PERSONAL DATA PROTECTION POLICY
Segula Holding, a limited liability company,
incorporated under the laws of France, registered under the number 343
166 393 R.C.S. Nanterre, with a registered Office located at 19 rue
d’Arras, 92000 Nanterre (hereinafter referred to as the “Segula Technologies
Group”) collects and processes personal data (as defined below) as part of its
activities.
This “Personal Data Protection Policy” (the “Policy”)
is intended to inform all the individuals affected by the processing, of the
way in which the Segula Technologies Group collects and uses their Personal
Data and of the means that enable them to control this use.
By this policy, the Segula Technologies Group, responsible
for the processing, undertakes to process your personal data with all necessary
care and exclusively for the legitimate purposes for which they were collected,
in accordance with applicable regulations.
This policy applies to the hexplora.io website
and its subdomains.
1. DEFINITIONS
“Personal Data” refers to information relating to an
identified or identifiable natural person. A person is “identifiable” when they
can be identified, directly or indirectly, by reference to an identification
number or to one or more elements that are specific to their identity.
“Personal Data Processing” refers to any
operation or set of operations that is carried out using personal data,
regardless of the method used (collection, recording, organisation, storage,
adaptation, modification, extraction, consultation, use, disclosure by
transmission, dissemination or any other form of provision, alignment or
combination, blocking, deletion or destruction, etc.).
2. THE DATA
COLLECTED BY THE SEGULA TECHNOLOGIES GROUP
The Segula Technologies Group makes sure to collect
and process only relevant Personal Data, that is sufficient, not excessive and
strictly necessary in order to achieve previously specified purposes.
The Segula Technologies Group is committed to obtain
the consent of those concerned as required and to inform them of the processing
of their Personal Data and of their rights.
In this context, the Segula Technologies Group may
collect and process the following Personal Data:
-Identification: surname, first name, title, function,
alias, social network name,
-Information: telephone N°, email and postal address,
-Professional life: universities, schools, degrees and
courses,
-Technical data: identification data (IP), connection
data (including logins).
The Segula Technologies Group collects the
aforementioned Personal Data:
-During users’ navigation on the Website
-When the user applies for job opportunities (data
collected through our service providers)
-When the user contacts the Segula
Technologies Group via our contact forms.
3. PURPOSE OF
THE PROCESSING CARRIED OUT BY THE SEGULA TECHNOLOGIES GROUP
The Processing carried out by the Segula Technologies
Group meets explicit, legitimate and particular purposes.
Personal Data may be processed for the following
purposes:
-To analyse user navigation and to enhance their
experience
-To respond to any queries they may raise via our
contact forms
-To process applications for our employment
opportunities via our service providers
-To send users commercial information regarding the
Segula Technologies Group.
Depending on the purpose for which the data is
collected, the legal basis for the data processing may be:
-The consent of the subject of the data Processing,
-The Segula Technologies Group’s legitimate interest,
which may include:
-Establishing and maintaining a lasting relationship
with suppliers, customers and any other person interested by the Group’s
activities,
-The improvement of the Group’s websites,
-Securing the Group’s tools in order to
ensure the protection and security of the tools used.
4. RECIPIENTS
OF THE COLLECTED DATA
The Segula Technologies Group may communicate the
Personal Data collected to a third party if the law requires it or if the Group
believes in good faith that disclosure is reasonably necessary in order to
comply with a legal process (e.g. a warrant, subpoena or other court order) or
to protect the rights, property or personal safety of the Group, our customers
or the public.
The Personal Data may also be disclosed to a third
party after obtaining the consent of the subject of the Processing.
The Segula Technologies Group may also share the
Personal Data collected with a third party in order to provide website users
targeted marketing or advertising offers. The Group also works with third party
businesses that may have access to your Personal Data:
-Subcontractors used by the Segula Technologies Group
for technical services and analytics providers
-Providers of HR software for talent and
training management
5. DATA
RETENTION PERIOD
The Segula Technologies Group stores the Personal Data
for as long as is necessary in order to achieve the purposes for which they
were collected.
The Segula Technologies Group may
however store Personal Data for a longer period in order to comply with legal
or regulatory obligations or even for statistical or historical purposes,
including cookies and other tracers stored on your device in accordance with
the legal obligations and recommendations issued by the authorities.
6. STORAGE AND
TRANSFERS OF PERSONAL DATA
The Personal Data collected by the Segula Technologies
Group is stored in France.
In order to accomplish its missions, the Segula
Technologies Group may be required to disclose the Personal Data collected to
its subsidiaries, service providers, customers or other third parties.
Where Personal Data is disclosed by the
Segula Technologies Group outside of the European Union, the Group undertakes
to first verify that the entities outside of the European Union, including the
Group’s subsidiaries located outside of the European Union, offer an adequate
level of protection under EU law. The location of the Segula Technologies Group
companies is available on the website https://www.hexplora.io
7. THE RIGHTS
OF PERSONAL DATA SUBJECTS
The Segula Technologies Group has introduced
appropriate Personal Data safeguards to ensure that the Personal Data is used
in accordance with the purposes set out in section 3 above.
In accordance with the legislation regarding the
protection of personal data, the subjects of Personal Data processing have a
number of rights with regard to the collection and processing of their Personal
Data, namely:
-The right to be informed about how the Personal Data
is collected and processed in a concise, clear, understandable and easily
accessible manner.
-The right of access to Personal Data, which means
having the right (i) to obtain confirmation that Personal Data has or has not
been collected and processed (ii) to obtain access to this Data and a copy of
the Data once it has been collected.
-The right to rectify, update or delete incomplete or
inaccurate Personal Data,
-The right to restrict processing of Personal Data,
-The right to object at any time for specific reasons
to the processing of Personal Data by the Segula Technologies Group. However,
it should be noted that such objections may be refused for legitimate and
compelling reasons requiring further processing,
-The right to portability, which is the right to retrieve
the Personal Data collected by the Segula Technologies Group and to transfer it
to another processing body.
-The right to give instructions concerning the use of
Personal Data after the death of the subject.
For any questions relating to the
exercise of these rights, please send an email to the following address:
informatiqueetlibertes@segula.fr
8. COOKIES
The Segula Technologies Group may use cookies to
collect or store Personal Data.
When the user accesses the website, they are informed
of the presence of cookies. These cookies do not identify users but are
designed to record information regarding their navigation.
The social network cookies make it possible:
-To identify the user (connection),
-To assign and identify a session number,
-To optimise the effect of the page,
-To count the number of likes on Facebook.
The analytics cookies make it possible:
-To distinguish between users,
-To limit the rate of demand.
When the user navigates on the Group’s
website, the cookies are enabled by default and the data may be read or stored
locally. The user will be notified on their initial use and will therefore be
able to decide whether to accept or refuse. By continuing to use the websites,
the user expressly accepts the use by Segula Technologies of the aforementioned
cookies. The user may choose to configure their browser to automatically refuse
cookies. If so, some features and characteristics of the websites may not
function properly.
9. SAFETY /
PRIVACY
The Segula Technologies Group work to protect and
secure the Personal Data that has been disclosed to them, in order to ensure
its confidentiality and that it may not be distorted, damaged, destroyed or
disclosed to unauthorised third parties.
The Segula Technologies Group has taken measures of
physical, electronic and organisational protection to prevent any loss,
improper use, unauthorised access or diffusion, alteration or destruction of
the Personal Data. However, despite the efforts of the Segula Technologies
Group to protect the Personal Data, the Group cannot guarantee the
infallibility of this protection because of unavoidable risks that may occur
during the transmission of Personal Data.
As all Personal Data is confidential, its access is
limited to Segula Technologies Group employees who require access in order to
perform their mission. All individuals with access to Personal Data are bound
by a confidentiality obligation and expose themselves to disciplinary action
and/or other sanctions if they fail to meet these obligations.
Nevertheless, it is important for each
user to show vigilance to prevent any unauthorised access to the Personal Data
in their possession.
10. LINKS TO
THIRD PARTY WEBSITES
Job postings are linked to our HR software for talent
and training management. Hence, when a candidate is referred to this platform,
the processed and collected data conforms to our Personal Data Protection
Policy.
The Segula Technologies Group exercises
no control over the content of third party websites in terms of protection of
the Personal Data that these websites may collect. It is therefore the
responsibility of each user to inform themselves of the Personal Data
protection policies.
11. POLICY
CHANGES
The Segula Technologies Group may update
this Policy at any time in order to adapt it to applicable regulations. In such
an event, the date of the Policy update will be updated and will indicate the
date on which the changes were made.
12. CONTACT
For any question regarding this Policy or for any
request concerning the Personal Data collected by the Segula Technologies
Group, please send an email to the following address:
informatiqueetlibertes@segula.fr.