COMPTA EMERGING BUSINESS (“CEB”) is fully committed to respect for the privacy and protection of personal data in general, as well as to the processing thereof in a responsible manner and in compliance with the applicable national legislation and with the General Data Protection Regulation (GDPR).
1. Personal data processing performed or participated by CEB
When CEB uses personal data in the context of a request, order, transaction or agreement (or for the preparation thereof), or to provide the holder with services requested by him (such as a website), this information is necessary for the implementation of the agreement concluded with the holder.
When CEB uses personal data for the purpose of marketing, improving or developing its products or services for security reasons, or for regulatory requirements outside the scope of the agreement or request of the holder, this is done on the basis of the legitimate interests of CEB, third party, or, if necessary, with the express consent of the holder.
CEB may collect personal data for the following purposes:
a. Internet sites and other online services
By visiting one of our websites or by using our online service, CEB registers the information necessary to grant access to the owner, for the operation of the site and for compliance with legal and security requirements regarding the operation of the site, such as such as passwords, IP address, and browser settings. We also collect information about the incumbent’s activities during the visit and to customize the experience of using the site to, for example, record the incumbent’s preferences and settings and collect statistics to help us improve and develop our products and services.
b. Requests for information, orders or support
When a holder contacts CEB in the context of a request for information, to order a product or service, to request support, to participate in a forum or other social or collaborative tool, we collect the information necessary to respond to the request, to grant access to the product or service, to provide support and to contact the holder. For example, we collect the name of the holder and contact information, details of the request and agreement between the holder and CEB to answer, send and invoice the request, or information of customer satisfaction surveys. We retain such information for administrative purposes, in defense of CEB’s rights, and in the context of the relationship with the owner. When a holder provides the name and contact information to register in the context of such a request, that registration may be used in the future to identify him when visiting our sites. To order the services and products, it may be necessary to register a holder identifier, which may also allow you to customize and control the owner’s privacy settings.
c. Cloud services
We collect information about the use of the CEB cloud services by the incumbent to allow the operation of product features, to improve the user experience, to customize the interactions with the incumbent, to inform our customers about the general use of the services, to provide support and improve and develop our products and services.
d. Contact with potential/customer, partner and supplier partners
Within the scope of CEB’s relationship with its customers/potential customers, partners and suppliers, professional contact information (such as the name, contact details of the company, position or function of its employees, subcontractors, consultants and authorized) for the purpose of contract management, response to requests, supply of products and services, provision of support, billing and management of services or relationship.
e. Visits to installations
CEB records individual visits to its own premises (name, identification and contact information professionals) and uses video surveillance systems in some places for the safety of people and property.
f. Marketing actions
Most of the personal information we collect comes from direct interactions with them. When a person registers at an event, we may collect information within the organization of the event and during an event, such as participation in sessions and survey results. We combine the personal data we collect to develop aggregate analysis and business information for the conduct of our business and for marketing purposes. The holder may choose to receive information by e-mail, telephone or postal mail about our products and services, or to register in subscriptions. When you visit our sites or use our services, CEB may provide you with personalized information. The holder always has the possibility to cancel the receipt of such personalized communications by sending an email to email@example.com.
In the context of a job application, advertised on a CEB website or otherwise disclosed, the holder may transmit personal data to the CEB, for example through a CV. CEB may use this information internally to respond to the contact of the holder or to analyze the application for employment.
2. Sharing of personal data
Where appropriate, CEB may have to share personal data with selected partners to assist in the provision of products or services to the holder or to the undertaking in which it performs or to respond to its requests with the authorization of the holder. When selecting suppliers and partners, CEB takes into account their data processing processes. If CEB decides to sell, buy, merge or otherwise reorganize its business, such transaction may involve the disclosure of personal data to buyers or potential buyers, or the receipt of such data from sellers. It is CEB’s practice to seek to ensure adequate protection for personal data in these types of transactions. In certain circumstances, personal data may be subject to disclosure to public entities for legal proceedings, orders or legal proceedings. CEB may also share the proprietor’s personal data to protect the rights or property of CEB, its business partners, suppliers, customers or others, whenever it deems that such rights or property have been or may be affected.
3. Security and integrity of personal data
The purpose of CEB is to protect personal data and preserve its accuracy. CEB implements adequate physical, organizational and technical protection measures to protect the holder’s personal data against unauthorized access, use or disclosure. CEB also requires its suppliers to protect such personal data against unauthorized access, use or disclosure. CEB applies the best practices of the International Information Security Management Standard ISO / IEC 27001: 2013 throughout its activity.
4. Retention Period
CEB does not retain personal data for longer than is necessary to fulfill the purposes for which they were collected, including security of processing in accordance with legal and regulatory obligations (eg for audit or accounting purposes), litigation regarding the treatment, and for the establishment, exercise or defense of lawsuits. As circumstances may vary according to context and services, other CEB specific additional communications may provide more detailed information on the retention terms applicable in each case.
5. How to contact us
6. Rights of the holder of personal data
The holder may at any time request access to, update or correction of their personal data. If personal data are processed on the basis of legitimate interests, the holder has the right to object to processing based on his or her specific situation. You also have the right to request that your personal data be deleted, to request their portability and to oppose the receipt of direct marketing by contacting firstname.lastname@example.org. If you consider that the processing of your personal data by CEB is not in compliance with the national legislation or the RGPD, please contact us by e-mail at email@example.com.
Miraflores, May 24, 2018.