Privacy policy and cookies

BeNomad cares about protecting the data and privacy of anyone accessing our digital ecosystem.

This page describes the types of web user personal data that may be collected by BeNomad as well how and the purposes for which such data may be used by BENOMAD and its subcontractors.

This Privacy and Data Protection Policy (hereinafter, the “Policy”) also provides you with important information regarding your rights and the protection of your personal data.

Your personal data is processed in accordance with current legislation and, in particular, European Regulation n°2016/679 of 27 April 2016 and the French Data Protection Act (Law n°78-17  “Informatique, Fichiers et Libertés” (Information, Files and Freedoms) of 6 January 1978 as amended.

In continuing to browse this web site (hereinafter the “site”), the site user acknowledges that, in accepting the website’s general terms of use, they have also read and agreed to this Policy.

1. Who is collecting the personal data (identity of the data controller)?

This site is managed by BENOMAD – Marina 7 – 1545 Route Départementale 6007 – 06270 VILLENEUVE LOUBET entered in the Trade and Corporate Register of Antibes under SIREN number 442768552 .

BENOMAD has appointed a data protection officer who can be contacted by email at the following address: dpo@benomad.com

2. Which personal data are collected?

“Personal data” means any information relating to an identified or directly or indirectly identifiable natural person.

Personal data refers to your identifiers such as:

The data collection form will describe the rules applicable to any other personal data collected where these differ from the rules set out in this Policy.

3. When do we collect personal data?

BENOMAD collects your personal data in an explicit and transparent manner with the inclusion of notices or references to this Policy.

Your personal data may be collected for the purposes of:

• Browsing the website,
• Filling in any website forms or post a comment,
• Receiving documentation or information on our products,
• Entering into correspondence with us by telephone or email, on social media or a forum or through any other means,
• Applying for a job vacancy,
• Reporting any problems or requesting assistance.

Some of the personal data we ask for is required. Required data is indicated with an asterisk. Other data is optional. Failure to provide required personal data will make it impossible for you to access all of the site’s services.

4. For what purpose is the personal data collected?
   What is the lawful basis for the processing?

Your personal data may only be collected and processed for a specific purpose which is stated at the time it is collected.

BENOMAD undertakes to collect personal data only for specific, explicit and legitimate purposes and not to process such data subsequently in such a way that is incompatible with those purposes.

BENOMAD undertakes only to process such personal data that is adequate, relevant and not excessive in relation to the purpose for which they are processed.

The lawful bases for our processing of your personal data include processing which:

• Is necessary for the performance of the contract between you and BENOMAD such as issuing, overseeing, implementing and managing your contract: providing you with the services you require and responding to your requests; managing recruitment;
• Is necessary to meet BENOMAD’s legal and regulatory obligations such as combating money laundering, employee and tax contribution declarations, book-keeping requirements.
• To achieve our legitimate interests such as expanding BENOMAD’s business, improving products and services, researching new products and services, administering, maintaining and improving the website and combating fraud;
• Is based on the consent of our customers. Such consent can subsequently be withdrawn at any time (using the the preference settings provided in our emails or on our website) such as for communicating with you about our products and services and providing you with marketing information.

5. Personal data recipients

BENOMAD undertakes not to sell, lease or transfer your personal data to third parties, without your prior express agreement.

BENOMAD may, however, share your personal data with other entities:

• Authorised employees of BENOMAD whose remit relates to the aforementioned purposes;
• Service providers and subcontractors. In particular BENOMAD may use third party service providers to process some or all personal data (e.g. hosting the site, providing services related to operating the site, maintenance or sending communications and special offers);
• BENOMAD’s entities (listed here) and their commercial partners: subject to your prior express agreement, we may share your personal data with certain selected commercial partners so that they can share special offers and advertising with you;
• Officers of the court and government officials as part of their remit to manage disputes and recover debts: in the event of a dispute we may share your personal data in the interests of mounting our defence;
• Authorities handling employee and tax declarations, particularly in the event of an audit by government authorities;
• Advertising networks and social media who need the data in order to select and share with you and others, relevant advertising, providers of search engines who assist BENOMAD in optimising the website.
• Third parties where you have given your consent to such data being shared.

We may also disclose your personal data to any potential buyer in the event of the sale of one of BENOMAD’s entities or assets.

In any event, these entities are required, under contract, to keep any personal information they may receive confidential and secure and to use such data only for providing the services for which they have been contracted by BENOMAD.

In principle, the personal data collected are not intended to be transferred outside the European Union. These personal data are hosted on a server located in France.

BENOMAD may share your personal data in order to comply with a legal requirement, regulatory requirement, legal summons, court order or other ruling or order, or where such disclosure is necessary for a domestic or overseas authority that has shown its legitimate authority to obtain information as part of an investigative remit or proceedings.

6. Personal data retention period

BENOMAD shall retain your personal data in a secure environment for the period necessary to achieve the purposes of processing for which such data were collected, in accordance with the retention periods recommended by the French Data Protection Authority (CNIL) and/or set out in the relevant legislation.

As such, any data used for the purposes of marketing and advertising are retained for three years following the last contact made by the customer or three years following the end of the contractual relationship.

The data required for the management of your contract and associated services are retained for the term of your contract and until the end of the legal limitation period.

7. Security and confidentiality

BENOMAD takes steps to protect the confidentiality and security of your personal data and prevent such data from being damaged, erased or accessed by unauthorised third parties.

In particular, your data is kept secure through the use of a user name and password which restricts access to personal data to employees, agents and representatives who have authority owing to their position and are bound by a duty of confidentiality.

In the event of a breach of your personal data, BENOMAD is required to notify the relevant regulatory authority and to notify you in a timely manner of any breach of your personal data that may result in an increased risk to your rights and freedoms so that you can take the appropriate steps.

8. What rights do I have?

In accordance with the relevant regulations, you are entitled to access, amend or erase your personal data, to be forgotten by BENOMAD, to restrict the processing of data, to receive the personal data shared with BENOMAD, in a structured, commonly used and machine-readable format, on legitimate grounds and to oppose the processing of your personal data. If the processing is based on your consent, you are also entitled to withdraw it.

You are also entitled to submit a claim to the French Data Protection Authority (CNIL) or a data protection authority in a European Union member state and to provide instructions on how your data should be handled after your death.

In terms of marketing, you have a right to oppose and may, at any time, opt out of marketing by clicking on the unsubscribe link included in the message or by logging into your customer account.

9. Protecting the personal data of minors

In general terms the site is not intended for minors under the age of 15.

However, if you are a minor and have submitted personal data, you guarantee that you have obtained the prior authorisation of one of your parents. BENOMAD accepts no liability in the event that such authorisation has not been obtained. All parents and carers are encouraged to encourage minors to act responsibly and with care when sharing their personal data online.

10. Cookies

When visiting the site, cookies may be installed on your computer, tablet or smartphone, subject to your prior, specific, express consent.

When you visit BENOMAD’s site for the very first time, a banner notifies you of the presence of these cookies and invites you to choose an option. We obtain your consent through this banner.

They are only installed if you agree to them and continue to use the site. If you do not agree to the use of these cookies, you may deactivate them by following the instructions below under the section “Deactivating cookies”. Moreover, at any time you may access clear, explicit information on the purposes for which the cookies are used, information on how you can reject the use of cookies and manage the use of each of these cookies, by clicking on the link in the site menu. You have the option of blocking or erasing these cookies or modifying the retention period.

We draw your attention to the fact that rejecting cookies may prevent you from accessing certain site functionalities. In the event that you are unable to use certain services or functionalities provided by BENOMAD due to systematically deactivating cookies on your browser, under no circumstances shall such a malfunction constitute a loss giving rise to compensation.

Cookies store information about your browsing on the site (pages viewed, date and time of visit etc.) and thus enable us to find out your preferences and better respond to your expectations and requirements.

Like most websites, the site uses cookies that may fall under four categories:

11. Links to other websites

The BENOMAD site may contain links to other third-party sites.

BENOMAD has no control over these sites and shall not be held liable for their content or how they use your personal data.

In order to protect your personal data we recommend that you consult the privacy policy of any other site you access via a link on our website. Under no circumstances do we accept liability for any of the aforementioned policies.

12. Policy changes

BENOMAD reserves the right to change its Policy at any time without notice. Any changes made by BENOMAD to this policy will be announced on the site and effective from the time of publication.

Consequently, we invite you to refer to it each time you visit and to familiarise yourself with the most recent version which is permanently available on the site.

For any information on personal data protection, you may also consult the site of the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés – CNIL) www.cnil.fr.

13. Contact BeNomad

For any questions or comments about this document you can write to us at: dpo@benomad.com

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