Privacy POlicy

PRIVACY POLICY

Groupe Europe Handling (hereinafter “GEH” or “we”), acting as a data controller within the meaning of the European Regulation No. 2016-679 of 27 April 2016 and the amended French Data Protection Act of 6 January 1978 (hereinafter, together, the “Regulation”), attaches great importance to the protection of personal data and respect for your privacy. This policy (hereinafter the “Policy”) aims to inform you, in accordance with the Regulations, about our practices regarding the collection, use and sharing of personal information provided through our website, digital-in-progress.com (hereinafter the “Site”). This Policy applies only to the processing of personal information that may identify or make identifiable users of the Site, directly or indirectly (hereinafter “Personal Information”). Users of the Site may include, but are not limited to, users, prospects, customers, and applicants for employment with GEH (“Users” or “you”). The purpose of this Policy is to inform Users about the processing of Personal Data by us, how we use, share and protect Personal Data, and what rights you have in relation to your Personal Data.

1. The data we collect

By using our Site, in particular by accepting the installation of cookies or by using our contact form or our chat tool, you may be required to transmit Personal Data to us, consisting in particular of (i) identification data (name, email address, etc.), (ii) technical data (IP address, etc.) and (iii) data relating to your browsing on our Site.

2. Why do we process your Personal Data and on what legal basis?

We use your Personal Data in order to:

1/Carry out commercial prospecting operations;

This processing is based on our legitimate interest in promoting the Platform as long as you have voluntarily provided this information on our form, have been informed of this purpose, can object to it at any time and that we do not keep this information for more than three (3) years after our last exchange with you.

2/ To respond to your requests for information and contact formulated on our Site;

This processing is necessary (i) to carry out pre-contractual measures and (ii) to pursue our legitimate interest in communicating about our services by responding to a request from you.

3/ To help us maintain a safe and secure environment on our Site;

This processing is necessary for (i) the pursuit of our legitimate interest in ensuring the computer security of the Site and of your Personal Data, (ii) compliance with our legal security obligations, or (iii) the establishment, exercise or defence of legal claims.

4/ To manage our Site and to carry out internal technical operations in the context of problem solving, data analysis, testing, research, analysis, studies and surveys;

This processing is based on our legitimate interest in improving the functionality of our Site and your browsing.

5/ Managing applications for the purpose of recruiting candidates for positions within GEH

This processing is based on our legitimate interest in filling positions at the request of Users.

At the time of collection of your Personal Data, you will be informed of the fact that certain Personal Data must or must not be provided in order to achieve the expected result. If you do not fill in the so-called mandatory information, the execution of the request may be impossible.

3. Who are the recipients of your Personal Data and why do we transfer it?

• Personal Data transferred to authorities

In accordance with the regulations in force, your Personal Data may be transferred to the competent authorities at their request or at the request of the rightful owner, and in particular to judicial officers in the case of the search for the authors of offences committed on the Internet.

• Personal Data transferred internally

The Personal Data collected and processed are transferred to our staff, our accounting, IT and communication departments, and potentially to any internal GEH department

• Personal Data transferred to our service providers

We work in close collaboration with third-party companies that provide IT services necessary for the proper functioning of the Site (database management, hosting, storage, maintenance, etc.). The servers of our hosting provider, OVH France, are located in France. When these service providers are subcontractors within the meaning of the Regulation, i.e. they carry out processing on our behalf, we ensure that they only act under our instructions and implement appropriate technical and organisational measures, so that the processing of Personal Data they carry out meets the requirements of the Regulation and guarantees the protection of your rights.

4. How long do we keep your data?

Your Personal Data will not be retained beyond the period strictly necessary for the purposes set out in the Policy and in accordance with applicable laws and regulations. In this respect, Personal Data used for the purpose of responding to your requests for information and contact are kept for three (3) years from the last exchange with you.

Personal Data used for commercial prospecting and communication purposes are kept for a maximum period of three (3) years from the end of the contractual relationship or the last exchange with you. Personal Data used for recruitment purposes are kept for two (2) years from the last exchange with the unsuccessful candidate, unless the latter agrees to a longer retention. Your Personal Data is deleted when the above retention periods expire. However, it may be archived beyond these periods for the purposes of research, the establishment and prosecution of criminal offences for the sole purpose of making your Personal Data available to the judicial authorities, if necessary.

5. Is your Personal Information transferred outside the European Union?

We do not transfer your Personal Information outside the European Union.

6. How is your Personal Information protected?

We take appropriate technical and organisational measures to ensure that Personal Data is protected against unauthorised access or modification, disclosure, loss or destruction. If we use a service provider on our behalf, we ensure that the service provider complies with its security obligations prior to disclosing your Personal Information.

7. What are your rights and how to exercise them?

In accordance with the Regulation, you have the following rights with respect to your Personal Data:

• A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible manner about how your Personal Data is processed. You also have the right to obtain (i) confirmation that Personal Data concerning you is being processed and, if applicable (ii) access to and a copy of such Personal Data.
• A right of rectification: you have the right to obtain rectification of inaccurate Personal Data concerning you. You also have the right to complete incomplete Personal Data concerning you, by providing an additional declaration. If you exercise this right, we undertake to communicate any rectification to all recipients of your Personal Data.
• A right to erasure: In some cases, you have the right to have your Personal Data erased. However, this is not an absolute right and we may, for legal or legitimate reasons, retain your Personal Data for a period of time in accordance with the Regulation.
   A right to restrict processing: in some cases, you have the right to restrict the processing of your Personal Data.
• A right to portability: you have the right to receive the Personal Data we have collected about you, in a structured, commonly used and machine-readable format, for your personal use or for transmission to a third party of your choice. This right only applies where the processing of your Personal Data is based on your consent, the performance of a contract or where such processing is carried out by automated means.
• A right to object to processing: you have the right to object at any time to the processing of your Personal Data for processing based on our legitimate interest, on a public interest mission or carried out for commercial prospecting purposes. However, this is not an absolute right and we may, for legal or legitimate reasons, retain your Personal Data for a period of time in accordance with the Regulation.
• The right to withdraw your consent at any time: you may withdraw your consent to the processing of your Personal Data where such processing is based on your consent. Withdrawal of consent does not affect the lawfulness of the processing carried out prior to such withdrawal.
• The right to lodge a complaint with a supervisory authority, including the Commission Nationale de l’Informatique et des Libertés: you have the right to contact your data protection authority to complain about our personal data protection practices.
• The right to give instructions regarding the disposition of your Personal Data after your death: you have the right to give us instructions regarding the use of your Personal Data after your death.

To exercise these rights, you may contact us at dpo@geh.aero We may require proof of your identity to exercise these rights.

8. Modification and application of the privacy policy

We may change this Policy from time to time, in particular to comply with any regulatory, legal, editorial or technical developments. If we do so, we will change the “last updated” date and indicate the date the changes were made. In the event of a substantial change, we will, where possible, inform you directly of the changes made. You should check this page regularly for any changes or updates to our Policy.

9. Contact

If you have any questions about this Policy, you can contact us by sending an e-mail to dpo@geh.aero.