LAST UPDATE: March 2021
If you have any questions, comments, or concerns regarding this policy, you can reach our Data Protection Officer, whose contact information is provided below in the section "What are your rights and how can you exercise them?"
1 – DEFINITIONS
In addition to terms defined elsewhere in this policy, the following terms, whose first letter is capitalized, whether used in the singular or plural in this policy, have the following definitions:
1.1 "Recipient": Refers to the natural or legal person, public authority, agency, or other body to whom Personal Data is disclosed, whether or not a third party.
1.2 "Personal Data": Refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the "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 one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
1.3 "Data Controller": Refers to the natural or legal person, public authority, agency, or other body which, alone or with others, determines the purposes and means of the Processing.
1.4 "Data Processor": Refers to the natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller.
1.5 "Processing": Refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated mean, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2 – WHAT IS OUR ROLE IN PROCESSING PERSONAL DATA?
2.1 The company Les Magasins Généraux (also referred to as "the company" or "we"), a simplified joint-stock company with a capital of €1,000.00, registered with the Bobigny Trade and Companies Register under number 808293823, whose registered office is located at 7, rue de l’Ancien Canal CS80101 93507 Pantin Cedex, VAT number FR15808293823, SIRET number 80829382300023, phone: +33 (0)1 56 41 39 38, email address: firstname.lastname@example.org, operates as a grand Parisian creative center within Les Magasins généraux in Pantin, founded by the communication agency BETC.
For more information about our company, click here.
2.2 The company Les Magasins Généraux (also referred to as "the company" or "we") operates the publicly accessible website at the following URL: https:// magasinsgeneraux.com/en-GB
This website aims to provide information to internet users (i.e., any natural or legal person visiting or using these sites, hereinafter referred to as "users" or "you") about the company's activities and services, as well as its recent activities (events, publications, etc.).
It also offers features that allow users to contact the company (contact requests, etc.) and presents the services offered by the company, projects carried out by the company, or the employees working within the company.
The company also manages social media pages that present its activities and allow it to publish content and interact with internet users (especially on Facebook, Instagram, or Twitter).
While browsing and interacting on the aforementioned website (hereinafter referred to as the "Site"), on pages administered by the company on social media, or in general during your interactions or exchanges with the company, we may collect and process Personal Data for the management of our activities and as Data Controller.
In this context, the company applies the principles defined by applicable laws and regulations on the protection of Personal Data, especially in Regulation (EU) 2016/679 of April 27, 2016, relating to the protection of natural persons with regard to the Processing of Personal Data ("RGPD"), and implements internal procedures for the management, retention, and security of your Personal Data, whether you are a potential employee, employee, client, prospect, contact, internet user, supplier, or Data Processor.
2.3 When our clients ask us to process Personal Data on their behalf, according to purposes and means defined by them, we act as a Data Processor, under a specific contract concluded for this purpose, with the understanding that this policy exclusively concerns the Processing of Personal Data carried out by the company as a Data Controller and not as a Data Processor.
3 – WHAT ARE THE METHODS FOR COLLECTING YOUR PERSONAL DATA?
3.1 Your Personal Data is collected directly from you or indirectly from third parties.
3.1.1 Your Personal Data, in whole or in part, is notably collected or processed when you browse the Site and enter information in the data collection forms on the Site, but also more generally in connection with requests you may send to the company by any means at your convenience, your interactions and communications with the company, as well as when you connect to a third-party social network from the Site, share content from the Site using "buttons" provided on the Site, or during your navigation on one of the company's pages on social media.
In general, your Personal Data is collected directly from you in the aforementioned scenarios.
3.1.2 However, your Personal Data may also be collected through third parties (see indirect collection from third parties).
The Personal Data we collect and process about you may be gathered or enriched by us, especially for the purpose of commercial operations, communication, solicitation, prospecting, or marketing, using other sources of information (social networks, "public" information, websites, file rentals, etc.).
Additionally, regarding Personal Data processed as part of our recruitment operations, we use the information you provide us (e.g., a form on the Site or information in your CV) and integrate it into our candidate database (CV database). However, we may also contact third parties (e.g., recruitment agencies, former employers, internship supervisors, or clients with whom you have worked on previous missions) or use other sources of information (particularly professional social networks, recruitment agencies, or specialized recruitment websites) to collect information about you for the purpose of reviewing your application or profile. Furthermore, even in the absence of a job application on your end, especially as part of our monitoring and active search operations for professional profiles that may match our job offers, we may collect Personal Data from third parties (e.g., recruitment agencies or "headhunters") or use other sources of information (particularly professional social networks or specialized recruitment websites) to collect information about you in order to suggest that you apply for one of our job offers.
Regarding Personal Data about suppliers, this data is generally collected directly from them. However, for Personal Data of suppliers with whom we do not have a direct contractual or commercial relation, their Personal Data may be communicated to us through third parties, such as other suppliers. Similarly, with respect to personnel members/contacts at our suppliers in the broad sense, we may collect such Personal Data through any supplier.
3.2 YOU ARE HEREBY INFORMED THAT:
• If the Processing of your Personal Data is necessary for compliance with applicable laws and regulations, the collection of such data is mandatory. If the Processing of your Personal Data is subject to your consent, the collection of such data is entirely optional (it being specified that failure to communicate this information could, in some cases, prevent us from carrying out the relevant Processing).
• If the Processing of your Personal Data is necessary for the performance of a contract or pre-contractual measures taken at your request, the communication of such data is necessary for the pursuit of this purpose, and the company may be prevented from fulfilling its contractual obligations or the aforementioned pre-contractual measures in the absence of the communication of this data.
• If the Processing of your Personal Data is based on our legitimate interests, the communication of such data is necessary for the pursuit of this purpose, and the absence of communication of your data may prevent us from carrying out the relevant Processing or may hinder it.
For example, if you do not provide the information required to respond to a request from you (e.g., information requests, job applications, etc.), your request related to this Personal Data collection may not be processed or may be delayed. If data collection forms (e.g., forms integrated into the Site or any data collection form in any format that we may make available to collect information about you) involve the entry of mandatory Personal Data for the implementation of the associated Processing, the relevant fields will be marked with an asterisk, and you will be informed of the possible consequences for failing to provide this information. In the absence of an asterisk, the requested information is optional.
3.3 Except for specific legal obligations or contrary provisions in this policy, we do not collect Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a person's sex life or sexual orientation.
3.4 Personal data of minors or protected adults: We draw the attention of individuals with parental authority over minors and individuals with a representation mission under guardianship, family authorization, or a future protection mandate for the need to ensure that the Personal Data of vulnerable individuals under their legal protection are not disclosed, used, or processed outside of their control and supervision. The fact that minor can legally consent alone to the Processing of their Personal Data concerning the direct offering of information society services from the age of fifteen (in France, this age may vary depending on the child's state of residence) does not limit the duty and interest of individuals with parental authority to educate their children about the importance of respecting their privacy and Personal Data.
In general, the use of the Site and the dedicated pages of the company on social media is reserved for adults with legal capacity, and the company cannot be held responsible for the use of the Site or its social media pages by minors or individuals incapable of consent, and thus the potential consequences, particularly regarding the Processing of their Personal Data.
As an exception, the company may process Personal Data of minors aged at least fifteen when they contact the company to apply for a job or internship, for example.
4 – WHAT DATA IS COLLECTED, FOR WHAT PURPOSES OF PROCESSING, AND ON WHAT GROUNDS?
4.1 In our capacity as Data Controller, we may implement Processing of your Personal Data for the following purposes:
a. Handling information requests and interactions with the company initiated through or by means of the Site or the company's social media pages:
• Purpose: We process your Personal Data in order to respond to any contact or information request that is sent to us, particularly through or initiated via the Site or through interactions on our social media pages (including the management, Processing, monitoring, and moderation of your messages or comments). We also process your data for the purpose of managing such requests and the responses to be provided, as well as more generally for managing our relations with our contacts.
• Data processed: Identity (title, name, first name), username (if the request is initiated on the company's social media pages), contact details (including telephone number or email address), affiliated company, contact request, information request, or documentation, and exchanged correspondence.
• Legal basis: The Processing of your Personal Data in this context is necessary for the pursuit of the legitimate interests of the company in responding to your requests and, more generally, in managing and monitoring its relations with its contacts.
b. Managing our relations with our clients (pre-contractual, contractual, and post-contractual relations):
• Purpose: In order to manage our pre-contractual, contractual, and post-contractual relations with our clients, we collect the Personal Data of our clients and/or of our contacts at our clients to ensure the management and monitoring of quotations and service proposals, the conclusion and execution of contracts, orders, deliveries, invoices, payments and transactions (including the management of overdue payments and litigation), associated accounting, customer relations in the broad sense, and especially the management and monitoring of customer accounts, complaints, and for conducting studies, analyses, reports, and statistics, especially for commercial purposes.
• Data processed: Identity, contact details (email address, postal address, telephone number, etc.), affiliated company and position, details of orders, quotations, payment data, transaction data, data related to contract and business relation monitoring, invoice data.
• Legal basis: For the Personal Data of clients, such Processing is, in principle, necessary for the performance of pre-contractual measures taken at the request of the client or of a contract concluded with the client. However, for certain aspects, such as managing billing and related accounting, these Processes may result from legal obligations on the part of the company. Furthermore, sub-purposes of this Processing related to the management and monitoring of our relations with our clients in the broad sense (including managing and monitoring customer accounts, overdue payments and litigation, complaints, or conducting studies, analyses, reports, and statistics) are necessary for the pursuit of our legitimate interests in managing and monitoring our relations with our clients. Regarding the Personal Data of contacts at our clients, the Processing is based on our legitimate interests in managing and monitoring our relations with our clients in the broad sense, especially in organizing and properly executing missions or services entrusted to us by them.