Adexcel Group, acting as data-controller, per European Regulation No. 2016-679 dated 27 April 2016 and the amended "Informatique et Libertés" law dated 6 January 1978 (hereinafter, together, the "Regulations"), places great importance to the protection of personal data and privacy.
The purpose of this policy (the "Policy") is to inform you, in accordance with the Regulations, about our practices regarding the collection, use and sharing of personal information provided through our website, adexcel-group.com (the "Site").
This Policy applies only to the processing of personal information that may, directly or indirectly, identify, or make Site Users identifiable (hereinafter "Personal Data"). Site Users may include, but are not limited to, ordinary users, prospects, customers, applicants for positions within the Group (hereinafter "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, 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.), (iii) data related to your browsing activity on our Site.
2. Why do we process your Personal Data and on what legal basis?
We use your Personal Information to:
- Carry out commercial prospecting operations ;
This processing is based on our legitimate interest in promoting the Platform to the extent that you have voluntarily provided this information on our form and have informed yourself of its purpose. You can object to it at any time and we do not keep this information for more than three (3) years after our latest exchange with you
- Respond to your requests for information and contact through our Site;
This processing is in pursuit of our legitimate interest in communicating with you via our Platform by responding to your requests.
- 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 IT security of the Site and your Personal Data, (ii) compliance with our legal security obligations, and/or (iii) the establishment, exercise and/or defence of legal claims.
- 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 our Site’s functionality and your navigation convenience.
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 pass it on?
- Personal data transferred to authorities
In accordance with the regulations in force, your Personal Data may be transmitted to the governing authorities, at their request, or at the request of rightful claimants, and, in particular, to judicial officers in the case of a search for perpetrators of offences committed on the internet.
- Personal Data transferred internally
The Personal Data collected and processed are transmitted to our staff, our accounting, IT, and communications departments, and potentially to any and all internal department of Adexcel Group.
- Personal data transferred to our service providers
We work in close collaboration with third-party companies that provide the IT services necessary for the Site’s proper operation (database-management, hosting, storage, maintenance, etc.). The OVH host servers 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 only 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 communications purposes are kept for a maximum period of three (3) years from the last exchange with you. Your Personal Data is deleted when the above-mentioned retention periods expire. Nevertheless, they may be archived beyond these periods for the purposes of research, and/or the establishment and/or prosecution of criminal offences with the sole aim, if necessary, of making your Personal Data available to the judicial authorities.
5. Is your Personal Data transferred outside the European Union?
We do not transmit your Personal Data outside the European Union.
6. How is your Personal Information protected?
We take appropriate technical and organizational measures to ensure that Personal Information is protected against unauthorized access or modification, disclosure, loss or destruction. If we use a service provider on our behalf, we ensure that the service provider meets its security obligations prior to disclosing your Personal Information.
7. Is your Personal Data transferred outside the European Union?
We do not transmit your Personal Data outside the European Union.
8. 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, and 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 Data.
9. What are your rights and how can you 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 the rectification of inaccurate Personal Data concerning you. You also have the right to complete the Personal Data concerning you, by providing additional declarations. If you exercise this right, we undertake to communicate all necessary rectifications to all recipients of your Personal Data.
- A right to erasure: In some cases, you have the right to have your Personal Data erased. This is not an absolute right, and we may, for legal or other legitimate reasons, retain your Personal Data for a longer period of time consistent with the Regulation.
- A right to restrict processing: in certain cases, you have the right to have the processing of your Personal Data restricted.
- A right to portability: you have the right to receive the Personal Data we have collected about you, in a structured, commonly-used, machine-readable format, for your personal use or for transmission to any third-party of your own choosing. This right only applies when the processing of your Personal Data is based on your consent, on the performance of a contract or when 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 mission of public interest or carried out for commercial prospecting purposes. This is not an absolute right, and we may, for legal or other legitimate reasons, retain your Personal Data for a longer 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 when 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 complain to 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 about what to do with your Personal Information after your death: you have the right to give us instructions about how we can use your Personal Information after your death.
To exercise these rights, you can contact us at the following address: email@example.com. We may require proof of your identity to exercise these rights.
When you visit our site: https://www.adexcel-group.com/ (hereinafter the "Site"), cookies are placed on your computer, tablet, and/or any terminal used by you (hereinafter the "User"). This allows us (hereinafter the "Publisher") to analyse page-traffic and improve our Site’s operation. Cookies are used according to their nature and for the purposes indicated below.
2. What is a Cookie?
A cookie (hereinafter the "Cookie(s)") is a text file deposited on a terminal when visiting the Site or when viewing an advertisement. The purpose of a Cookie is to collect information related to the User's browsing activities on the Site and to send the User personalised services and content.
3. Identification of cookies
There are different types of cookies:
- Third-party and proprietary cookies
A Cookie is said to be "proprietary" or "third party" depending on the domain from which it originates. Proprietary Cookies are those installed by the website that the User is currently visiting. Third-party Cookies are Cookies installed by a domain other than the website the User is visiting. When a User visits a site and another entity installs a Cookie through that site, that Cookie is a Third-Party Cookie.
- Session cookies
These cookies allow website operators to track a User's actions during a browser session. The browsing session starts as soon as the User opens the browser window and ends when the User closes it. Session cookies are temporary in nature. Once the browser is closed, all session cookies are deleted.
- Persistent cookies
These Cookies remain on the User's device after closing the browser session and for the period of time specified by each of these Cookies. They are activated each time the User consults the website that generated them.
4. What types of cookies does the Publisher use and for what purposes?
Different types of cookies are used on the Site, for different purposes. Some are necessary to use the Site.
- Strictly necessary technical cookies
These cookies are necessary for the operation of the Site. They allow the User to use the Site’s main features. Without these Cookies, the User cannot use the Site in a normal fashion. These Cookies only require information from the User to be deposited on the User's terminal and do not allow any behavioural or identification tracking.
- Cookies for audience measurement
The audience measurement cookies help to establish statistics on the number of visitors and the use of the various elements that make up the Site (sections and content visited, paths). They enable the Publisher to improve the Site’s appeal and ergonomics.
- Advertising cookies
Advertising cookies make it possible to determine which advertisement to display according to the User's Site-browsing activity in order to limit the number of times an advertisement is displayed, to measure the effectiveness of an advertising campaign, and/or, , if the User has previously accepted such a possibility, to adapt advertisements based on the User's preferences.
- Social network sharing cookies
The Publisher offers Users the possibility of sharing editorial and/or other content published on the Site through social networks. These Cookies also allow the social networks to target their advertising offers. Social network Cookies are managed by the publisher of the social network. The User is invited to read the social network's cookie management policy on the concerned sites.
- How can the User manage Cookies?
User-management Cookie deposits
The User can manage the deposit of Cookies in the following ways:
- The deposit of strictly necessary technical Cookies is activated by default and cannot be deactivated by the User, as these Cookies are essential to the Site’s basic operations;
- The User may deactivate or activate the installation of Cookies subject to the collection of his/her consent (audience-measurement Cookies, advertising Cookies, etc.) via the information banner, but has the possibility of making changes whenever he/she wishes. Deactivation entails the refusal by the User of the deposit of the Cookies in question.
If the User activates the recording of Cookies on his terminal, the Cookies integrated in the pages and contents that he has consulted may be stored temporarily in a dedicated space in his terminal and will only be readable by the depositor.
The consent given by the User is only valid for a period of thirteen (13) months from the time of the first deposit in the User's terminal equipment following the expression of the User's consent.
If the User disables the storage of Cookies on his terminal or browser, or if he deletes those stored there, the User will be informed that his navigation and experience on the Site may be different from other Users who have activated the Cookies (non-personalised content).
This could also be the case when the Editor or one of our service providers cannot recognise, for technical compatibility purposes, the type of browser used by the terminal, the language and/or display settings and/or the country location of the terminal connected to the Internet.
Where applicable, the Publisher declines all responsibility for the consequences of any and all of the
Site’s degraded operations resulting from the User’s refusal of Cookies.
For more information
The User may connect to the Youronlinechoices site, offered by digital advertising professionals grouped together within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France. The User will thus be able to find out which companies are registered with this Platform and which offer the possibility of refusing or accepting the Cookies used by these companies in order to adapt the advertisements likely to be displayed on the User's terminal to the User's browsing activities: