In this privacy policy, "FIRST", "We", "Us" and "Our" refer to the FIRST group and/or one or more of its member companies which may process your personal data. Each member company of the FIRST group is a separate legal entity. There is a single data controller for your personal data for all the companies, who can be contacted by email at dpo@groupefirst.com
This privacy policy of First concerns the protection of personal data. It applies to personal data as defined in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, applicable from 25 May 2018 "the General Data Protection Regulation" (hereinafter "GDPR")
Personal data means any data concerning an identifiable User. Any natural person who can be identified, directly or indirectly, on the basis of the information collected about them in the context of the provision of a Service by FIRST is deemed to be identifiable. The term Service (hereinafter referred to as "Service(s)") applies to any website, application, tool or any other product offered by FIRST and intended to be used by a User, in which this Privacy Charter is referenced, regardless of the way in which you access or use the Service, including via mobile devices. The term User applies to persons who have used a Service provided by FIRST.
1. Scope
In this privacy policy, we provide information on how your personal data is collected, processed and used, as well as on your rights in relation to your personal data. Our document also sets out the information that we are required to provide to data subjects under the GDPR. The principles set out in this Privacy Policy will apply to all personal data that you provide to FIRST as well as to any personal data that we collect from other sources.
2. Collection of personal data
Personal data is generally collected in the context of our business relations. Personal data is gathered through multiple sources on our website, by email, by telephone, through our sales representatives or during an event.
Website:
- Online purchase
- Contact forms
- Document downloads
- Surveys/questionnaires
- Requests for information and customer feedback
- Cookies (see our cookie policy)
- Knowledge cycles
- Quick analyses
Email or post:
- Order
- Newsletters
- Invitations
- Customer satisfaction surveys
Telephone:
- Purchase
- Customer contact requests
- Requests for information
- Customer satisfaction interviews
In person:
- Sales appointment
- Meetings at events/trade fairs
- Purchase in a cash and carry
3. Personal data collected
Depending on the type of source, we collect:
- Your surname and first names
- Your title
- The name of your company, your position
- Your telephone number
- Your email address Your business and/or residential address
- In order to enable payments, credits or other transactions that you may enter into with us, your credit card or other account details
If you communicate with us, we will also collect the information you have provided to us.
On websites, we keep a record of traffic data that is automatically recorded by our server, such as your IP address, the URL visited before our site and the other pages visited. We also collect statistics on the site, such as the most viewed pages and the frequency of visits. We cannot identify a person from traffic data or site statistics unless you log in to your own account on the site.
4. Purposes for which we collect personal data
Users' privacy is protected by regulations. Under data protection regulations, FIRST is only authorised to use the personal data of its users if it has a valid legal basis. FIRST must ensure that it has one or more of the following legal bases:
- The performance of a contract (for example to process and fulfil an order or to open and manage a customer account)
- Compliance with a legal obligation (e.g. retention of invoices)
- Where this is in the legitimate interest of the efficient and lawful operation, development and improvement of First
- Where the user has given their consent.
A "legitimate interest" of First must not override the rights and freedoms of users. Examples of legitimate interests mentioned in the GDPR include fraud prevention, direct marketing and the sharing of data within a group of companies (such as First).
The company First collects and records personal data of its customers in order to carry out the following processing operations:
|
We will only use your personal data for the purposes set out in this policy, or for purposes reasonably compatible with the original purpose for which it was collected, or if there is another legal basis for further processing.
For processing operations requiring consent, the data subject has the right to withdraw their consent by sending a request by email to dpo@groupefirst.com You may also unsubscribe from our newsletters via the dedicated link in the email you have received.
5. Disclosure of your personal data
We share your personal data with your consent or where necessary to provide any product or service you may have requested.
We share your personal data with other members of the First group where necessary in connection with the purposes described in this privacy policy.
We will also share personal data with:
- Any company that would purchase or has purchased our assets, or a company whose structure or business we acquire;
- Service providers and processors who process it on our behalf, according to our instructions, in accordance with the contract;
- The competent authorities
In addition, your personal data may be shared for the following purposes:
- To comply with our legal obligations;
- To respond to legitimate requests from public authorities;
- To obtain legal advice from external lawyers and other professional advisers;
-
To establish, exercise or defend against a potential, actual or threatened dispute;
- To protect First, your vital interests or those of another person.
We ensure that appropriate measures are put in place to guarantee a high level of security and confidentiality when sharing personal data. If personal data is transferred outside the European Union, additional measures will be taken in accordance with the General Data Protection Regulation (GDPR).
6. Proportionality and relevance of the data collected:
The personal data collected is strictly necessary for the purpose pursued by the collection. The companies of the FIRST Group endeavour to minimise the data collected and to keep it accurate and up to date, while facilitating the rights of data subjects.
7. Marketing
Your personal data may be used for marketing purposes, which includes any communication concerning First products and services. Where your explicit consent is legally required in order to receive marketing communications, we will only send you such communications if you have given it.
We keep the contact details of individuals on our marketing lists until the individual unsubscribes. If you choose to unsubscribe, we may retain limited information sufficient to identify you so that we can honour your unsubscribe request.
You can contact us at any time to ask us to stop sending you marketing communications. If you wish to unsubscribe from mailing lists or subscriptions, you can also follow the "Unsubscribe" option provided in each email sent to you in order either to stop communications completely or to specify the types of communications that no longer interest you.
Limited retention period for personal data:
Personal data is kept for a limited period that does not exceed the period necessary for the purposes for which it was collected.
Data retention periods are brought to the attention of individuals and vary according to the nature of the data, the purpose of the processing, or legal or regulatory requirements.
Confidentiality / Data security:
We are committed to providing the highest levels of security for your personal data. We protect your information by taking appropriate technical and organisational measures against any unauthorised or unlawful processing and against any accidental loss, destruction or damage.
First has its IT and communication systems monitored by competent partners using various tools. The primary purpose of this monitoring is to protect First, its employees, its customers and its business partners.
Appropriate physical, logical and organisational security measures are in place to guarantee the confidentiality of data, and in particular to prevent any unauthorised access.
Your rights
Pursuant to Articles 14 to 22 of Regulation 2016/679 of 27 April 2016, any natural person using the service may exercise the following rights:
A right of access
A right to rectification,
A right to object to and to erasure of the processing of their data
A right to object to profiling
A right to restriction of processing,
A right to portability of their data
Finally, where First detects a personal data breach likely to result in a high risk to your rights and freedoms, you will be informed of this breach as soon as possible.
You can exercise these rights by sending a signed letter accompanied by a copy of an identity document to the following address:
FIRST
Data Protection Officer
4 rue Nicéphore Niépce, 91420 MORANGIS -France
or by email to the following address: dpo@groupefirst.com
We will respond to your requests in accordance with applicable legislation and internal policies. We may ask you to provide additional information to enable us to confirm your identity.
In exceptional cases, where we consider that your request is manifestly unfounded or excessive, we may charge you a reasonable fee. We will inform you in advance of the applicable fees.
If you have given your consent to the processing of your personal data, you may withdraw it at any time. This will not affect the lawfulness of processing prior to the withdrawal. Where we are required to retain your personal data for legal reasons, your personal data may not be processed further and will only be kept for the period required by law.
We respect your privacy and value the information you have provided to us. In drafting this privacy statement, we have borne in mind your privacy rights. However, if you consider that our processing of your personal data is not compliant, we would be grateful if you would contact us so that we can try to address your concerns. You also have the right to lodge a complaint with the competent supervisory authority, the Commission Nationale Informatique & Libertés for France, if you consider that the processing of your data is unlawful and infringes your rights.
8. Transfer of your information to third countries and international organisations
Before transferring personal data outside the European Union, we ensure that the recipient country or company provides appropriate safeguards for the processing of the personal data transferred and that data subjects have enforceable rights and effective legal remedies.
If you do not wish your personal information to be transferred to a country outside the European Community, do not communicate it to First. By providing your personal information to First, your consent is presumed.
9. Cookies
When you visit our websites, you can browse and access important information without revealing your identity. In order to improve our site, we use "cookies" to track your visit. A cookie is a small text file in alphanumeric format which is transferred to your browser by a web server and can only be read by the server that gave it to you. It cannot be executed as code or transmit viruses.
Most browsers are initially set up to accept cookies. You can manage cookies using various tools, including your browser settings. We invite you to consult the page https:\\ cookies to find out more.
10. Partner sites
If you click on a link from one of our websites that takes you to another site, this policy no longer applies. We are not responsible for the practices of other sites regarding the processing of your information. The use of your information by the owner of the website should normally be governed by the privacy policy of the site concerned, which we invite you to read carefully.
11. Changes to this privacy notice
We carry out a regular review of this privacy policy. When making changes to this policy, we will revise the "last updated" date. We encourage you to review this policy periodically to understand how First processes your personal data.
12. How to contact us
To contact us, if you have any questions about our privacy policy or about the information we hold about you, you can send an email to or by email to dpo@groupefirst.com or write to
First
"Data Protection Officer"
4, rue Nicéphore Niépce
91420 Morangis – France
Date of last update: 01 January 2020