POLICY FOR COOKIE MANAGEMENT AND CONFIDENTIALITY OF PERSONAL DATA

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Cookies are small text files placed on the visiting user’s computer, phone or tablet and which can be used by websites to improve the navigation experience.

The law stipulates that we can only store cookies on your device where they are strictly necessary for our site to function. For all other types of cookies, we require your prior agreement to storage.

This site therefore uses various types of cookies. Certain cookies are placed by the third-party services appearing on our pages.

You can change or withdraw your consent at any time, on our website. Likewise, you can manage cookies from the websites you visit (refuse them, accept them, select them) via your browser.

If you want to know more about who we are, how to contact us and how we process your personal data gathered via our site, you can click on our legal notice and below that our policy on personal data.

LIST OF COOKIES TO BE FOUND IN THE SITE SETTINGS BEFORE ACCEPTING THEM

The current cookies on the altuscoating.com site are:
– Required: Zoho CRM, the purpose of which is managing the database of customers and newsletter subscribers, expiring at the end of six months
– Functional: Vimeo, the purpose of which is to display videos, expiring at the end of 12 months
– Statistical: Google Analytics, the purpose of which is to provide site consultation statistics, expiring at the end of two years
– Marketing: Active Contact, the purpose of which is to distribute the newsletter, expiring at the end of 30 days
Your consent applies to the following domains: altuscoating.com.

POLICY FOR MANAGEMENT AND CONFIDENTIALITY OF PERSONAL DATA GATHERED BY ALTUS COATING

When you visit and navigate on the Altus Coating internet site which can be accessed at the following address, altuscoating.com (the “Site”), we gather data, which may or may not be anonymized.

The same applies if you are prospective customers, customers, suppliers or subscribers to Altus Coating.

Described below, you will find in our Confidentiality Policy the manner in which this data is gathered, processed and protected by Altus Coating, this being in application of the legislative and regulatory texts in force, including Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of

personal data and on the free movement of such data, known as the “GDPR”.

1 – THE DATA PROTECTION OFFICER

The data protection officer (DPO) for our company is Mr Éric Pertus.

His address is: Altus Coating “Service des Données Personnelles” (“Personal Data Dept.”), 301, rue du 19 mars 1962 – 39570 Courlaoux.

+33 (0)3 84 24 18 77- info@altuscoating.com.

All requests regarding the processing and safeguarding of personal data gathered by Altus Coating should be addressed to him.

2 – DATA SUBJECTS COVERED BY THE MANAGEMENT POLICY

Altus Coating processes the personal data of the following persons:

Visitors to the Site and internet surfers

Definition: Visitors or internet surfers who navigate on the Site, whatever their status with respect to Altus Coating.

Their data is collected via Cookies (see our Cookies Policy above) and/or via the Site contact form if they are asking us a question, for example, or if they decide to contact us directly by email or by telephone.

Prospective customers

Definition: Any natural person and/or corporate entity who are prospective customers of Altus Coating met through trade salons or via the intermediary of our commercial agents of through any other means.

It is possible that someone who contacts us via the Site is in fact a prospective customer or becomes one.

In this case, his data is initially processed as that of a visitor, and then later classified into the folder for prospective customers. The same applies for the other categories.

Customers

Definition: Altus Coating customers, being natural persons or corporate entities or their representatives.

Suppliers

Definition: Suppliers of Altus Coating products and/or services, being natural persons or corporate entities or their representatives.

Subscribers

Definition: These are any natural person or corporate entity who has voluntarily signed up for our Newsletter via our Site or through any other means, with prior consent being given.

A subscriber can also be a customer, a prospective customer, a visitor or a supplier.

3 – THE DATA GATHERED, AND ITS USE BY ALTUS COATING

Depending on the category of the data subject, the personal data gathered by Altus Coating is as follows and is used as shown:

Visitors and internet surfers

The data is gathered via the “contact form”: Surname, telephone number and email address, in order to respond to requests.

If someone contacts us directly via email, we gather: The person’s email address, surname and first names, and potentially, if included in the email, telephone number, and the name and address of the person’s company.

The purpose of using the data is to respond to requests.

The data is not stored unless it is reclassified into another of the aforementioned categories.

Prospective customers

The purpose of using the data is to respond to requests from prospective customers submitted via the Site or directly to Altus Coating via any other means (freely given consent). Prospective customers also receive marketing, communications and publicity emails from Altus Coating via a CRM software program called “Zoho” (legitimate interest). Unless consent has been previously received, prospective customers are not subscribers.

The data from prospective customers is stored for a maximum of 18 months, unless they are reclassified into another category because the Prospective Customer becomes a customer or a subscriber.

Customers

The data gathered is: Surname, first name, position, company name and full details of the company (postal address, email address and telephone number), direct contact details for the individual (landline and/or mobile phone numbers and work email address).
Likewise, by virtue of their capacity as customer, the customer’s accounting and tax or regulatory data is gathered.

This data enables the processing of orders, the preparation of quotations and invoices, and also tracking of consignments and the performance of after-sales services (contractual and legal basis).

Customers can also receive marketing and communications data (Salon details, for example) or advertising data via an email sent via Zoho (legitimate interest). With their prior consent, customers can receive the Newsletter, which is similarly sent via Zoho (freely given consent).

Customer data is stored while the customer is active, i.e., while the customer remains an Altus Coating customer. After 2 years without activity by a customer, the data relating to the customer is retained for a maximum of 5 years to satisfy the legal and financial obligations, and in particular the accounting and legal obligations, unless there are legal stipulations or obligations requiring a longer time.

The customer data can be transferred to processors, who are suppliers of services for Altus Coating such as accounting services (accountants), legal services (lawyers), marketing services or advertising services, solely for the purpose of performance of the said services and to comply with the legal and regulatory obligations. In this case, it is possible that the personal data of customers may be stored for longer by these data processors (specifically 30 years in the event of disputes, the legal period of retention for lawyers – contractual or legal basis)

Suppliers

The data gathered is: Surname, first name, position, company name and full details of the company (postal address, email address and telephone number), direct contact details for the individual (landline and/or mobile phone numbers and work email address). Likewise, by virtue of their capacity as supplier, the supplier’s accounting and tax or regulatory data is gathered.

This data is used solely in the context of the contractual relationship existing between Altus Coating and the supplier, enabling the processing of orders placed by Altus Coating with these suppliers, the payment of invoices and also tracking of services or products ordered (contractual and legal basis).

Supplier data is stored while the supplier is active, i.e., while the supplier remains an Altus Coating supplier. After 2 years without activity by a supplier, the data relating to the supplier is retained for a maximum of 5 years to satisfy the legal and financial obligations, and in particular the accounting and legal obligations, unless there are legal stipulations or obligations requiring a longer time.

Subscribers

This data is used solely in the context of subscription to the Altus Coating Newsletter via Zoho, and with the prior consent of the subscriber (freely given consent).

The subscriber’s data is retained while he remains a subscriber. He can unsubscribe at any time. In that case, his data is deleted.

4 – TRANSFER OF DATA GATHERED TO OUTSIDE THE EUROPEAN UNION

None of the personal data gathered by Altus Coating is sold to third parties.

The data gathered from subjects who are recipients of marketing and advertising actions via email, for example, or via subscription to the Newsletter are stored in the Zoho CRM, which is hosted in several third countries.

The measures taken by Zoho to comply with the regulations are described here: https://www.zoho.com/gdpr.html.

5 – SECURITY AND CONFIDENTIALITY MEASURES

Altus Coating has established and implemented security measures across all aspects of the process for managing the personal data collected, in order to prevent unauthorized access to this data, falsification of data, disclosure of data or destruction of data. These measures are both technical and human in nature (regular changes of passwords, compartmentalization of servers and access, alarms, etc.). The personal data is also anonymized insofar as possible.

It is also noted that the data subjects are also responsible for the quality and reliability of the data they transmit to Altus Coating, and that they should ensure they do not transmit viruses, notably when making contact via email.

Altus Coating may be required to verify the data and thus the personal data gathered, to ensure its accuracy and to update it. In this eventuality, the data subjects are informed that public databases such as Infogreffe, Data Inpi or Sirene may be consulted.

6 – DATA SUBJECT RIGHTS

Data subjects whose data has been gathered have a right of access, of rectification, of restriction of processing and of objection to processing of their personal data and a right of erasure and portability of their data.

They may also lodge a complaint with CNIL, the French National Commission for Data Protection and Liberties: https://www.cnil.fr/fr/plaintes.

7 – UPDATES TO THE PERSONAL DATA MANAGEMENT POLICY

Altus Coating may update this Personal Data Management Policy at any time.