Last updated : November 5 2024
The purpose of this privacy policy (hereinafter " the Policy ") is to inform users (hereinafter " the User(s) ") of the website https://www.hbssfrance.com (hereinafter the " Site ") and their contacts of the means implemented to process their Data (as defined below), in accordance with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms as well as Regulation No. 2016-679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal Data and the free movement of such Data (hereinafter " Regulations ").
The Data controller is SELARL Fayrouze Masmi Dazi Avocat, whose registered office is at 106 rue de l'Université 75007 Paris and whose SIRET number is 844 878 934 00018.
The Policy may be modified at any time by the data controller, in particular to comply with any regulatory, jurisprudential, editorial or technical developments. The User must refer to the latest version of the Policy before browsing. However, any substantial modification will be brought to their attention.
1) What Data is collected on the Site?
“Data” means any information relating directly or indirectly to an identified or identifiable natural person (e.g. surname, first name, telephone number, email address ).
The data controller may be required to collect and process Data:
- From the User,
- User contacts.
This Data may be collected:
- Directly, through a declaration by the User (when sending an email to the address contact@hbssfrance.com);
- Automatically, by the data controller's systems (when the Site places or reads tracers, such as cookies, on the User's terminal).
When the User sends an email to the address contact@hbssfrance.com, the data controller collects his email address as well as the content of his message. Once again, the data controller strongly recommends that the User avoids communicating any Personal Data in his email in any event to limit this communication to what is strictly necessary for processing his request and not to integrate Data relating to third parties.
When the User browses the Site, tracers collect data relating to their browsing.
2) Why does it collect User and contact data?
The Data collected as part of the use of the Site are processed in order to meet the following purposes:
- Management of User requests;
- Contacting the User and, where applicable, the contacts he/she has included in the appointment as part of his/her appointment request;
These treatments are based on the following legal basis: The processing is necessary for the execution of pre-contractual measures taken at the request of the User who contacts SELARL Fayrouze Masmi Dazi Avocat considering entrusting it with a file.
- The improvement and security of the Site (for Data collected through tracers).
This processing is based on the following legal bases: the legitimate interest of the data controller in improving and developing its Site or, where applicable, the consent of the User.
3) To whom are the collected Data transmitted?
The Data collected for the purposes set out above are communicated:
- To the HBSS France teams, its members within the framework of their missions;
- To subcontractors of HBSS France and its members: these are the service providers who need to access certain Data to perform their services, mainly:
- The host: pantheon.io
These subcontractors may be located outside the European Union. In this case, the data controller ensures that these transfers are governed by appropriate guarantees (in particular the Commission's adequacy decision or standard contractual clauses) or are based on a derogation or exception provided for by the Regulation. A copy of these guarantees can be obtained by sending a request to the address provided at the end of the Policy.
Finally, the data controller informs the User that, when they click on redirection icons to external sites (for example Linkedin), the publishers of these sites may collect their Data and/or deposit and read tracers placed on their terminals. The data controller recommends that the User refer to the privacy policies of said sites to obtain more information on this subject.
5) How long is the Data kept?
The User's Data and that of their contacts will not be kept beyond the period strictly necessary for the purposes pursued as set out herein and in accordance with the Regulations and applicable laws.
In this regard, the Data collected for the purpose of managing the User's requests for information are kept for 2 years after the request is closed (if the User subsequently becomes a customer, their Data may be kept for longer as part of separate processing).
Subsequently, they may be archived for the purposes of complying with any regulations and/or legislation in force and in particular, due to compliance with legal limitation periods or because these data are of administrative interest, in particular in the event of litigation (5 years in French law).
4) What rights do the User and their contacts have over their Data?
The User and his contacts whose Data is provided benefit from the following rights:
- Right of access: the right to request confirmation as to whether or not one's Data is being processed and, where applicable, access to said Data and information relating to its processing.
- Right of rectification: the right to request the rectification of any error in the Data concerning him/her;
- Right to erasure : the right to request the erasure of one’s Data;
- Right to restriction of processing: the right to request restriction of the processing of his/her Personal Data;
- Right to portability: the right to receive certain Data collected directly from him and to transmit them to another data controller;
- Right to formulate general and specific directives on the fate of his Data after his death.
They have the right to object if they wish their Data to no longer be processed. In this case, they must put forward reasons relating to their particular situation. On the other hand, in the event of processing of Data for commercial or advertising prospecting purposes, or profiling, they may object at any time and without reason.
They also have the right to withdraw any consent given.
The exercise of these rights is carried out at any time using the contact details provided in the Policy. Proof of identity may be requested in order to protect the data controller and the User or their contact against any fraudulent request.
Please note: Most of the above rights are subject to limitations and exceptions. If we are unable to comply with a request to exercise these rights, the data controller will indicate the reason to the User.
The User and his contacts can finally send a complaint to the competent protection authority (in France, the CNIL, online or by mail to the following address: 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07).
6) Any questions?
For any questions relating to the collection and processing of Data: contact@hbssfrance.com