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Privacy Policy

To June 17, 2019

INTRODUCTION

The protection of privacy is a core concern of GROUPE LEGENDRE and its Subsidiaries (the «Subsidiaries»). The processing of your Data is subject to compliance with the provisions of Act 78-17 of January 6, 1978 as amended («Loi Informatique et Libertés») and European Regulation No. 2016/679 of April 27, 2016 on the protection of Personal Data, known as the «RGPD», or any other legislative or regulatory act amending them. You can obtain further information on Data protection from the Commission nationale de l'informatique et des libertés (www.cnil.fr). This Privacy Policy concerns individuals and aims to explain clearly and simply to you - as a visitor to our Site - how we collect, use and store your Personal Data. To this end, this document provides the persons for whom GROUPE LEGENDRE is responsible with information relating to:

  • How we collect and process your Personal Data,
  • How GROUPE LEGENDRE uses your Personal Data
  • The measures taken by GROUPE LEGENDRE to ensure the protection of your Personal Data collected in connection with the use of the Site.
  • To your obligations and those of GROUPE LEGENDRE under the Data Protection Act.

DEFINITION

«Personal Data» According to article 2 of the French Data Protection Act, «Personal Data» means "any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to that person". Personal Data includes, in particular, Data enabling Users to be identified.

«Subsidiaries» Subsidiaries: refers to subsidiaries within the scope of their parent company, i.e. GROUPE LEGENDRE.

« LEGENDRE GROUP » Société par actions simplifiée (simplified joint-stock company) with capital of 10,065,600 euros, headquartered at 5, rue Louis-Jacques Daguerre - 35136 SAINT-JACQUES-DE-LA-LANDE and registered in the Rennes Trade and Companies Register under no. 440 919 777, is considered to be the data controller.

«Privacy Policy» Personal Data: refers to the present document, accessible from the LEGENDRE GROUP and its Subsidiaries' Sites, the purpose of which is to inform the Internet user of the manner in which the data controller collects, uses and retains Personal Data.

«Site(s)» means the digital medium(s) used by GROUPE LEGENDRE and its Subsidiaries to inform Internet users about their business.

«DPO» Data Protection Officer is the French acronym for Délégué à la Protection des données personnelles.

ARTICLE 1 - WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

LEGENDRE GROUP is responsible for processing your Data. GROUPE LEGENDRE, a simplified joint stock company with capital of 10,065,600 euros, whose registered office is located at 5, rue Louis-Jacques Daguerre - 35136 SAINT-JACQUES-DE-LA-LANDE and registered in the Rennes Trade and Companies Register under number 440 919 777, (hereinafter the «GROUPE LEGENDRE», or the «Data Controller») is responsible for processing your Data.

You can contact us by mail by writing to :

LEGENDRE GROUP

Legal department - DPO

5, rue Louis Jacques Daguerre

35136 SAINT-JACQUES-DE-LA-LANDE

GROUPE LEGENDRE has appointed a DPO for itself and all its «Subsidiaries». The DPO's duties include informing and advising the Data Controller on all issues relating to the protection of Personal Data. He ensures compliance with regulations on the protection of Personal Data. He is also the point of contact for the Commission Nationale de l'Informatique et des Libertés («CNIL»), the supervisory authority, for any questions relating to the management of Personal Data. You can contact our DPO :

  • By post: M. le Délégué à la Protection des Données - GROUPE LEGENDRE - 5, rue Louis Jacques Daguerre, 35136 SAINT-JACQUES-DE-LA-LANDE
  • By e-mail: dpo@groupe-legendre.com

We make every effort to comply with current data protection regulations, as well as with implementation measures supervised by the CNIL. For certain services, we use specialized partners who act as subcontractors. These subcontractors must comply with our Privacy Policy and with their legal obligations in this area. In addition, we also take care to ensure the protection of your Personal Data through appropriate provisions in our contracts with parties likely to help us process your Personal Data or to whom we communicate your information.

ARTICLE 2 - WHAT DO WE MEAN BY PERSONAL DATA?

By Personal Data, we mean not only data that identifies you directly, but also data that does so indirectly. The various types of Personal Data we usually collect when you use the Site include the following:

  • Identification data: your surname, first name, home address, e-mail address, telephone number, business address, age, date of birth, place of birth, marital status, family situation.
  • Professional data: profession, business address.
  • Financial data: amount of annual electricity bills, status as owner or tenant, income, consumption habits.
  • Data obtained via cookies: for all information relating to the use of cookies by LEGENDRE GROUP, you can consult the policy of LEGENDRE GROUP and its Subsidiaries regarding the deposit of cookies in the «Legal Notice» tab of our Sites.

Unless required by law, we do not process sensitive Personal Data, i.e. Data concerning health, racial or ethnic origin, political opinions, religion or beliefs, trade union membership or sex life.

ARTICLE 3 - WHEN DO WE COLLECT YOUR DATA?

GROUPE LEGENDRE and its Subsidiaries collect your Personal Data directly or indirectly, in particular:

  • Through your terminal (in particular: cookies, connection data);
  • Through the Sites' Data collection forms, such as the contact section;
  • While browsing the pages of the Sites ;
  • By subscribing to our newsletter.

GROUPE LEGENDRE and its Subsidiaries may also receive data collected from you by a third party.

ARTICLE 4 - FROM WHOM DO WE COLLECT YOUR PERSONAL DATA?

We collect most of your Personal Data directly from you, but may obtain information about you when we consult a file held by a public authority.

ARTICLE 5 - PURPOSES OF PERSONAL DATA PROCESSING

The processing of Personal Data carried out by GROUPE LEGENDRE and its Subsidiaries through the Sites has the following purposes (hereinafter the «Purposes»):

  • Handle your questions or requests for information or any other request;
  • To keep you up to date with the latest news from GROUPE LEGENDRE and its subsidiaries;
  • Allow you to obtain an energy savings simulation;
  • Keep track of your current contracts;
  • Enable you to generate gift vouchers.

The information required by GROUPE LEGENDRE to fulfill the purposes described above is indicated by an asterisk (*) on the various pages of the Sites. If you fail to complete the fields marked with an asterisk (*), you may be denied access to all or part of the services and functionalities of the Sites and your requests may not be taken into account. The other fields are optional and are intended to improve the quality of the service offered to you by the Sites. Other information is optional and enables us to get to know you better and improve our communications and services to you.

ARTICLE 6 - LEGAL BASIS FOR THE USE OF YOUR PERSONAL DATA

In accordance with the law, we use your Personal Data only with your prior consent. We also take care to ensure that any Personal Data we receive from third parties has been collected in accordance with the law.

ARTICLE 7 - COOKIES AND SIMILAR TECHNOLOGIES

We use cookies on our Sites to enhance their performance, to enable them to remember your preferences, and to bring you information that we think may be of interest or use to you. Generally speaking, cookies are small data files stored on your computer. They can have various functions, but are generally used to keep track of the websites you visit. They contain a small amount of information relating to specific website visits, which can be used to remember you and your preferences on future visits. Cookies can be «functional» and contain Data about you (as a user) such as language, which means that you do not have to re-enter this Data each time you visit our Websites. Cookies may also be «technical» and record Data relating to the pages of our Website consulted by the user, as well as where information may be entered in forms. Such cookies provide personalized information and may prevent you from receiving the same or similar advertisements repeatedly. We also use Data recorded by cookies to compile statistics for our Website and to ensure that its performance and content are improved. We may use cookies to identify certain patterns in your online behavior, in order to offer you content that meets your needs and serves your interests. Most browsers are automatically configured to accept cookies. However, you can set your browser to notify you when you receive a cookie, or to prevent cookies from being stored on your hard drive. If you refuse our cookies, you may experience a slowdown in navigation or not be able to access all services. Our Websites may contain links to third-party sites whose terms of use do not fall within the scope of our privacy policy. We recommend that you read their privacy policies carefully.

ARTICLE 8 - RETENTION PERIOD

The Personal Data collected is kept for the time necessary to achieve the various Purposes described in the previous paragraph and to comply with our legal obligations. Data relating to cookies is kept for a period of thirteen (13) months from the date of collection. The Personal Data collected is deleted following the occurrence of one of the following events:

  • End of shelf life ;
  • Exercise your right of deletion in accordance with the French Data Protection Act ;
  • Removal of the Site by GROUPE LEGENDRE for any reason whatsoever.

ARTICLE 9 - DATA SECURITY

We take appropriate technical and organizational measures to ensure that your Personal Data is adequately secured against loss or accidental disclosure to unauthorized persons. Procedures for the physical and electronic safeguarding of Personal Data collected on the Sites are implemented, in accordance with current French legislation on the protection of Personal Data. Employees of LEGENDRE GROUP and its Subsidiaries who, by virtue of their position, have access to your Personal Data, undertake to maintain the strictest confidentiality in this regard. However, LEGENDRE GROUP and its Subsidiaries do not control all the risks associated with the operation of the Internet and draw your attention to the existence of possible risks in terms of occasional loss of Data or breach of confidentiality of Data transiting via the Internet network. To this end, it is necessary to contribute to the security of your Personal Data by following the following advice:

  • Use the latest operating system on your computer, and keep up to date with all security updates; ;
  • Use the most recent version of your browser and perform all security updates; ;
  • Install antivirus, antispyware and firewall software, and set your preferences so that these protections are regularly updated.
  • Don't leave your equipment and connection methods unattended; ;
  • Keep your codes confidential: never share your password with anyone;
  • If you are not comfortable with the Site (suspicion of fraudulent copying), do not use it and do not enter codes/passwords.

The information provided on the Website may be interrupted in the event of force majeure or other circumstances beyond the control of LEGENDRE GROUP or its Subsidiaries, or due to events beyond the control of LEGENDRE GROUP or its Subsidiaries.

ARTICLE 10 - DATA RECIPIENTS

According to the purposes described above, the Personal Data collected by GROUPE LEGENDRE and its Subsidiaries may be transmitted to the following recipients: the relevant LEGENDRE GROUP departments and/or divisions, Subsidiary departments and/or management, commercial partners, third-party service providers. GROUPE LEGENDRE and its Subsidiaries will only transmit your Personal Data to a third party in the following cases:

  • You have given your prior and express consent to the sharing of this information;
  • GROUPE LEGENDRE receives a request from a judicial authority or any administrative authority empowered by law to disclose such information in accordance with the legal provisions in force.

ARTICLE 11 - WHAT ARE YOUR RIGHTS?

11.1 - Right of access and rectification

You have the right to access your Personal Data. Following your request, GROUPE LEGENDRE can provide you with :

  • Categories of Personal Data processed ;
  • The purposes for which we collect your Data ;
  • The categories of recipients to whom we transfer your Data ;
  • Where possible, the length of time we keep your Data ;
  • The logic behind any automated processing of your Personal Data; ;
  • The source of Personal Data processed if it has not been collected from you.

Once we have received your request for access, accompanied by a copy of a valid form of identification, we will get back to you within a maximum of thirty working days. If your request proves to be complex, we will inform you of this within one month and will get back to you with the requested information within a maximum of two additional months. If you find that your Data is inaccurate or incomplete, you can ask us to rectify it. We take all necessary measures to ensure that your Personal Data is correct, up to date, complete and relevant, which is why we ask you to keep us informed of any changes. If we correct your Data and we have previously shared it with a third party, we will also notify the third party.

11.2 - Right to be forgotten

In certain specific cases, the law allows you to have your Personal Data deleted. This is the case in particular if the Data is no longer necessary for the Purposes for which we have collected it, if the processing of your Data is based exclusively on your consent and you decide to withdraw it, or if you have objected to the processing of your Data and LEGENDRE GROUP or its Subsidiaries do not have legitimate grounds which prevail over yours. LEGENDRE GROUP and its Subsidiaries may, however, retain your Personal Data when it is necessary for the establishment, exercise or defence of its legal rights or for LEGENDRE GROUP and its Subsidiaries to comply with its legal obligations. The LEGENDRE GROUP and its Subsidiaries will therefore be bound by the retention periods stipulated by the various laws.

11.3 - Right to limit processing

This particular right of opposition allows you to request GROUPE LEGENDRE and its Subsidiaries to temporarily block your Data in specific cases defined by law: GROUPE LEGENDRE and its Subsidiaries will then no longer be able to process your Data concerned for a defined period of time. This blocking may be requested:

  • Where the Data in question is inaccurate, incomplete, ambiguous or out of date, for the time necessary to enable us to verify the accuracy of your Data; ;
  • When their collection, use, communication or storage is prohibited; ;
  • When the Data are no longer necessary for the purposes of the processing ;
  • During the period necessary for LEGENDRE GROUP or its Subsidiaries to examine the merits of an opposition request.

If you have exercised this right, we may retain your Data, but we may not further process it except with your consent, for the establishment, exercise or defense of our rights (or those of another person), or as otherwise provided by law.

11.4 - Right to Data portability

By virtue of this right, you may request GROUPE LEGENDRE or its Subsidiaries to transmit your Personal Data to you or directly to another data controller, where technically possible. This right only applies to Data that you yourself have provided and that is processed automatically, either under contract or with your consent.

11.5 - Right to withdraw your consent

Where the processing of your Data is based on your consent, you have the right to withdraw this consent at any time. However, such withdrawal will not affect the lawfulness of the processing carried out during the period prior to your withdrawal of consent.

11.6 - Right of objection

You always have the right to object, without justification and at no cost, to the use of your Data for prospecting purposes. In this case, your Data will no longer be used for this purpose. You also have the right to object, for reasons relating to your particular situation, to any processing of your Personal Data that is based on our legitimate interests. However, your request will not be acted upon if our legitimate interest prevails over yours or if the processing of your Data is required for the establishment, exercise or defense of our legal rights.

ARTICLE 12 - HOW TO EXERCISE YOUR RIGHTS OR LET US KNOW THAT YOU NO LONGER WISH TO RECEIVE MARKETING OFFERS?

To exercise your rights, you can send us your dated and signed request, accompanied by a legible copy of both sides of your identity card, being as precise as possible:

  • By post to : Service juridique- DPO- Groupe Legendre - 5, rue Louis Jacques Daguerre, 35136 SAINT-JACQUES-DE-LA-LANDE.
  • By e-mail to: dpo@groupe-legendre.com

Upon receipt of your complete request, we will respond within a maximum of 30 calendar days. For any additional copies requested in connection with the exercise of your right of access to your Personal Data, we are entitled to charge you a reasonable amount based on administrative costs.

ARTICLE 13 - PERSONAL DATA POLICY RELATING TO MINORS

The Sites are not intended for minors. However, access to the Sites is not reserved for adults, as they do not contain any content prohibited to minors under the age of eighteen (18). The Site forms and questionnaires are not intended to collect information on minors. If information is collected on a minor via our Sites, the minor's legal representative may contact LEGENDRE GROUP to rectify, modify or delete this information.

ARTICLE 14 - LIABILITY

By using the Site, you accept that you are aware of your rights and of the related procedures. Furthermore, GROUPE LEGENDRE may not be held liable in the event that :

  • The voluntary or involuntary use of all or part of your Personal Data by a third party;
  • In the event that your Personal Data is erroneous or not updated by you.

ARTICLE 15 - WHO SHOULD YOU CONTACT IN THE EVENT OF A COMPLAINT?

In the event of a complaint concerning the processing of your Personal Data, you may submit a complaint to the Commission nationale de l'informatique et des libertés at the following address: Commission nationale de l'informatique et des libertés 3 Place de Fontenoy TSA 80715 75334 PARIS CEDEX 07 Tel: 01 53 73 22 22 Fax: 01 53 73 22 00

ARTICLE 16 - MODIFICATION OF OUR PRIVACY POLICY

We may modify this Privacy Policy from time to time, particularly in the event of the addition of new services. We invite you to consult this document regularly in order to take note of any changes or updates made to the Privacy Policy.