1. PERSONAL DATA
Sebia and its subsidiaries (hereinafter “Sebia”) attach great importance to transparency and the protection of your Personal Data.
That is why Sebia wants:
- That you understand how we use your Personal Data.
- To ensure that you are aware of your rights in this regard.
- To inform you of the ways in which you can exercise them.
Definitions
For the purposes hereof, the terms “Personal Data”, “Processing”, “Controller”, “Subcontractor” have the definition given to these terms within Article 4 of the European Regulation 2016/679 of 27 April 2016 (hereinafter “GDPR”). Specifically:
« Personal Data »: means any information relating to an identified or identifiable natural person.
« Controller»: means the company of the Sebia Group which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
« Sebia Group »: refers to the group constituted by Sebia, a limited company with a capital of €10203900, whose registered office is at LISSES (91090) – 27 rue Léonard de Vinci, registered under number 672 041 902 at the Evry Trade and Companies Register, as well as its consolidated subsidiaries within the meaning of Article L233-3 of the French Commercial Code. For all intents and purposes, it is stated that the Controller is part of the Sebia Group.
Scope of this Privacy Policy – Update
This Privacy Policy covers personal information that Sebia obtains through:
- communication tools owned by Sebia, (its websites, mobile applications owned by Sebia and social networking sites that refer to this Privacy Policy)
- offline collection (sales, marketing, direct or through partners and suppliers)
- any other third-party sources
(Collectively, the “Tools”).
Personal information obtained by Sebia through its recruitment website that is subject to the specific privacy policy for candidates, available on our HR recruitment platform, or products and services that expressly reference one or more different privacy policies is not covered by this Privacy Policy is.
Sebia reserves the right to change this Privacy Policy at any time in order to comply with the mandatory provisions of the governing legislation and depending on the evolution of its Tools. Therefore, it is essential to consult the current Privacy Policy regularly in order to be updated of any new information that may be added to it.
Personal Data processed
The communication of your Personal Data is at your sole option and remains at your entire discretion. Nevertheless, some Personal Data are essential to access to certain services or to provide certain services, Sebia cannot be held responsible if it is forced to deny or restrict access to these services or is unable to perform the services it is held to in the absence of these Personal Data. When collecting Personal Data, you will be informed, by the presence of an asterisk, if the Personal Data must be filled in or if they are optional.
The Personal Data that Sebia may collect via its Tools include:
- contact information (name of the natural person, telephone numbers, fax numbers, e-mail, postal addresses, job title)
- online account creation data (username, password, password bypass information such as security questions and answers)
- biographical data necessary for the purpose in question (date of birth, gender, work experience)
- payment data (name, billing address, credit card details, bank through a secure payment provider who alone has access to this data)
- Geographical data (IP address, country, postal code, mobile device geolocation if necessary)
- navigation data
Sebia undertakes to limit the collection of Personal Data to what is strictly necessary in accordance with the minimization principle provided for in the GDPR.
Sebia formally recommends avoiding communicating Personal Data via text boxes or within downloaded documents.
Sebia reminds that it is forbidden to collect and process sensitive Personal Data within the meaning of GDPR (data relating to the health of an individual, racial or ethnic origin, political or trade union opinions, etc.) and that therefore sensitive Personal Data that might nevertheless be communicated to Sebia is systematically deleted.
Purposes/Legal basis/Storage period
The Personal Data collected by Sebia are processed for the purposes described in the table below. This Personal Data is kept for a period of time in accordance with the legal provisions or proportional to the purposes for which it was collected. In addition, Sebia must be able to justify a legal basis for the processing it carries out. In accordance with the GDPR, the legal grounds on which Sebia may rely are the following:
- the performance of a contract to which the data subject is a party or the performance of pre-contractual measures at the request of the data subject, such as a request to pre-register for a service or the performance of a service.
- the compliance with a legal obligation, in particular conservation of invoices for accounting obligation;
- the prior consent of the data subject;
- the legitimate interest of the Data Controller, with respect to the rights and freedoms of users (e.g.: improvement of the customer experience, prevention of fraud, etc.).
The Personal Data are not kept by Sebia beyond the time strictly necessary for the intended purposes as stated above and this in accordance with the GDPR or in the event that the data subject exercises the right of modification or deletion.
Personal Data are either anonymized or deleted when the retention periods expire. Nevertheless, Personal Data may be archived beyond the periods provided for the purpose of research, establishment and prosecution of criminal offenses for the sole purpose of allowing, where necessary, the provision of these data to the judicial authority or to comply with one or more legal obligations of conservation.
Recipients of the Personal Data
Sebia provides access to Personal Data only in the cases listed below:
- Access to Sebia’s staff who need to know the Personal Information in order to perform their duties in the context of the purposes described in this Privacy Policy;
- Access to Subcontractors or technical service providers selected by Sebia in order to perform all or part of the services on behalf of Sebia (development of the content of the Tools, maintenance, hosting, payment processing, customer support, data analysis, etc.).
- Access to public authorities and/or organizations in accordance with the legislation in force or by virtue of a decision of a competent regulatory or judicial authority.
- Access to third parties in the event of a potential or final sale or transfer of all or part of Sebia’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, assignment, dissolution or liquidation) or any other combination of activities, provided that the third parties concerned guarantee levels of protection comparable to those of the Sebia Group with respect to the Personal Data shared
Transfer of Personal Data
Personal Data collected by Sebia will not be transferred outside the European Union.
Security measures applied to Personal Data
Sebia, in its capacity as Data Controller, ensures that it implements and that its Subcontractors implement appropriate technical and organizational measures in accordance with applicable legal provisions, to protect Personal Data against alteration, accidental or unlawful loss, use, disclosure or unauthorized access, including:
- Securing access to its premises and computer platforms;
- Raising awareness of the confidentiality requirements of its employees who have access to Personal Data;
- A level of requirement in compliance with the GDPR in terms of data protection when selecting its Subcontractors.
Rights and exercise of rights of the natural persons concerned
In accordance with the GDPR, any natural person whose Personal Data is collected and processed has, depending on the legal basis of the Processing concerned, the following rights:
- A right to access, modify, rectify, erase (right to oblivion), and delete his or her Personal Data,
- A right to limit the Processing,
- A right to object to the Processing of Personal Data concerning him or her or to withdraw consent for legitimate reasons or for commercial prospecting purposes,
- A right to the portability of Personal Data
- A right to organize the fate of Personal Data in case of death (conservation, deletion or communication to a designated person).
These rights can be exercised by contacting Sebia at the following address: dpo@sebia.com indicating the subject of the request and enclosing proof of identity and any other information that may be useful in processing the request. Sebia processes requests relating to the exercise of the rights listed above as soon as possible and at the latest within one month of receipt of the request including all the documents requested above.
Lastly, Sebia reminds you that the individual concerned, if he or she considers that his or her rights have not been respected, has the right to lodge a complaint with the supervisory authority in his or her country of residence, in France the CNIL: https://www.cnil.fr/.
Applicable Law/Jurisdiction
This Privacy Policy is governed by French law, regardless of the language in which the individual concerned has accessed it, the French version being the sole authentic version. Any dispute relating to its interpretation or execution will be submitted to the competent French courts.
2. COOKIES AND OTHER TRACKERS
Definition
A Cookie is an alphanumeric file that may be deposited and recorded in the terminal (computer/smartphone/tablet…) when a service is consulted with a navigation software via the consulted Tool. It allows its issuer, during the period of validity of this Cookie, to recognize the terminal concerned each time this terminal accesses digital content containing Cookies from the same issuer, and depending on the Cookie, to collect additional information on the user’s behavior when using the services.
The User is informed that, when connecting to the Sebia Tools, Cookies are installed on his/her terminal for the proper functioning of the services, or on his/her browser subject to the choice expressed by the User concerning the Cookies; this choice can be modified at any time.
They may be:
- Internal cookies: they are issued and deposited by Sebia from its servers and its domains.
- Third-party cookies: they are issued by partners with whom Sebia works from the server or domain of that partner entity.
Depending on the time during which the cookies are stored in the user’s terminal, there are:
- Session cookies: activated during the user’s browsing of the relevant Tool or for the provision of a service requested by the user.
- Permanent cookies: stored for a certain period of time on the user’s terminal, the person responsible for the Tool in question having access to them when the user connects to that Tool.
According to the function of the Cookies and the purpose of the data obtained, Sebia distinguishes:
- Security cookies: technically essential for browsing the Tools (to move around, use its basic features and secure your connection) and for the delivery of the service.
- Functional cookies (or personalization cookies): improve your navigation on the Internet Tools by offering personalized functionalities: the nominative welcome and the recording of your preferences (language or region where you are located).
- Analysis (or performance) cookies: allow the monitoring and statistical analysis of the user(s) of the Tools to which they are linked (most viewed pages, error messages, overview of traffic on the Tools concerned, the of this traffic and pages visited, etc.). The objective is to improve your user experience and the functioning of our Tools,so that you can intuitively find what you are looking for.
- Advertising cookies: allow for the management of advertising space on the accessed Tool.
- Behavioral advertising or targeting cookies: store information about the behavior of users obtained through their browsing habits, which allows the Tools to offer them relevant advertisements according to their interests. They are also used to limit the number of times the same ad is displayed and to help measure the effectiveness of advertising campaigns. Deleting these cookies will not prevent the advertisement from being displayed.
- Social network cookies: allow you to share content from our Tools with others or to let those people know that you have viewed or thought about content from the relevant Tool.
Sebia also uses third-party web analytics services in connection with its Online Tools such as Google Analytics, Adobe Analytics… which may use Cookies to collect data (such as IP addresses) in order to evaluate usage and interaction with the Online Tools.
Cookie management by the user of Sebia Tools
Consent
The installation of certain Cookies is subject to your consent, when their exclusive purpose is not to allow or facilitate navigation or when they are not strictly necessary for the provision of services or the management of services. Therefore, when you first visit the Tool concerned, you are asked to consent or not, to the installation of these non-essential Cookies on your terminal. A Cookie will be installed to remember your choice. If you delete this Cookie your consent will be requested again. You may at any time revoke your choice by going to cookies parameter in the footer of the tool.
If the user refuses the registration of Cookies in his terminal or his browser, or if he deletes those registered there, Sebia reminds that his navigation and his use of the Tool concerned may be limited. In this respect, Sebia declines all responsibility for the consequences related to the degraded functioning of the Tools or services resulting (i) from the refusal of Cookies by the User (ii) from the impossibility for Sebia to record or consult the Cookies necessary for their functioning due to the User’s choice.
Types of Cookies used by Sebia
Last amended on: 06/22/2021