Passman (hereinafter, “We” or “Us”) is committed to protecting and respecting your privacy.
This Policy (together with our Terms and Conditions of Use and any other related documents) sets out how we will treat any personal data about you that we collect from you or that you provide to us. Please read the following carefully to understand our position and practices regarding your personal data and how we will treat it. Your visit to one of our sites or use of one of our services constitutes your acceptance of, and consent to, the practices described in this policy.
For the purposes of the provisions of the Data Protection Act 1998 regarding the protection of personal data, the data controller is Passman, 4 rue Edouard Aynard, 69100 Villeurbanne.
Information we may collect from you
We may collect and process the following data about you :
1) The information you provide us with.
You may provide us with information about yourself when you fill out forms on our sites, when you communicate with us by telephone, email or by any other means, or when you use our services. The information you provide to us may notably include, your first and last names, mailing address, e-mail address and telephone number, as well as financial and relating to your credit card information, personal description and photograph.
The information we collect about you.
Each time you visit our site or use one of our services with one of our customers, we automatically collect the following information:
Technical information, including the MAC address of the device used to connect you to the Internet, your login information, your browser type and version;
Information about your visit, including the length of your visit.
2) Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or other services provided by us. In addition, we work closely with third parties (such as business partners and subcontractors for technical, settlement and supply services, advertising networks, statistical service providers, information retrieval contractors, market intelligence agencies, etc.), and we may receive information about you from them.
How we use your information
We use the information we hold about you as follows:
The information you provide us with. We will use these information:
- to fulfil our obligations under any contract between us and to provide you with information, products and services you request from us ;
- to provide you with information about other goods and services that we offer which are similar to those you have already acquired or about which you have sought information ;
- to provide you, or to enable members of the Orange group of companies and other users of the Orange brand to provide you, with information about goods or services that we think may be of interest to you ;
- to notify you of any changes to our service ;
- to ensure that the content on our site is displayed in the most effective way for you and your computer.
The information we collect about you. We will use these information:
- to administer our site and for internal operations, notably for purposes of troubleshooting, data analysis, testing, research, statistics and surveys;
- to improve our site to ensure that its content is displayed in the most effective manner for you and your computer;
- to enable you to use interactive features of our service, if you wish to do so;
- as part of our efforts to safeguard the security of our site;
- to measure or understand the effectiveness of the advertisements we provide to you (to you or to third parties), and to provide you with relevant advertisements;
- to make appropriate suggestions and recommendations to you and other users of our site regarding goods and services that may be of interest to you or them.
Information we receive from other sources. We may combine these information with the information you provide to us and the information we collect about you. We may use this information and the combined information above for the purposes mentioned above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, that is, with our subsidiaries and with our parent company and its subsidiaries, in accordance with the definitions contained in Section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties, including:
- our business partners, suppliers and sub-contractors for the execution of any contract concluded by us with them or with you ;
- advertisers and advertising networks who require the data to select and offer relevant advertisements for you or third parties;
- statistical and search engine service providers assisting us in improving and optimising our site.
We may disclose your personal information to third parties:
- in the event of a sale or acquisition by us of any business or assets, in which case we would have the right to disclose your personal information to the prospective seller or buyer of the business or assets concerned;
- if Passman or a substantial portion of its assets were to be acquired by a third party, in which case the personal data it holds about its customers would form an integral part of the transferred assets;
- if we were required to disclose or share your personal Information in order to comply with any legal obligation, or to enforce or apply our Terms and Conditions of Use, a relevant trademark license agreement or other contracts, or to protect the rights, property or safety of Passman, our customers or any third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Storage location of your personal data
If we provide you with a password (or if you choose a password) that allows you to access certain parts of our site, it is your responsibility to keep it confidential. Please do not disclose your password to anyone.
Unfortunately, the transmission of information via the Internet is not completely safe. Although we will make every effort to protect your personal data, we cannot guarantee the security of your data transmitted on our site, so any such transmission will be at your own risk. Once we receive your information, we will use strict security procedures and features to try to prevent unauthorised access.
You are entitled to ask us to refrain from processing your data for marketing purposes. In general, we will inform you (prior to any collection) if we intend to use or disclose your information to any third party for such purposes. You can exercise your right to avoid such processing by (un)ticking certain boxes on the forms we use to collect your data. You may also exercise this right at any time by contacting us at the following email address: email@example.com.
Our site may, from time to time, contain links to or from other websites belonging to our networks of partners, advertisers or affiliates. If you click on a link to any of these websites, please note that they have their own privacy policies and that we are not responsible for them. Please review those policies before submitting your personal data to those websites.
Access to the information
The law stipulates that you have a right of access to the information we hold about you. You may exercise this right of access in accordance with the terms of the law. Any request for access may be subject to payment of a lump sum processing fee to provide you with details of the information we hold about you.
Policy regarding the processing of personal data GRDP
Whether you are a customer, partner, supplier, shareholder or more generally a PASSMAN Group contact, you will find the answers to your main questions here. If any of them are missing, please do not hesitate to contact our Data Protection Officer (DPO) at firstname.lastname@example.org.
Who is the data controller?
This is PASSMAN CORP, whose registered office is located at 4 rue Edouard Aynard 69100 Villeurbanne, France, together with its controlled subsidiaries, including PASSMAN INSIGHT, PASSMAN and Screen Services.
Why do we process your data?
The purposes for which your data is processed depend on your relationship with the PASSMAN group. Their legal basis may be:
- your consent, in particular in your capacity as a prospect or contact in the broadest sense of the PASSMAN Group.
- the performance of a contract between you and the PASSMAN group; this is particularly the case if you are a tenant, customer, supplier or counterparty to any other transaction undertaken by PASSMAN.
- compliance with our legal or regulatory obligations: convening shareholders of our Group’s issuing companies to General Meetings, other obligations incumbent on them as listed companies, due diligence that we must carry out in the context of the fight against money laundering and the financing of terrorism, etc.
- our legitimate interest, particularly in the context of protecting our premises and their occupants (video surveillance).
Which data do we process?
You have a contractual relationship with a PASSMAN Group company.
We endeavour to inform you “as we go along” and within the framework of contracts aiming at or involving the processing of your personal data, of the exact nature of this data as well as your rights relating to it. Generally, this data is collected directly from you. For any further information, please do not hesitate to contact our DPO at the following address: email@example.com.
You are a contact in the broadest sense of the PASSMAN group.
The personal data that we process is primarily intended to send you information about the PASSMAN Group and to manage our relationship with you. If there is no other link between you and the PASSMAN Group, we will remove your personal data from our databases on request at firstname.lastname@example.org.
Specific information concerning the CRM set up by the PASSMAN Group
In order to facilitate the management of its contacts, the PASSMAN Group has set up a management tool known as “CRM” (Client Relationship Management).
As an internal or external “contact” in the broadest sense of our Group, we process your personal data using software developed by the PASSMAN Group .
As this processing is based on your consent, you may at any time request that the data contained in this tool be deleted (email@example.com ).
The data that we may be required to process are as follows:
These are your : surname(s) first name(s), civil capacity, name of your company, professional and/or personal address, professional and/or personal telephone number, professional and/or personal email, function, category of function, sector of activity, number of rooms in your establishment (if relevant), interest in a product, project deadline (if relevant), type of relationship you have with the PASSMAN Group (customer, tenant, supplier, director, shareholder, prospect, employee, etc.), or that of your company, your requests for invitations to events organised by the PASSMAN Group, information details about meetings you have held with our employees, that you may belong to an association or other professional circle and any information of a strictly professional nature concerning your relationship with our Group.
Generally speaking, this data has been collected from you directly or is public information.
Your personal data will be processed:
- in order to ensure effective and targeted communication between PASSMAN Group employees on the one hand and you or your company on the other
- to optimise the management of the group’s contacts within our teams
This data is for the exclusive use of the PASSMAN Group. The recipients are :
- authorised employees of the PASSMAN Group
- where applicable, certain authorised employees, acting as subcontractors of personal data on behalf of the PASSMAN Group. Your personal data may be transferred outside the European Union in accordance with the regulations in force. Under no circumstances will they be the subject of commercial transactions with third parties.
Policy for the retention of your data in the CRM :
- we delete your data, within our tool, within a maximum of 90 days following your request.
- we carry out annual campaigns to ensure the reliability of your data
You are a shareholder of a PASSMAN Group company (or represent a shareholder)
We process your personal data in order to send you all the documentation to which you – or the company you represent – are entitled or request in your capacity as shareholder, to meet our legal and regulatory obligations and to monitor the composition of our shareholder base.
This personal data consists of your surname(s) (of birth or customary use), first name(s), date and place of birth, professional and/or personal telephone number, professional and/or personal postal address, professional and/or personal e-mail address, number of shares and voting rights held.
Who are the recipients of your personal data?
They are :
- authorised personnel of the PASSMAN Group
- duly authorised service providers, for whom the PASSMAN Group ensures that they have a security and confidentiality policy that complies with regulations
- where appropriate and at their request, competent administrative or judicial authorities.
Under no circumstances will your personal data be the subject of commercial transactions with third parties.
If they were to be transmitted outside the European Union, we would ensure compliance with the regulations in force for this type of transfer.
What are the retention periods ?
Your personal data will not be kept in a form that allows your identification for longer than the time required in light of the purposes for which it is processed and compliance with our contractual, legal and regulatory obligations.
What are your rights ?
- You may at any time request further information on the processing of your personal data.
- You have the right to access, rectify and carry your data.
- You have the right to request the deletion of data concerning you or a limitation of their processing, as well as the right to object to the processing of such data.
- Where the processing has your consent as a legal basis, you have the right to withdraw your consent at any time.
- You have the possibility to lodge a complaint with a supervisory authority.
- For any request, please contact the Data Protection Officer: firstname.lastname@example.org.
Ensuring the security of your data is important to us
The PASSMAN Group endeavours to implement the technical and organisational measures necessary to ensure the security of your personal data in order to protect it from intentional or unintentional manipulation, loss, destruction or unauthorised access. In particular, we make the prevention of cyber threats one of our priorities. PASSMAN Group employees are authorised to access your data under strict supervision and differentiated according to their duties and are bound by confidentiality clauses, as are our external service providers.
Evolution of our processing policy
This policy reflects our current standards, which are subject to change. Any changes will take effect upon publication of the last updated version of this policy.