DATA PROTECTION POLICY
ActivSkeen is dedicated to protecting your Personal Data as a priority. We are committed to ensuring the transparency of our processing of any Personal Data that we gather, and to providing you with all the relevant information concerning the processing of your Personal Data that may be gathered on our https://activskeen.com web site (the “Web Site”).
ActivSkeen (“we”, “us” or “ActivSkeen”) may gather and process your Personal Data when you visit this Web Site. As the data controller, ActivSkeen is responsible for the Personal Data that you provide to us. In order to protect your privacy and your Personal Data in the most effective way possible, we have appointed a data protection officer. This person, who is the sole point of contact of the regulator, ensures that we process your data in keeping with the applicable laws.
You may contact our data protection officer at the following address: email@example.com.
ActivSkeen may be contacted by post at 280 Avenue Napoléon Bonaparte, 92500 Rueil-Malmaison France, by telephone on +33 1 47 76 42 62, or by means of the contact form found on this Web Site.
We undertake to ensure the highest possible level of protection for the persons whose personal data we process (the “Data Subjects”). The protection of personal data, and in particular the personal data of our clients, is all the more important to us given our professional secrecy obligations.
We undertake to comply at all times with the applicable regulations when processing personal data. For instance, we will always comply with the following principles:
- We will process your Personal Data lawfully, in good faith and transparently;
- We will gather your Personal Data for specific, explicit and legitimate purposes and will not process it in a way that is incompatible with these purposes;
- We will ensure that the Personal Data that is processed is appropriate, relevant and limited to what is necessary in light of the purposes for which it is processed;
- We will do our best to ensure that the Personal Data is accurate, and if need be, up-to-date. We will take all reasonable measures to ensure that any Personal Data that is unsuitable for the purposes for which it is being processed, is erased or rectified immediately;
- We will keep your Personal Data in a form that enables you to be identified only for the duration needed in light of the purposes for which it is being processed;
- We will process your personal data in such a way as to ensure that this data is protected by a suitable level of security.
In concrete terms, these commitments mean that:
- We will respect your privacy rights;
- We will ensure that the protection and the security of your personal data lie at the heart of our concerns;
- We will assess each processing operation by factoring in the principles of data protection, so as to comply with the principle of privacy by design;
- We will not use your personal data for purposes that are not brought to your attention;
- We will neither share your personal data nor sell it to third parties;
- We undertake to secure and to protect your personal data. To that end, we will only work with trusted partners;
- We will respect your rights and will do our best to comply with your requests, provided that these are reasonable.
You may visit our Web Site without disclosing any Personal Data. However, should you wish to access certain parts of our web sites and/or to make use of specific information or services, we may gather your Personal Data which we shall process for the purposes that are mentioned below.
“Personal data” means information relating to a natural person who is identified or identifiable, such as an e-mail address, your family name and first name, your IP address, etc.
We gather your Personal Data via the contact form of this Web Site and by other means. In some cases, we gather your Personal Data directly from you. In other cases, your Personal Data may be disclosed to us by a third party.
The personal data that we may process comprises:
- identification data, such as your family name and first name, your e-mail address;
- data from job applications, such as your CV, your diplomas, your professional experience, if you wish to apply for a position at ActivSkeen.
Some information concerning the activity of the users of this Web Site may be gathered automatically. This information is destined for ActivSkeen alone, and may be used as a basis for studies, statistics, audience measurements and other analyses with the aim of improving and developing the Web Site. Moreover, we may process your personal data:
- to enhance our Web Site and keep it up-to-date, and to ensure its security;
- to conduct customer satisfaction surveys;
- to manage the discussion forums that you may take part in;
- to manage recruitment, when you apply online for positions, such as on the emplois.vinci.com web site, or when you send us a spontaneous job application;
- to generate statistics and optimise the Web Site;
- to send out documents in response to requests posted on our Web Site;
- to transmit information concerning our company and its activity, to answer any queries received and to transmit information about the services on offer.
We always process your personal data in keeping with one of the following legal bases:
- when you have signed a contract with ActivSkeen, and the performance of this contract requires us to process your Personal Data, the legal basis for the processing of this data is the performance of the contract;
- where the processing of your Personal Data is necessary for the performance of pre-contractual measures taken at your request, the legal basis for the processing of this data is founded on these pre-contractual measures. This is for instance the case when you send us a job application, which requires us to assess your CV in order to take a decision concerning your application;
- where the processing of your Personal Data is necessary for us to pursue our legitimate interests, the legal basis for the processing of the data is founded on our legitimate interests. For instance, we may process your Personal Data to solicit you for business as this is in the legitimate interests of ActivSkeen;
- we may also process your Personal Data by invoking any of the other legal bases listed in the applicable laws and regulations.
PERIOD OF RETENTION
ActivSkeen will only keep your Personal Data for the duration that is necessary in light of the purposes for which it is being processed, in accordance with the applicable law. Thus, the period of retention of your Personal Data will depend on the purpose for which it is processed, in keeping with the following rules of thumb:
- customer relationship management: 5 years following the end of the relationship with the client;
- invoicing: 10 years following the end of the trading year involved;
- accounts: 10 years following the end of the trading year involved;
- management of job applications: 2 years following the last contact with the applicant;
- management of the relationship with service providers: 5 years following the end of the relationship;
- replying to requests made to us via the contact form of the Web Site: for the duration needed to answer the request involved, or for one of the durations shown above if your request concerns one of these purposes.
TRANSFERS OF PERSONAL DATA
Your Personal Data will be stored in the European Union (EU) and the European Economic Area (EEA) by ActivSkeen and its trusted service providers. However, in some cases, your Personal Data may also be transferred to a country outside the EU and the EEA for specific data processing operations.
In case of a transfer of your Personal Data outside the EU or the EEA, we will ensure that the data is transferred securely and in keeping with the applicable rules and regulations. If the country where the data is transferred does not feature protection comparable to that of the EU, we resort to “appropriate or suitable guarantees”.
These appropriate or suitable guarantees are a means of ensuring that the protection of your Personal Data is guaranteed even when it leaves European territory. The appropriate guarantees may for instance involve resorting to the standard contractual terms adopted by the European Commission.
We will inform you on a case-by-case basis about any planned transfer of your Personal Data to a third country, about the existence or non-existence of an adequacy decision by the European Commission, and where applicable, about the reference to the appropriate guarantees and the means of securing a copy thereof or the place where they are available for perusal.
THE RECIPIENTS OF YOUR PERSONAL DATA
We may transfer your Personal Data to our service providers that are in charge of:
- hosting operations (OVH);
- maintenance operations.
We may also be compelled to disclose your Personal Data by laws, court rulings and/or requests from governmental or public authorities, inside or outside your country of residence. We may also disclose your Personal Data if we determine that, for reasons of national security, or for the purposes of the application of a law or imperative public need protected by law, a disclosure is necessary or appropriate.
We may also disclose your Personal Data if we determine in good faith that the disclosure is reasonably necessary to protect our rights by resorting to the available remedies, applying our General Terms and Conditions, investigating fraud or protecting our operations or our users.
Finally, ActivSkeen may restructure its worldwide activities at any point in time. These measures may lead us to disclose Personal Data to existing or potential clients or to receive Personal Data from potential sellers. We will always ensure adequate protection of the confidentiality of any Personal Data that is disclosed as part of this type of transaction.
You have the right to secure confirmation from us that your Personal Data is or is not being processed (right of access). Should this be the case, you may access your Personal Data and obtain information such as the purpose of the processing of this data, the categories of Personal Data involved, etc.
You may also request that your Personal Data be rectified or erased.
You also have the right to oppose the processing of your Personal Data or to request that its processing be limited. You moreover have the right to request that your personal data be sent to you in a structured and standardised format, if the conditions required to exercise this right are met.
Should you wish to exercise these rights, please send an e-mail to our DPO, who can be contacted at the following address: firstname.lastname@example.org.
In order to enable us to process your request to your satisfaction, you must prove your identity by any suitable means. Should we have any doubts in this respect, we may ask you for additional information, such as the transmission of a copy of your identity card, signed by you.
We will do our best to respond to your requests to your satisfaction. Whatever our answer, we undertake to respond within a timescale of one month, but our response times may be extended by two more months depending on the complexity and the number of requests involved.
If, for any reason whatsoever, you believe that our answer is not satisfactory, please note that you may file a complaint with France’s CNIL [data protection watchdog].
ActivSkeen uses various technological and organisational security measures to protect the Personal Data that we gather, use or transfer against loss, wrongful use, tampering or destruction.
However, ActivSkeen hereby disclaims liability for the security of transmissions of Personal Data over the Internet.
EXTERNAL WEB SITES
Our web sites may feature links to external web sites.
ActivSkeen does not provide any warranty nor does it make any representation concerning these external web sites.
MODIFICATION OF OUR POLICY
This policy was last updated on 06/10/2020.
We may modify this policy from time to time to ensure that it remains in line with the latest technological developments, common practice in our trade and the applicable regulatory requirements, or for other reasons.
Should we need to make major changes to our Policy, we will publish a clearly visible announcement on the home page of the Web Site before the modification becomes effective.