Charte de protection des données personnelles des interlocuteurs de Shan (Privacy policy)

PURPOSE OF THE POLICY

In accordance with regulations applicable since 25 May 2018 (RGPD) and the law in force since 20 June 2018 (I&L), Shan is responsible for the processing of personal data collected and held in the conduct of its activities, and is therefore under the obligation to inform its interlocutors of the policy implemented to protect said data.

The purpose of this policy is to inform the persons concerned (customers, prospects, partners, service providers, journalists, influencers, analysts, investors) of their exposure and their rights in this matter. The full policy is therefore accessible to each, by request as well as via the company’s website (www.shan.fr).

NATURE OF THE DATA

The company is called upon to collect and store data enabling the identification, location and, by the same token, the contact details and tracking of its regular or occasional interlocutorse, i.e. data relating to their civil status (first name, surname, age, sex, nationality), their access (e-mail and postal addresses, telephone numbers) and their curriculum vitae (function, diplomas, expertise, references, interests, distinctions, achievements). It may also store sensitive data (opinions, trade union membership, political or philosophical affiliations) if the persons concerned explicitly authorise it or if contractual, regulatory or legal provisions expressly require it.

The company collects this personal information either directly, when drawing up contracts with its clients and service providers, during visits to its website and its pages on social networks, or as part of its canvassing and representation activities, or indirectly, through the use of private or public databases (Hors Antenne files for journalists and institutions, Sfaf directories and the Centre de Professions Financières for Analysts and investors, Communication & Entreprise, Cliff and Stratégies guide for communicators, Linkedin website and Who’s Who edition for all audiences).

COOKIE MANAGEMENT

Shan automatically collects information about you using cookies to save your language preference on the Site.

Cookies are alphanumeric identifiers transferred to your computer’s hard drive via its Internet browser, enabling Shan to recognise the browser and thus offer you more innovative and attractive features.

However, you can set your computer to block them from being saved.

These cookies are treated in respect of the legal retention period of thirteen months stipulated by the CNIL. They are strictly necessary for the provision of online communication services and are exempt from consent when you visit the Site.

USE AND PURPOSE OF DATA COLLECTED

The company uses the personal data in its possession for communication and promotional purposes, on behalf of its clients (creation of files, sending press releases, requesting information, organising interviews, inviting to information meetings, opinion polls), and, to a lesser extent, for canvassing purposes, on its own behalf (client outreach and recruitment).

The company makes use of this information when doing so complies with legislation in force and serves a legitimate interest (normal business), meets a legal obligation (execution of a contractual commitment, application of a regulatory provision) or results from an ad hoc decision (consent of the person concerned).

DATA TRANSMISSION

The company demands that its employees, sub-contractors and partners use the personal data under its control exclusively for professional purposes and that they systematically take appropriate measures and precautions to preserve their confidentiality and integrity. It also provides these employees, sub-contractors and partners with a document to this effect when they enter into a relationship.

The company may be required to directly or indirectly transfer personal information to third parties, namely service providers in order for the latter to perform their duties (management of electronic messages, backup of computer files, processing of accounting, legal and social files); in such cases, the company verifies the security and proper use of the data thus entrusted. Shan may also be called upon to share this information with public organisations or administrative authorities where compelled to do so by legal or regulatory obligations (crime prevention, defence of rights in court, conduct of legal proceedings).

The company ensures that the personal data  it collects is not transferred outside the European Economic Area. If this is not the case, it undertakes to guarantee the protection of this data by means of a transfer framework based on standard contractual clauses if the recipient country concerned cannot guarantee a level of privacy protection consistent with the decisions of the European Commission.

DATA PROTECTION

The company has put in place administrative, material and technical security measures in order to protect the personal data in its possession against the risks of deterioration, loss, theft, misappropriation, falsification and unauthorised use.

DATA RETENTION

The company undertakes to keep personal information for as long as it is necessary and useful for the performance of the tasks for which it is collected, unless the legislation in force imposes a different retention period.

DATA RIGHTS

Under current regulations, the company’s interlocutors retain a number of rights over personal data held about them, with a few restrictions and exceptions. Interlocutors can access the data and obtain a copy (right of access), obtain details regarding how data is processed (right of information), request corrections or additions to the data (right of rectification), and request the deletion of the data (right to erasure). They may furthermore require that use of their data be restricted and thus authorise, for example, only their retention (right of restriction), as well as recover the data in a customary format and transmit these to third parties (right of portability), request that use of their data cease, subject to existing exceptions and restrictions (right of objection), make the processing of their data conditional on their consent, and withdraw authorisation for use as they wish (right of withdrawal), as well as specify and regulate the use of the data after their death (droit de suite).

The rights described above can be exercised at any time by sending an e-mail to dpo@shan.fr

Interlocutors are furthermore entitled to complain to the Commission Nationale de l’Informatique et des Libertés (CNIL) in the event of a breach of regulations concerning the protection of personal data, and may contact the CNIL by the usual means of communication to do so (3 Place de Fontenoy – TSA 80715 – 75334 – Paris Cedex 07 / 01 53 73 22 22) or via the online complaint service (www.cnil.fr).

CHANGES TO THE POLICY

Modifications to the policy will be the subject of a specific communication if necessary.

QUESTIONS OR REMARKS ON THE POLICY

Questions and comments concerning this Data Privacy Policy should be addressed to François-Xavier Dupont (fx.dupont@shan) or Annick Rousseau (annick.rousseau@shan.fr).

[1] Cookies are temporary files deposited during the consultation of websites and stored on the hard disks of visitors’ computers or smartphones. They do not identify visitors personally, but enable recognition of the terminals used and the collection of information on the navigation carried out on said terminals.