PERSONAL DATA PROTECTION POLICY
Total Eren, a company registered in the Paris Trade and Companies Register under number B812 962 736 and located at 37 rue La Pérouse, 75016 Paris, France (hereinafter “Total Eren” or “we”), is aware of its duties and obligations regarding the protection of personal data (hereinafter “the Data”). We are vigilant about using your Data responsibly while maintaining a confidential framework.
This policy covers the processing of Data by Total Eren, as Data Controller, in the context of its website, its contact mailbox, its administrative and legal procedures, its recruitments, and its discussions in relation to the implementation of its renewable energy projects (hereinafter “the Policy”). It is thus aimed at any external individual in connection with Total Eren who is concerned by the processing.
This Policy informs you about the Data that Total Eren may process; it explains how it is used and with whom it may be shared, and describes the measures taken to ensure its confidentiality and security.
The implementation of Data processing is governed in particular by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as “GDPR”.
The GDPR requires the Data controller to provide the data subject with a certain amount of information. In this context, Total Eren undertakes to comply with the regulatory provisions applicable to Data protection.
The purpose of this Policy is to explain in a concise, transparent and understandable way what processing may be carried out with your Data and what rights you have in relation to such Data.
If you have any questions, please contact us using the contact details in Section 12.
- APPLICABLE DEFINITIONS. 2
- DATA SUBJECTS. 2
- DATA PROCESSED.. 2
- USE OF YOUR DATA. 3
- DATA RECIPIENTS. 3
- TRANSFERS OUTSIDE THE EU.. 4
- PERIOD OF RETENTION.. 4
- DATA SECURITY. 5
- HOSTING OF OUR WEBSITE. 5
- YOUR RIGHTS AND HOW TO EXERCISE THEM.. 7
- UPDATING OF THE POLICY. 8
1. APPLICABLE DEFINITIONS
- Personal data
Information relating to an identified or identifiable natural person.
- Personal data processing
Operation or set of operations involving personal data, regardless of the process used (paper or electronic), such as recording or disclosure.
- GDPR – General Data Protection Regulation
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
- Data controller
Organization that determines the purposes and means of processing personal data.
Person or legal entity that processes personal data on behalf of the Data Controller.
- Data subject
Natural person whose personal data is processed.
2. DATA SUBJECTS
Total Eren may process Data provided by you:
- candidates in the context of a recruitment or an internship;
- VIE (international internship) participants within the framework of an assignment with Business France;
- internet users visiting our website total-eren.com;
- people sending a message to our mailbox firstname.lastname@example.org;
- users of Total Eren’s social networks;
- contacts for business discussions related to our renewable energy projects;
- providers, suppliers, consultants or partners in the context of the execution of a contract;
- investors, shareholders or directors as part of the governance of the company.
3. DATA PROCESSED
The following categories of Data are processed:
- contact details;
- email address;
- professional life;
- economic and financial information;
- billing information;
- social network profile information and posts;
- information on participation in boards of directors and general meetings;
- information necessary for our dealings that you have voluntarily shared with us.
In addition, when you browse on our website www.total-eren.com, information about your connection is collected such as:
- connection identifier;
- IP address;
- unique device identifier;
- date and time of connection.
This Data is collected when you connect to the site and is only processed by the site host.
4. USE OF YOUR DATA
Total Eren will only use your Data if you have given your consent or if such use is based on one of the legal grounds provided for in the GDPR:
- the execution of a contract or of an undertaking under which we and you are bound;
- compliance with a legal, regulatory or fiscal obligation;
- the protection of the legitimate interests pursued by Total Eren.
Total Eren collects and processes information about you for various purposes, including:
- managing the job applications received;
- managing documentation for VIE assignments;
- contacting you and/or answering your requests;
- discussing with you concerning our projects;
- managing our relationships with suppliers, service providers, partners, and consultants;
- managing and protecting our website and social networks;
- managing the legal life of the company;
- protecting our rights in the event of a claim, restructuring, or other operations of merger or acquisition.
None of your data is passed on to third parties, nor is it used for any purpose other than those described above.
5. DATA RECIPIENTS
In order to achieve the above purposes, Total Eren may share your Data only with:
- our subsidiaries concerned by a recruitment or a VIE assignment;
- our internal services to respond to your contact requests;
- service providers and subcontractors performing services on our behalf;
- partners, especially commercial and banking partners;
- Business France in the context of a VIE assignment;
- public authorities or bodies on request and within the limits of what is permitted by the regulations;
- certain regulated professions such as lawyers, notaries, and auditors.
Our service providers and partners are subject to confidentiality obligations.
6. TRANSFERS OUTSIDE THE EU
Total Eren hosts your Data within the European Union. However, some projects or procedures may require us to make international transfers.
In the event that your personal data is transferred to, hosted in or accessed from a country outside the European Union where the Data protection legislation is not equivalent to that of the European Union for a particular operation, such transfers will be subject to appropriate security and control measures in accordance with the rules set out in the GDPR.
Transfers with our subsidiaries are guaranteed by the execution of Standard Contractual Clauses as published by the European Commission in June 2021.
7. PERIOD OF RETENTION
Total Eren keeps the Data only for as long as necessary for:
- the purposes set out in the Policy;
- compliance with regulatory obligations and preservation of evidence in contractual matters until the rights of the parties or third parties concerned are extinguished.
Consequently, unless there are special time limits, the Data may be kept for the maximum period of limitation.
In order to comply with a legal obligation, Total Eren may retain your Data for a longer but specified period.
All Data collected via our website www.total-eren.com is stored in the site’s computer systems under reasonable security conditions for a period of one (1) year.
|Purposes||Period of retention|
|Management of job applications||Two years after the last contact with the candidate or immediate destruction at the candidate’s request|
|Management of VIE assignments||Five years after the end of the VIE contract|
|Management of contacts with you, or your requests||The time it takes to respond to and process your requests|
|Discussions with you concerning our projects||The duration specified in the confidentiality agreement|
|Management of our relationships with suppliers, service providers, partners, consultants and organisations||The duration of the contract extended by the duration of the applicable limitation period of 5 years|
|Management and protection of our website||One year maximum|
|Management of the company’s legal life||The lifetime of the company|
|Protection of our rights in the event of a claim, restructuring, or other operations of merger or acquisition||The duration of the procedure|
8. DATA SECURITY
Total Eren has taken the necessary physical, technical and organisational measures to ensure the security, integrity, availability and confidentiality of the Data, in particular to protect the Data against destruction, loss, theft, accidental destruction, alteration or unauthorised access.
As such, your Data is only accessible to authorised Total Eren personnel. Access rights are granted in accordance with the employee’s function and are updated in the event of a promotion or change of function.
9. HOSTING OF OUR WEBSITE
The website www.total-eren.com is hosted by the company Twinbi, whose head office is located at 10 rue de Penthièvre – 75008 Paris – France.
The host may be contacted by email at the postal address provided above.
In order to prevent external attacks, the host stores the connection logs for a period of one year in a text file that can only be accessed by the server’s administrator. This contains the public IP address of all visitors.
The Data collected and processed by the site is exclusively hosted and processed in France.
- facilitate your navigation on our site and improve your user experience;
- provide social media and networking features;
- measure the audiences of certain services.
What is a cookie?
A cookie is a small file stored on your computer or mobile device when you visit a website. It records information about a device’s navigation on a site.
A cookie file does not identify the user, but allows its issuer to identify the device in which it is stored, during its validity period.
Only the issuer of a cookie is likely to read or modify the information contained therein.
Processing of cookies
The period of validity of your consent to the use of these cookies will not exceed thirteen months, pursuant to Deliberation No. 2013-378 adopted by the CNIL on 5 December 2013, and may be extended by a new manifestation of consent.
The cookies we set on our site are as follows:
|_ga||total-eren.com||Stores a unique identifier used to generate statistical data on how the visitor uses the site.||1 year||HTTP Cookie|
|_gat||total-eren.com||Stores a unique identifier used to generate statistical data on how the visitor uses the site.||1 day||HTTP Cookie|
|_gid||total-eren.com||Stores a unique identifier used to generate statistical data on how the visitor uses the site.||1 day||HTTP Cookie|
|Collect||google-analytics.com||Used to send data about the visitor’s device and behaviour to Google Analytics. Follows the user across devices and marketing channels.||Session||Pixel Tracker|
Third-party cookies embedded in our site
We may include computer applications on our site from third parties such as LinkedIn and YouTube, which allow you to view or share content from our site.
We do not control the processes used by these third parties to collect information about your browsing on our site in association with the Data they hold. We invite you to consult the privacy policies of these third parties in order to learn about the purposes of use, including advertising, of the browsing information they may collect through these applications. These protection policies should allow you to exercise your choices with these third parties, in particular by configuring your accounts for the use of each of their sites.
Use of Google Analytics
The website uses Google Analytics, owned by Google LLC.
We inform you that the information obtained from cookies about your use of the website may be transmitted to a Google LLC server in the USA and stored there.
Total Eren uses Google Analytics for audience measurement and traffic analysis purposes to provide a better user experience.
11. YOUR RIGHTS AND HOW TO EXERCISE THEM
In accordance with the GDPR, persons whose Data is collected have the following rights:
- Right to information
You have the right to receive clear, transparent, understandable and easily accessible information about how we use your Data and about your rights. It is in this sense that we are providing you with this Policy.
- Right to access your Data
You have the right to access and obtain a copy of the Data we hold about you (provided that the request is not manifestly unfounded or excessive, in particular because of its repetitive nature).
- Right to rectify your Data
You have the right to request for your Data to be rectified if it is inaccurate or out of date, and/or completed if it is incomplete (provided that the request is not manifestly unfounded or excessive, in particular because of its repetitive nature).
- Right to erase your Data
In some cases, you have the right to have your Data erased or deleted. This is not an absolute right as we may be required to retain your Data for legal or legitimate reasons.
- Right to limit the processing of your Data
This means that you have the right to request that the processing of your Data be blocked for a certain period of time. We may then retain this Data, but we may not use or process it.
This right applies in certain specific circumstances, for example if you dispute the accuracy of the Data. Processing is then limited for a period of time allowing Total Eren to verify the accuracy of the Data.
- Right to object to processing, if there is a legitimate reason
When the processing of your Data is based on Total Eren’s legitimate interest, you may at any time object to the processing of your Data on grounds relating to your particular situation, unless Total Eren has compelling legitimate grounds which override your interests, rights and freedoms, or when such Data is necessary for the establishment, exercise or defence of legal claims.
- Right to Data portability
You have the right to receive the Data about you that you have provided to us and that we hold about you, in a structured, commonly used and machine-readable format.
This applies only to Data that you have provided directly or indirectly, and only when the processing is based on your consent or the performance of a contract and is carried out using automated processes.
- Right regarding the fate of the Data
You have the right to give us specific instructions about what to do with your Data after your death.
For any information or to exercise these rights
You can contact us by email at email@example.com or by post at the following address:
Responsable des Données Personnelles
37 rue La Pérouse
All requests to exercise rights must be accompanied by a signed identity document.
Total Eren is obliged to respond within a maximum period of one month from the date of receipt of the request. Due to the complexity and number of requests, this time period may be extended by two months and in that case, we will inform you of the extension within one month.
Due to legal or regulatory obligations, Total Eren may not be able to respond favourably to your request. If this is the case, you will be duly notified of the reasons.
If you believe that Total Eren is processing your Data in a manner contrary to the Regulations, you may file a complaint with the French Data Protection Authority (CNIL). This is the supervisory authority responsible for matters relating to the processing of personal data. The CNIL can be contacted at 3, Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, by telephone at +33 (0)1 53 73 22 22, and on its website www.cnil.fr.
12. UPDATING OF THE POLICY
This Policy may be reviewed and updated periodically to reflect changes in our business, or in accordance with legislative or regulatory developments.
We invite you to refer to it regularly on our website.
Total Eren thanks you for reading this Policy.