Greenbull Group Site Privacy Policy
In force on 1Er October 2024
SECTION 1. PREAMBLE
This Privacy Policy has been written in accordance with the General Data Protection Regulation (” RGPD ”) and Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, amended by Law No. 2018-493 of June 20, 2018 (the” Personal Data Legislation ”), and aims to inform users (” Users ”) of the website www.greenbull.com (the” Site ”):
· On how their personal data is collected. Any information that makes it possible to identify a User/Customer is considered to be personal data. As such, it may be: his first and last names, his age, his postal or email address, his location or even his IP address (non-exhaustive list);
· On the rights they have with respect to this data;
· On the person responsible for processing the personal data collected and processed;
· On the recipients of this personal data.
This policy complements the Legal Notice, the General Conditions of Use, and the Cookie Use and Management Policy that can be consulted by Users at any time on the Site.
The User must accept this Privacy Policy when validating their contact form on the Site, by ticking the box provided for this purpose.
SECTION 2. DATA CONTROLLER AND DATA PROTECTION OFFICER
2.1 Responsible for the treatment
Users' personal data is collected by GREENBULL GROUP, a simplified joint stock company with a share capital of 1,282,389.05 Euros, whose head office is located at 400, Promenade des Anglais, Le Nizza, 06200 - NICE, 06200 - NICE, registered with the Nice Trade and Companies Register, registered with the RCS of Nice under the number 834111 122, represented by its president, Mr. Guillaume MONGES (” Treatment Manager ”).
The Personal Data Controller can be contacted as follows:
By post to the following address: 400, Promenade des Anglais, Le Nizza, 06200 NICE
By email: contact@greenbull.group
By phone at: 0428 70 57 54
2.2 Data Protection Officer
The Data Protection Officer of the Data Controller is:
Mrs. Julie BELIZON
400 Promenade des Anglais
Le Nizza
06200 - NICE
04 28 70 57 54
dpo@greenbull.group
If you feel, after having contacted us, that your “Information Technology and Freedoms” rights are not respected, you can send information to the CNIL.
SECTION 3. PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA
In order for Users to contact Greenbull Group, the Data Controller may be required to collect personal data in accordance with Personal Data Legislation.
In accordance with the provisions of the Personal Data Legislation, the collection and processing of User data respect the following principles:
· Lawfulness, loyalty and transparency: data may only be collected and processed with the consent of the User who owns the data. Each time personal data is collected, the User will be informed that his data is collected, and for what reasons his data is collected as indicated below;
· Limited purposes: the collection and processing of data are carried out to meet one or more purposes determined in this Privacy Policy;
· Minimization of data collection and processing: only the data necessary for the proper execution of the objectives pursued by the Site are collected;
· Retention of data reduced over time: the data is kept for a limited period of time, of which the User is informed;
· Integrity and confidentiality of data collected and processed: the Data Controller is committed to guaranteeing the integrity and confidentiality of the data collected.
In order to be lawful, and in accordance with the requirements of the Personal Data Legislation, the collection and processing of personal data may only take place if they comply with at least one of the conditions listed below:
· The User has expressly consented to the treatment;
· The processing is necessary for the proper execution of a contract;
· The processing meets a legal obligation to which the Data Controller is subject;
· The processing is explained by a necessity linked to the protection of the vital interests of the person concerned or of another natural person;
· The processing may be explained by a necessity linked to the execution of a mission in the public interest or in the exercise of public authority vested in the Data Controller;
· The processing and collection of personal data are necessary for the purposes of legitimate and private interests pursued by the Data Controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject prevail that require the protection of personal data, in particular when the data subject is a minor.
SECTION 4. TYPES OF PERSONAL DATA COLLECTED AND PROCESSED AND PURPOSES OF PROCESSING
The Data Controller collects, stores and processes personal data concerning the User for the following purposes:
When personal data is recorded, the User is informed of the duration for which his data will be kept, and when this duration cannot be specified, the Data Controller informs him of the criteria used to determine it.
SECTION 5. RECIPIENTS OF PERSONAL DATA
In order to be able to respond to Users' requests, personal data is collected by the Data Controller.
The corresponding database has been processed in accordance with Personal Data Legislation.
SECTION 6. PERSONAL DATA MANAGEMENT
The data collected is intended for the services of the Data Controller.
They cannot be used for commercial purposes.
SECTION 7. TRANSMISSION OF PERSONAL DATA TO THIRD PARTIES
Personal data may also be used for the purposes of managing Users' contacts, by entities that are part of the same group of companies as GREENBULL GROUP (the” Affiliated Companies ”).
Some data may be processed abroad (European Union or outside the European Union).
In this case, GREENBULL GROUP takes the necessary measures with its Affiliated Companies in order to guarantee an adequate level of protection of Customer data in full compliance with applicable regulations.
If the Affiliated Companies are not located in a country with legislation considered to offer adequate protection, they will then have previously signed the “standard contractual clauses” of the European Commission or will be subject to binding internal rules approved by the authorities.
Apart from these Affiliated Companies, the Data Controller may communicate the relevant personal data concerning the User to any potential or entitled acquirer/investor in the context of a merger, consolidation, change of control or other restructuring or other restructuring or any other transfer operation in which the Data Controller would participate.
The Data Controller may also communicate all or part of the personal data to the authorities when required by law and/or competent authorities.
SECTION 8. LIMITATION OF TREATMENT
Unless the Customer expresses his express agreement, his personal data is not used for commercial, advertising or marketing purposes.
SECTION 9. DURATION OF PRESERVATION OF PERSONAL DATA
The Data Controller will keep the data collected for the period necessary for the purpose of the processing:
- 10 years maximum from the end of the financial year for data kept for accounting and fiscal purposes, in accordance with article L.123-22 Commercial Code;
- 10 years maximum from the validation of the order (concerning amounts greater than 120€), in accordance with article L. 213-1 and D. 213-1 and D. 213-2 of the Consumer Code, in order to deal with possible complaints or to manage disputes;
- A maximum of 3 years from their collection or from the last contact from the prospect for prospect data in accordance with article 5 of Deliberation No. 2016-264 of July 21, 2016;
- A maximum of 13 months from the date of navigation for cookies, in accordance with article 5 of the CNIL Deliberation No. 2019-093 of July 19, 2019.
GREENBULL GROUP may keep certain personal data beyond the deadlines announced above in order to fulfill its legal or regulatory obligations.
SECTION 10. DATA HOSTING
As mentioned in the General Conditions of Use and the Legal Notice, the site www.greenbull.com is hosted by WEBFLOW INC., a foreign company incorporated under the laws of the State of Delaware, USA, whose head office is located at 398, 11th Street, 2NDFloor, San Francisco, California, 94103, USA.
SECTION 11. SECURITY AND CONFIDENTIALITY
The Data Controller implements organizational, technical, software and physical digital security measures to protect personal data against alteration, destruction and unauthorized access. However, it should be noted that the Internet is not a completely secure environment and the Data Controller cannot guarantee the security of the transmission or storage of information on the Internet.
SECTION 12. IMPLEMENTATION OF USERS' RIGHTS IN TERMS OF DATA COLLECTION AND PROCESSING
In application of Personal Data Legislation, Users have the following rights:
12.1 Right to access, rectify and right to be forgotten
They can read, update, modify or request the deletion of data concerning them directly on their Personal Space or by sending an email with the exact mention of the information they wish to have deleted as well as their identity.
If they have one, they have the right to request the deletion of their Personal Space by unsubscribing on the Site or by sending an email with the exact mention of the information they wish to have deleted as well as their identity.
In case of doubt about the identity of the User, the Data Controller reserves the right to ask him to attach any document allowing him to prove his identity, for example to avoid identity theft.
They can exercise their right of access to know the personal data concerning them.
12.2 Right to data portability
The User has the right to request the portability of his personal data, held by the Site, to another site, by sending an email with the exact mention of the information he wishes to have deleted as well as his identity.
12.3 Right to limitation and opposition to data processing
The User has the right to request the limitation or to oppose the processing of his data by the Site, without the Site being able to refuse, except to demonstrate the existence of legitimate and compelling reasons, which may prevail over the interests and rights and freedoms of the User, which may prevail over the interests and rights and freedoms of the User.
12.4 Right to determine the fate of data after death
The User is reminded that he can organize what should be the future of his data collected and processed if he dies, in accordance with law No. 2016-1321 of October 7, 2016.
12.5 Right to refer the matter to the competent supervisory authority
In the event that the Data Controller decides not to respond to the User's request, and the User wishes to contest this decision, he is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent judge.
These rights, as long as they do not oppose the purpose of the processing, may be exercised by sending a request by post or email to the Data Controller whose contact details are indicated in article 2.1 of this Privacy Policy.
In order for the Data Processing Manager to grant his request, the User may be required to provide him with certain information such as: his first and last names, his e-mail address as well as his account number, personal space or subscriber number.
The Data Controller must provide a response within a maximum of thirty (30) calendar days. In case of refusal to grant the User's request, the User must be motivated.
The User is informed that in the event of refusal, he may file a complaint with LACNIL (3, Place de Fontenoy, 75007 PARIS) or refer the matter to a judicial authority.
The User is also informed and accepts that the Data Controller reserves the right to record and keep telephone conversations passing through his call center.
In addition, in accordance with article L. 223-1 of the Consumer Code, the User also has the right to register on the list of opposition to Bloctel telephone canvassing.
ARTICLE 13: CONDITIONS FOR MODIFYING THE PRIVACY POLICY
The publisher of the Site www.greenbull.com reserves the right to modify this Policy at any time in order to ensure that Users of the Site comply with current law.
The User is invited to read this Policy each time he browses the Site, without the need to formally notify him.