In the framework of the entry into force on 25 May 2018 of the European regulation of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free circulation of that data (“the GDPR”), the La Belle Etoile1 company, as the entity “responsible for processing”2 in the sense of the GDPR, drafted this charter on the protection of personal data to inform you of your rights and obligations with regard to the legislation in force.
The purpose of the GDPR is to protect natural persons with regard to processing3 personal data, a basic right the respect of which is an integral part of the La Belle Etoile company’s values and ethics.
The protection granted by the GDPR applies to natural persons located on the territory of the European Union, independent of their nationality or place of residence, with regard to the processing of their personal data.
This charter aims to inform you of the commitments La Belle Etoile has made to the GDPR and the protection of your collected and processed personal data.
II. THE NATURE OF THE DATA COLLECTED UNDER GDPR
The data collected and processed concern any information relating to an identified or identifiable natural person: an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (the “data”); The collected and processed data are those that you have voluntarily sent us.
III. THE PURPOSES OF PROCESSING PERSONAL DATA
The data are collected so that you can receive news about the EuropaCity project.
La Belle Etoile will not take any automated decision on the basis of your data, including profiling4.
IV.THE ADDRESSEES OF PERSONAL DATA
The data we collect from you is processed by the Communication Department on French territory.
No data will be transferred to countries outside the European Union.
We maintain a high level of data protection and confidentiality.
However, you are hereby informed that your data may be disclosed in application of a law or a regulation, by virtue of a decision by a competent regulatory or legal authority or, if necessary, to protect the rights and interests of La Belle Etoile.
VI. LENGTH OF TIME THE DATA ARE KEPT
The data are stored by the host of the site of SendInBlue, a simplified public limited company registered at the Paris Commercial and Companies Registry under the number 498 019 298 – head office 55 rue d’Amsterdam, 75008 Paris, telephone 08 92 97 63 40, and kept until they are no longer needed for the purposes for which they were collected or processed.
VII. RIGHTS GRANTED TO THE PERSONS CONCERNED
You have the right to ask La Belle Etoile to access, rectify or delete your personal data and to limit or oppose their processing and portability. The legislation on collecting personal data guarantees you the following rights:
a) Right of access
You have the right to obtain from La Belle Etoile the confirmation that your personal data have or have not been processed.
b) Right of rectification
You have the right to obtain from La Belle Etoile the rectification of your personal data that are inaccurate.
c) Right of deletion (“The right to be forgotten”)
You have the right to obtain the deletion of the collected data. La Belle Etoile agrees to delete data in the following cases:
- The personal data are no longer needed with regard to the purposes for which they were collected or processed in another way;
- The person whose data were collected withdraws the consent on which the processing is based;
- The personal data have been illicitly processed;
- The person whose data were collected opposes the processing and no legitimate, imperious grounds exist to process them;
- lThe personal data must be erased to comply with a legal obligation provided for in French or European Union law.
d) Right to restrict processing t
You have the right to obtain from La Belle Etoile the restriction of the processing of your data if any of the following cases apply:
- The person concerned contests the personal data’s accuracy during a period allowing La Belle Etoile to verify it;
- The processing is illicit and the person concerned opposes their deletion and instead requests the restriction of their use;
- La Belle Etoile no longer needs the personal data for processing but the person concerned still needs them to bring to bear, exercise or defend rights in a court of law;
- The person concerned opposes the processing if the verification of the legitimate reasons pursued by La Belle Etoile prevail over those of the person concerned.
e) Right of opposition
You have the right to oppose the processing of your personal data at any time. In that event, La Belle Etoile will no longer process your personal data unless it can demonstrate legitimate and imperious grounds for processing that prevail over your interests, rights and freedoms or to bring them to bear, exercise or uphold them in a court of law. You have the right, at any time, to oppose the processing of your personal data for canvassing purposes, including profiling, if it is used for such canvassing. In that event, your personal data will not be processed for that purpose.
f) Right to data portability
You have the right to receive the personal data you sent us in a structured, commonly-used, computer-readable format, and to transmit them to another personal data processor, without La Belle Etoile preventing you from doing so, when the processing is:
- Based on consent
- Done with automated processes
If you exercise your right of data portability, you have the right to obtain that the personal data are directly transmitted from one data processor or another, if technically feasible.
This right does not apply to processing that is necessary for the execution of a mission in the public interest or relating to the exercise of public authority with which La Belle Etoile is invested.
VIII. How to exercise your rights
You can exercise the aforementioned rights to protect your personal data by e-mailing a request to firstname.lastname@example.org .
As project manager, La Belle Etoile agrees to inform you of measures taken after a request is made as soon as possible and in any case within one month after it is received.
If necessary, this period can be extended by two months, considering the complexity and number of requests. You will be informed of the extension and the reasons for the postponement within one month after the request is received.
IX. Explicit consent
Since 25 May 2018, the processing of personal data has been authorised only if the person concerned gives explicit consent. You may withdraw your consent at any time. Withdrawal of consent does not compromise the licitness of the consent-based processing done beforehand.
1 – La Belle Etoile, a subsidiary of Immochan and Wanda Culture Europe, which are proposing the EuropaCity project –
2 – La Belle Etoile, a non-listed company with a capital of €1,000, Paris Commercial and Companies Registry 821 682 044, head office 9 avenue de Flandre 75019 Paris- Tel 01.77.51.00.00 – email@example.com
3 – Article 4.2 of the GDPR: ““Processing” shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.
4 – Article 4.4 of the GDPR – ““Profiling” shall mean any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”.