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Privacy Notice

Consolis Holding SAS is a société par actions simplifiée registered under French law with the Company Registry of Paris under number 494 052 327 R.C.S. Paris, having its registered office at 4, rue du Général Foy, 75008 Paris.  This privacy notice (hereinafter “Privacy Notice”) explains how Consolis and its affiliates in (together ”Consolis”, ”controller”, ”we” ”us”), collect, store, use, disclose and transfer (hereinafter “process”) your personal data.

We understand that your privacy is important to you and that you care about how information relating to you (“Personal Data”) is used. Please read this Privacy Notice carefully to be informed about how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us in the event you have a complaint.

1. Processing Activities covered under this Privacy Notice

We collect, use, disclose, and process your Personal Data in our role as a Data Controller when you:

  • Interact or use our website or any other service that displays or links to this Privacy Notice, including accessing or downloading materials from the resources or portals available to you on this website or requesting information about our services (our “Website”);
  • Visit our branded social media pages;
  • Visit our offices;
  • Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, or texts;
  • Log in in our portal using your client credentials;
  • Provide your Personal Data for the purposes of administering or use our Services and managing our relationship with you in any manner, e.g., setting up an account or collecting your Personal Data to process an invoice for accounting purposes, or creating an account for you to access any of our portals;
  • Register for, attend or take part in our events or webinars (collectively, “Events”);
  • Contacting us through our contact form available in our website;
  • Registering or sending information through our career portal, sending your personal details by email, or when you apply through any of our external recruiters,
  • Subscribing to our newsletter, mailings, press releases, reports, annual reports and new from our dedicated investors section.
  • Participate in surveys, research or other similar data collection facilitated by us.
 

2. Personal Data we collect about you

The Personal Data we collect directly from you may include (online) identifiers, contact details, professional or employment-related data, financial account data, commercial data, visual data, and internet activity data, as well as any other data you choose to provide us. We may collect such information, for example, in the following cases:

Situations

Categories of Personal Data

If you express an interest in obtaining additional information about our Services or Investing opportunities; communicate with us via a phone call, e-mail address; visit our offices; use our contact for or similar features; register to receive communications, newsletters; sign up for an event or webinar; participate in a survey (e.g., customer satisfaction); use our Services; download pictures from our Media Gallery or otherwise communicate with us.

Contact information, such as your name, job title, company name, address, phone number, email address, other information voluntarily chosen to share with us.

If you attend an Event

Attendee contact details which may include name, title, company name, address, country, phone number, email address, image and video.

If you visit our Website or interact with us via social media

Information about your device and your usage of our Websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data using cookies, web beacons, or similar technologies, any information you choose to share with us.

If you use our Services/ customer portals

Name, business contact details like e-mail and business address, job title, company name, phone number, financial company bank account, transaction information, e-mails that might contain personal information, other information voluntarily chosen to share with us.

If you are a supplier or service provider to Consolis (or work for a supplier or service provider)

Contact information, payment and billing information.

When you submit an application for any of our vacancies through any of our channels, such as the career portal, email, etc.

Name, contact details, professional background, and all the job-related information that you voluntarily choose to provide to us.

If you provide us Personal Data relating to other individuals (e.g., employees, individuals working for a client, an affiliate or a service provider), you warrant that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Notice.

If you believe that your Personal Data has been provided to us improperly or want to exercise your rights relating to your Personal Data, please contact us by using the contact information detailed in Section 11.

Personal Data we collect from other sources

From Customers / Service Providers/ Vendors: We receive and store your personal data that our Customer or Vendor has provided to us in order to satisfy contractual obligations. For example, when setting up new customers for our Services, we collect Personal Data, such as name and e-mail address, to provide our clients with the Services. The types of information we may collect directly from our customers and their employees include names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information, as well as other contact or other information they choose to provide us or upload to our systems in connection with the Services. Other personal information we process may vary depending on the requirements specified in customer contracts. In those cases, we assume that those entities have an appropriate legal basis to share personal data with us.

3. Purpose and legal basis for collecting your Personal Data:

We collect and process your Personal Data for the following purposes and relying on the following legal basis:

Purpose

Description

Legal Basis

Providing and improving our Websites (including our social media pages)

We process your Personal Data to operate and administer our Websites and to provide you with the content you access and request.

We process your Personal Data to analyze overall trends and help us improve the user experience on our websites.

Our legitimate interest in providing relevant online content and well-functioning Websites to our customers and prospective customers regarding our service offering and related information

Displaying personalized interactions, advertisements, and content 

We process your Personal Data to conduct market research, advertise to you, provide personalized information about us on and off our Websites and to provide other personalized content and interactions with you based upon your activities and interests.

Our legitimate interest in providing best-in-class Services to our customers, including advertising our Services or, where necessary, to the extent you have provided your prior consent

Registering visitors to our premises 

We process your Personal Data in our registration form for security reasons

Our legitimate interest in ensuring the safety of our offices, staff, visitors and our confidential information against unauthorized access

Managing Event and webinar registrations

We process your Personal Data to plan and host Events or webinars for which you have registered or that you attend, including sending related communications to you

(i) Your consent when providing us the information; (ii) Our legitimate interest in providing Services requested by individuals or companies

Sending communications, administering surveys, and conducting research

We process your Personal Data to send you marketing information, product recommendations and other non-transactional communications

Your consent to receive any direct marketing or communication from us or when you are already a registered client.

Recording phone calls, videocalls webinars.

We process your Personal Data, including recording phone calls (in accordance with applicable laws) for quality assurance, and administration purposes

Consent or our legitimate interest in maintaining the high quality of our phone calls with customers and suppliers.

Handling contact and user requests

We process your Personal Data, if you request user support, or if you contact us by other means including but not limited to via phone

(i) performance of a contract or (ii) your consent to fulfill your requests and communicate with you

Providing, developing and optimizing the performance of the Services 

We process your Personal Data to develop, optimize, provision, and improve the performance of the Services and to satisfy our obligations under the applicable terms of use

Our legitimate interest to provide and administer our Services in line with customer expectations
Where applicable, compliance with legal obligations incumbent on us.

Managing our customer and user accounts

We process your Personal Data (including Usage Data) to manage customer and user accounts generally, such as billing, customer correspondence, customer relationship management, and maintaining your user account in our portal.

Our legitimate interest in the management of customer and user accounts and performance of a contract when applicable.

Maintaining our security 

We process your Personal Data (including your Usage Data) for the purposes of maintaining Consolis own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect Consolis or its Services

Our legitimate interest in promoting the safety and security of Consolis generally and to protect our rights and the rights of others

Managing job applications

We process your Personal Data (including your Usage Data) in relation to the position you apply for. The purpose of talent acquisition, including assessing capabilities, reference checks.

(i) Your consent when you submit and application though any of our channels. (ii) Performance of a contract.

Undertaking financial reporting, managing payments, preparing internal reports, and business modelling 

When necessary we process your Personal Data (including your Usage Data) for the purposes of financial reporting, modelling purposes (e.g., forecasting), and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you or the company you represent.

Our legitimate interest in meeting our obligations associated with the reporting of our finances, management of our business operations, and necessary for the performance of a contract.

Aggregating data

We process your Personal Data (including your Usage Data) for the purposes of aggregating this information to ensure that it is no longer identifying you.

Our legitimate interest in minimizing the amount of Personal Data processed as part of the noted processing activity

Complying with legal obligations

We process and/or disclose your Personal Data (including Usage Data) to the extent required when cooperating with competent authorities, regulators or relevant jurisdictions to ensure the compliance with legal requirements under applicable laws and/or protect our rights.

Legal obligation incumbent on Consolis or any of its affiliates like a law enforcement or national security request, to establish, exercise or defend legal claims, or our legitimate interest in protecting against misuse or abuse of our Websites or Services, protecting company property or the safety of our premises and employees, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes

 

4. Recipients of your Personal Data:

Where applicable, we share your Personal Data in the following circumstances:

Vendors, contractors, and other service providers

Consolis may share personal data with service providers or other third parties that carry out functions or services in our behalf or that assist or enable our operations. These Service Providers include hosting, email and collaboration service providers website analytics companies, freelancers, product feedback or help desk/customer support and CRM service providers, professional advisors, head-hunters, the website/ platform in which you submitted your employment application (if applicable), travel agencies and travel service providers, payrolling vendor scheduling programs and IT processing systems.

Business transfers:

Other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or insolvency.

We may also transfer your personal data to law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.

Consolis Group Companies, partners and affiliates

We may also share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Notice. Personal Data is transferred between Consolis entities to ensure efficient and effective business operations and to enable Consolis entities to provide customer, sales, marketing, human resource, finance, information technology, legal, quality assurance, software/product development, and other support services.

5. Marketing Communications

You can opt-out of receiving promotional or marketing communications from us at any time, by using the unsubscribe link in the email communications we send, or by contacting us using the details provided in Section 11. Please note that if you have accounts for our Services, we will still send you non-promotional communications, like service-related emails.

6. Period of Retention of Personal Data

The Personal Data being processed for the purposes of collection described in Section 3 of this Privacy Notice. We will retain the Personal Data in observance of the principles of proportionality and necessity and, in any case, until the purposes of the processing have been achieved and in accordance with any legal obligations that we are subject to.

In case you have a contractual relationship with the Consolis, Personal Data shall be stored and processed at least as long as there is such a contractual relationship.

We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements.

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any Personal Data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

7. Transfer of your Personal Data

Your Personal Data will be processed within the European Economic Area (EEA) and stored on servers located within the EEA whenever possible. However, Your Personal Data may be transferred to and stored by us or by our affiliates and third parties described in Section 3 above, located in countries outside the EEA. Consequently, your Personal Data may be processed outside your jurisdiction, and in countries that may not provide for the same level of data protection as your jurisdiction. However, we ensure that the recipient of your Personal Data provides an adequate level of protection, for example by entering into appropriate data processing agreements and, if necessary, standard contractual clauses or an alternative lawful data transfer mechanism.

8. Data Subject Rights

You have the following rights in relation to your Personal Data:

  • Right of access: You can contact us any time to request about the Personal Data we may hold and request a copy and a list of purposes for which your Personal Data is processed.
  • Right to correction: you have the right to require us to correct mistakes in your Personal Data should you notice any.
  • Right to erasure (“right to be forgotten”): you have the right to require us to delete your Personal Data—in certain situations.
  • Right to restriction of use: you have the right to require us to restrict use of your Personal Data in certain circumstances, e.g. if you contest the accuracy of the data
  • Right to data portability: you have the right to receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
  • Right to object: you have to object at any time to your Personal Data being used for direct marketing (including profiling) and in certain other situations to our continued use of your Personal Data, e.g. where we use your Personal Data for our legitimate interests. We may however continue to process your Personal Data if, even if you object thereto, we have compelling legitimate grounds for the processing that override your integrity interest.
  • Right to withdraw consent: you have the right to withdraw your consent at any moment where you have provided it previously. The withdrawal of your consent does not affect the lawfulness of processing based on consent prior to the withdrawal.
  • Right not to be subject to decisions without human involvement: you have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
  • Right to complaint: you can submit a complaint regarding our processing of your Personal Data to your local data protection authority.

You can exercise your rights using the contact details provided in Section 11.

Your Personal Data will be processed when responding to these rights requests and we may request you to provide additional documentation or information to verify your identity before fulfilling your request. We will respond to your request or complaint as soon as possible and you will receive an answer no later than 30 days from receipt of your request. The response time may vary according to your location and applicable regulations. If we are unable to comply with your request due to an exception or limitation, we will explain this in writing. If we need more time, we will inform you of the reason and extension period in writing.

9. Security

We take appropriate precautions including organizational, technical, and physical security measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, Consolis cannot fully guarantee the security of the information since it may rely on the use of different security systems including the system you are using to communicate with us. You are solely responsible for protecting your password, limiting access to your devices, maintaining up-to-date and patched version of software and operating system, and signing out of our Website after your sessions.

In case a security incident occurs, we have a data breach response in accordance with the applicable regulations.

10. Changes to the Privacy Notice

We are constantly trying to improve our Website and Services, so we may need to change this Privacy Notice from time to time. You can see when this Privacy Notice was last updated by checking the date at the bottom of this page.

11. Contact Us

For any questions or concerns about this Privacy Notice, contact us by using the information below:

When contacting us please include your request or the right you want to exercise and provide enough information to identify yourself (e.g. your full name, if applicable, reference number) and any additional identity information we may reasonably request from you.

Last updated, May, 10, 2024.