In this context, “Personal Data” means any information relating to an identified or identifiable natural person (a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
For the purposes of this Policy, as a Data Subject and user of the Website, you shall be hereinafter referred to as "You"/“Your”.
DHP SAS, “société par actions simplifiée” a company organized under the laws of France, having its registered office 21, avenue Matignon, 75008 Paris, registered with the register of Paris Trade under number 403 197 155, acts as a controller in the processing of Your Personal Data (i.e. it determines the purposes and means of the processing). DHP SAS shall hereinafter be referred to as "We"/“Our”/”Us”.
1.What Personal Data do We collect?
We collect and process the following categories of Personal Data when You use the Website:
2.What special categories of Personal Data do We process about You?
Under the GDPR, certain categories of Personal Data are considered as particularly sensitive so that
processing thereof is subject to specific rules. Such is notably the case with respect to Personal Data
revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, etc.
However, please note that We do not collect any special categories of Personal Data when You use Our Website.
3.How do We use Your Personal Data?
We process Your Personal Data for the following purposes:
Technical provision of the Website, and of its functionalities, and performance of statistical analysis on the Website.
Please note that the legal bases We rely upon for lawfully processing Your Personal Data are:
- Your consent, where necessary;
- Our legitimate interest consisting in ensuring the proper functioning Our Website.
4.Do We share Your Personal Data?
As part of Our processing activities, We communicate Your Personal Data to the following categories of recipients:
- Our suppliers, service providers, agents and contractors assisting Us in meeting the purposes identified herein (e.g. IT service providers hosting Your Personal Data on Our behalf, Our legal counsels, etc.); and
- competent courts, public authorities, government bodies and law enforcement forces (in particular, where We must respond to legal or regulatory requests).
In any event, and disregarding the recipient at stake, We communicate Your Personal Data on a strict need-to-know basis and only to the extent necessary for meeting the processing purposes identified in this Policy.
5.Do We transfer Your Personal Data outside the EEA?
For the purpose of the processing activities detailed herein, We transfer Your Personal Data outside
the European Economic Area (“EEA”), including to countries which are not regarded by the European
Commission as ensuring an adequate level of data protection.
In this respect, We have implemented appropriate safeguards to ensure that the level of protection applied to Your Personal Data is not altered by such transfers. Such safeguards consist in: (i) the execution of standard contractual clauses based on the models issued by the European Commission; and (ii) the implementation of Binding Corporate Rules (where We transfer Your Personal Data to entities of the AXA group).
You can obtain copies of these appropriate safeguards by sending an email to Our Data Protection Officer (“DPO”), whose contact details are specified below in Section 11 (How can You contact Us?) below.
6.How do We keep Your Personal Data secure?
To keep Your Personal Data secure, We have implemented technical and organizational measures
designed to protect Your Personal Data against the risk of accidental or unlawful destruction, loss,
alteration, unauthorized disclosure of, or access to Your Personal Data.
We review such measures on a regular basis to check that they remain adequate and relevant to secure Your Personal Data.
7.For how long will Your Personal Data be retained?
In the course of Our processing activities, We retain Your Personal Data for a period not exceeding 25 months as per the CNIL’s recommendation.
8.What about cookies?
9.What are Your rights in relation to Your Personal Data?
As a Data Subject, You benefit from various rights in accordance with the applicable data protection
legislation, and notably the GDPR, as follows:
You have the right to request access to Your Personal Data as well as to request rectification or erasure thereof.
You are also entitled to request the restriction of the processing carried out with Your Personal Data or to object to such processing.
You can request the portability of Your Personal Data.
You have the right to specify guidelines on the use of Your Personal Data after Your death and to withdraw your consent to the processing of Your Personal Data where applicable.
However, please note that some of the above mentioned rights are subject to particular requirements resulting from the applicable data protection legal framework. As a result, if Your particular case does not meet the legal requirements to do so, We will not be able to let You exercise the concerned right.
You can exercise Your rights by contacting Our DPO with the contact details specified in Section 11 (How can You contact Us?). As part of Our response to Your request, You may be asked to provide further information to confirm Your identity and/or to facilitate locating the Personal Data associated to Your request.
In any event, please note that You are entitled to lodge a complaint with the French Data Protection Authority (“CNIL”) in the event You consider that the processing activities We carry out with Your Personal Data are unlawful.
10.Updates to the Policy
We will update this Policy from time to time, notably in response to new legal, technical or business developments. When We make any material change to this Policy, We take appropriate measures to inform You accordingly.
11.How can You contact Us?
Should you have any questions or requests regarding the processing activities we carry out with your personal data under this Policy, including the exercise of Your rights detailed above, please feel free to contact us with the contact details here: firstname.lastname@example.org