

– to ask for portability of the data,

– to make a claim with a control authority,

– to withdraw its consent at any time, without prejudice to the lawfulness of the consent-based processing prior to withdrawal, this right exists exclusively when the processing is based on article 6, paragraph 1, point a), or on article 9, paragraph 2, point a) of the RGPD, i.e. on the consent of the individual with regard to the processing of its personal data for one or more specific purposes.


> Automated decision making – profiling

Unless otherwise stipulated in the specific provisions, there will be no profiling done and in general, no automated decision shall be taken on the collected database.

2 – Specific provisions

The following provisions are specific to each type of private data processing.


> Managing relations with our contacts and prospects

Processed private data – We process the following type of private data: civility, first name, last name, telephone numbers, electronic address, postal address, occupation.

Purposes – The processing of private data is used to manage relations with our contacts and prospects. This processing is particularly used to send news about our organisation, our products and services to the data subject.

Legal base – This private data processing is subject to the consent of the data subject (article 6, paragraph 1, point a) of the RGPD). Request for data is contractual by nature. The data subject is not obligated to provide this data. If the data subject does not provide the data or withdraws its consent to data processing, it cannot receive news about our organisation, our products and our services.

 

 

> Customer acceptance procedure

Processed private data – We process the following type of data: civility, first name, last name, telephone numbers, electronic address, postal address, occupation, organisation (company, enterprise or other), designations, requested product or service, distribution channel.

Purposes – This data processing is used to meet our obligations of vigilance with regard to the customers, in compliance with the French law, specifically articles L. 561-4-1 and R. 561-5 of the Monetary and Financial Code.

Legal base – This processing is required to comply with the legal obligations that the processing manager is subjected to. It is based on article 6, paragraph 1, point c) of the RGPD. The request for data shall condition the establishment of a business relation, in compliance with the applicable legal and regulatory provisions. The data subject must provide this data if it desires the establishment of such a business relation. If the data subject does not provide the data, we cannot establish a business relation with the individual.

> Managing relations with our customers

Processed private data – We process the following type of private data: civility, first name, last name, telephone numbers, electronic address, postal address and occupation.

Purposes - The lawfulness of processing such data results from its purpose, the execution of a contract or pre-contractual measures, and is based on our legitimate interests.

Legal base – This processing is necessary to execute a contract that the data subject is bound to or its pre-contractual measures. It is based on article 6, paragraph 1, point b) of the RGPD. Request for data is contractual by nature. The data subject must provide this data if it wants to avail our products or services. If the data subject does not provide the data, it cannot become a customer and avail of our services. This processing is necessary to execute the pre-contractual measures established at your request and to execute the contract concluded between us. It is based on article 6, paragraph 1, point b) of the RGPD. The request for data shall condition the contract conclusion. It is contractual by nature. The data subject must provide the data. 

> Analysing and improving our products and services

Processed private data – We process the following type of data: civility, first name, last name, telephone numbers, electronic address, postal address, occupation.

Purposes – This processing is used for purposes of analysis and statistical study of the usage of our site, our products and services.

Legal base – The processing is necessary for the legitimate interests we pursue, namely, improving and optimising the products and services. It is based on article 6, paragraph 1, point f) of the RGPD. Request for data is contractual by nature. The concerned person is not obligated to provide this data and can oppose to its processing at any time. If the data subject does not provide the data, it cannot receive news about our organisation, our products and our services.

 

> Using Google Analytics 

Processed private data – Google processes data as indicated in its privacy policy (https://support.google.com/analytics/answer/6004245?hl=fr / https://policies.google.com/privacy?hl=fr#infocollect). This data particularly includes the IP address of the devices used to view the site.

Purposes – This processing is used for purposes of analysis and statistical study of the usage of our site.

Legal base – The processing is necessary for the legitimate interests we pursue, namely, improving and optimising out Internet site for the benefit of the users. It is based on article 6, paragraph 1, point f) of the RGPD. Request for data is contractual by nature. The concerned person is not obligated to provide this data and can oppose to its processing at any time. To prevent the collection of data to be used by the website and its processing by Google, the data subject must comply with the instructions of Google: http://tools.google.com/dlpage/gaoptout

> Marketing and advertising messages

Processed private data – We process the following type of data: last name, first name, information on open messages and links.

Purposes – The processing is used to improve our communication and to send you relevant content.

Automated decision making – profiling – Automated decisions shall be taken based on the data collected. The underlying logic of these automated decisions is as follows: customising user experience and offering relevant content. The importance and expected consequences of this process for the data subject are as follows: customisation of communication messages sent to it.

Legal base – The processing requires the consent of the data subject (article 6, paragraph 1, point a) of the RGPD) and it is necessary for the legitimate interests we pursue, namely, improving our communication and avoiding to send inappropriate communications (article 6, paragraph 1, point f) of the RGPD). Request for data is contractual by nature. The concerned person is not obligated to provide this data and can oppose to its processing at any time. If the data subject does not provide the data or withdraws its consent to process the data, it cannot receive adapted communications.

> Security and prevention of illicit activities

Processed private data – We process the following type of data: civility, first name, last name, telephone numbers, electronic address, postal address, occupation.

Purposes – The process is used to ensure the security of our products and services and to prevent illicit activities related to our products and services.

Legal base – This processing is required in order to comply with the legal obligations to which the processing manager is subject (article 6, paragraph 1, point c) of the RGPD) and it is necessary for the legitimate interests we pursue, namely, improving the security of our products and services and preventing illicit activities (article 6, paragraph 1, point f) of the RGPD). The request for data must comply with the applicable legal and regulatory provisions. The data subject must provide this data if it wants to avail of our products and services. If the data subject does not provide the data, it cannot avail of our products and services via the internet site.