1) PREAMBLE :
Ingredia places the protection and respect of privacy among its highest priorities. The Group undertakes to comply with all obligations applicable to data protection and respect for the rights and freedoms of individuals (in particular the European Data Protection Regulation" or "RGPD"), the opinions and recommendations of the CNIL as well as the European Data Protection Committee.
2) ROLES :
For a proper understanding of this policy it is specified that:
3) PURPOSE :
The purpose of this policy is to satisfy the obligation of information and to formalize the rights and obligations of Ingredia with respect to its customers and prospects regarding the processing of their personal data for all services of the https://ingredia-nutritional.com website.
4) SCOPE :
This policy applies to all processing of personal data relating to customers and/or prospects carried out from the https://ingredia-nutritional.com website.
5) WHY DO WE PROCESS YOUR DATA? :
Each processing operation is carried out within the framework of this protection policy and in compliance with the various regulations applicable to Ingredia. No processing of personal data of customers and prospects is implemented if it does not comply with the general principles of the RGPD.
The purposes are as follows:
6) LEGAL GROUNDS FOR PROCESSING YOUR DATA:
The legal grounds for processing personal data are as follows:
Legitimate interest: processing is necessary to pursue the legitimate interests of the organization processing the data or of a third party, in strict compliance with the rights and interests of the persons whose data is processed; this applies in particular in the context of commercial prospecting.
Consent: This is linked to the prior authorization obtained from individuals for the purposes of carrying out surveys.
7) TYPES OF DATA COLLECTED :
The Personal Data collected or held is that which is strictly necessary for the activities of the Ingredia group.
In this context, the group collects the following types of data.
Identification data such as first name(s), last name(s), date and place of birth, etc.
Data enabling the person to be contacted through various media, such as postal address, e-mail address, telephone number(s).
8) DATA COLLECTED USING COOKIES AND TRACKERS:
9) DATA ORIGINS :
Data relating to our customers or prospects is collected either directly from them or via the contact form.
10) DATA RECIPIENTS - AUTHORIZATION & TRACEABILITY :
Data collected by The Group may be shared in whole or in part depending on the purpose.
A) INTERNAL RECIPIENTS:
Authorized staff of the marketing department, sales department, departments in charge of customer relations and prospecting, administrative departments, logistics and IT departments and their line managers.
Authorized personnel in departments responsible for internal control procedures.
Recipients of customer and prospect personal data within the Group are subject to an obligation of confidentiality.
The Ingredia Group decides which recipients will have access to which data, based on an authorization policy.
B) EXTERNAL RECIPIENTS :
Legal entities that have entered into a contract with the Ingredia Group (subcontractor).
Service providers and subcontractors performing services on our behalf and for whom the compliance of commitments with the RGPD has been verified.
Duly authorized judicial and/or administrative authorities as well as regulated professions (examples: notaries, lawyers, bailiffs).
All accesses concerning processing relating to the personal data of customers and prospects are subject to a traceability measure.
In addition, personal data may be communicated to any authority legally empowered to have access to it. In this case, The Group is not responsible for the conditions under which the staff of these authorities have access to and use the data.
11) RETENTION PERIOD :
The data retention period is defined by Le Groupe in the light of its legal and contractual obligations and, failing that, according to its needs, and in particular in accordance with the following principles:
After these deadlines, data is either deleted or kept after being anonymized, notably for statistical purposes. In the event of pre-litigation or litigation, data may be kept for the duration of the litigation period, plus the legal time limits for contesting.
12) STORAGE :
Personal data is stored in our databases or in the databases of our subcontractors.
13) DATA SECURITY :
It is Ingredia's responsibility to define and implement the technical security measures, physical or logical, that it deems appropriate to fight against the destruction, loss, alteration or unauthorized disclosure of data in an accidental or illicit manner. The Group requires the same measures from its business partners and subcontractors.
In this respect, Ingredia takes all useful precautions, with regard to the nature of the data and the risks presented by the processing, in order to preserve the security of the data and, in particular, by applying measures of physical protection of the premises, authentication procedures with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data...
14) TRANSFER OUTSIDE THE EUROPEAN UNION :
You are informed that your data will not be transferred to countries outside the European Union.
15) COMMERCIAL SOLICITATION:
If you give your consent during registration Ingredia may send you newsletters and other promotional messages by email, post and SMS. These newsletters will keep you informed of Ingredia news, products and services.
16) PERSONAL RIGHTS:
Customers and prospects have the right to request confirmation from the Ingredia Group as to whether or not data concerning them is being processed. In particular, every individual has the right to be informed, in a comprehensible and easily accessible manner, about the processing of his/her data.
In accordance with applicable regulations, you have various rights that you may exercise at any time:
You have a right of access, a right of rectification, a right to the deletion of data concerning you, as well as the right to request the portability of the data you have provided to us.
You have the right to object, on legitimate grounds, to the processing of your data, or to request the restriction of such processing.
You also have the right to object at any time and without cause to the processing of your data for direct marketing purposes, as well as to profiling when carried out for the same purpose.
You also have the right to specify what happens to your personal data after your death.
17) EXERCISING YOUR RIGHTS:Rights may be exercised exclusively by e-mail to the following address: firstname.lastname@example.org or by post to :
Ingredia, DPO, 51 Avenue F. Lobbedez CS 60946 62033 Arras Cedex FRANCEAs required by law, we must be able to verify the identity of the person asserting his or her rights. It is therefore necessary to send us a copy of your identity card or any other element enabling us to prove your identity with certainty.We would like to point out that the exercise of some of these rights may, on a case-by-case basis, make it impossible for the data controller to provide the service in the cases strictly provided for by the regulations in force.Your request will be answered within one month of receipt of your complete request. We reserve the right not to respond to manifestly unfounded or excessive requests.
18) DATA BREACH :
In the event of a personal data breach, The Group undertakes to notify the CNIL in accordance with the conditions prescribed by the RGPD.
If said breach poses a high risk to customers and prospects and the data has not been protected, Le Groupe.
Will notify the customers and prospects concerned;
Will communicate the necessary information and recommendations to the customers and prospects concerned.
19) RIGHT TO LODGE A COMPLAINT WITH THE CNIL : Customers and prospects concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely the CNIL in France, if they consider that the processing of personal data concerning them does not comply with European data protection regulations, at the following address:CNIL - Service des plaintes
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tel: 01 53 73 22 22
20) SUBCONTRACTING :
Le Groupe informs its customers and prospects that it may involve any subcontractor of its choice in the processing of their personal data.
In this case, The Group ensures that the subcontractor complies with its obligations under the RGPD.
The Group undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does itself. In addition, The Group reserves the right to audit its subcontractors to ensure compliance with the provisions of the RGPD.
21) EVOLUTION : The present policy may be modified or amended at any time in the event of changes in legislation, case law, CNIL decisions and recommendations or usage.
Any new version of the present policy will be brought to the attention of the users of the site by any means defined by Ingredia, including electronic means (distribution by e-mail or online, for example).