Privacy policy

EN | FR

PRIVACY POLICY FOR CUSTOMERS AND PROSPECTS OF ESTIN & CO

Société de Participations Estin & Co (the “Company”) is committed to protecting the personal data of its customers, prospects and visitors on its website at https://estin.com (the “Site”). For this reason, it provides the required level of protection for this data, particularly under the French law “Loi Informatique et Libertés” of 6 January 1978 (amended by article n° 2018-493 of 20 June 2018) and the European Data Protection Regulation of 27 April 2016 (“GDPR”). The Company wishes to inform its customers and prospects of how it protects their personal data, including for sending newsletters or business information or using its Site.

Identity of the Data Processing Manager

The entity responsible for processing collected personal data is:

Société de Participations Estin & Co SAS

RCS Paris No. 534 927 058

58 rue de Monceau, 75008 Paris, France

Collected personal data and purposes

Customer data: name*, first name*, e-mail*, company and position in the company.

Data marked with an asterisk is compulsory for the creation of a customer or prospect record in the Company’s CRM.

This data is collected for the following specific purposes:

• follow-up on current contracts
• management of customer relationship
• business development

The legal basis for the collection and processing of personal data by the Company is based, depending on the processing, on the consent of the customer, prospect or user, the execution of a contract between the Company and the client, or the legitimate interest of the Company with regard in particular to business development.

Recipients of personal data

The Company and its subcontractors:

Collected and processed personal data is intended for the internal services of the Company: marketing; accounting, secretarial work.

The Company has to transfer certain personal data of its customers and prospects to subcontractors, solely with the purpose to enable them to carry out the missions entrusted to them and according to the instructions of the Company.

These subcontractors have an obligation to ensure the security and confidentiality of this personal data and not to use it for any purpose other than the fulfillment of their mission.

These subcontractors are:

• Salesforce: Salesforce.com France S.A.S, RCS Paris 483 993 226, 3 Avenue Octave Gréard, 75007 Paris - France
• The Rocket Science Group LLC d/b/a Mailchimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA

Data transfers outside the European Economic Area

Personal data may be accessed by the Company's authorised employees located in London, Zurich, New York and Shanghai, and may be processed by service providers outside the European Economic Area, including Mailchimp in the United States.

Where personal data is transferred outside the European Economic Area, the Company relies on an adequacy decision adopted by the European Commission where that decision covers the destination and the recipient. Otherwise, transfers must be protected by appropriate safeguards, such as the European Commission's standard contractual clauses, together with any supplementary measures required in light of the circumstances of the transfer.

For transfers to Mailchimp in the United States, Mailchimp's Data Processing Addendum provides for reliance on the EU–US Data Privacy Framework where applicable, and on standard contractual clauses where required, including where the Framework does not cover the transfer or can no longer be relied upon. Further information is available in Mailchimp's Data Processing Addendum.

Information about the safeguards applicable to a transfer, and a copy of the relevant safeguards where applicable, may be requested by contacting privacy@estin.com.

CUSTOMER AND PROSPECT CONTACT

Electronic communication

The Company's customers and prospects are likely to receive communications from the Company or its subcontractors by electronic means (email and text messages).

The Company is likely to measure the open rate, click-through rates and unsubscribe rates of its mailings in order to adapt them as best as possible.

If the customer or prospect does not wish to receive information and business development messages from the Company, he or she can oppose being contacting at any time by indicating it via the unsubscribe link provided for this purpose in all electronic communications of the Company.

Retention

The personal data of the prospect is kept by the Company for a period of three years from the latest contact.

Personal data necessary to comply with a legal or contractual obligation of the Company is kept and/or archived in accordance with the provisions in force (notably but not exclusively those provided for by the Code of Commerce, the Civil Code or the Consumer Code).

Exercising rights on personal data

In accordance with the amended Computer and Freedoms Act and current European regulations, and under the conditions specified by the provisions of the GPDR, the User whose personal data is collected and processed by the Company benefits from the the following rights on his or her personal data:

• a right of access which allows him or her to obtain from the Company the communication of personal data relating to him or her,
• a right to rectification which allows him or her, if necessary, to rectify, complete, update personal data which is inaccurate, incomplete, ambiguous, out of date,
• a right to erasure ("right to be forgotten") which allows him or
• her to obtain from the Company, under certain circumstances and conditions, the erasure or deletion of his personal data,
• a right to restrict processing, which allows him or her, under certain conditions, to prohibit the Company from using and processing his or her data for a certain time so that verification can take place (verify the accuracy of personal data, check whether the legitimate reasons given by the person prevail over those of the data controller in the event of a request for opposition, etc.).
• a right to data portability allowing the Company, under the conditions of Article 20 of the GDPR, to retrieve the data it has provided in an easily reusable form, and, if necessary, to then transfer them to a third party.
• a right to object in certain circumstances and conditions, except in matters of business development and commercial segmentation by the Company (this right can then be exercised without having to justify a legitimate reason), for personal data concerning him or her to be processed,
• the right to lodge a complaint with a supervisory authority: any complaint on the applicable data protection legislation can be brought before the CNIL: www.cnil.fr.

In accordance with current European regulations, the User can exercise his or her rights by accompanying his or her request with a two-sided copy of his identity card with his signature:

By mail to:

Société de Participations Estin & Co

58 rue de Monceau, 75008 Paris, France

By email to: privacy@estin.com

The person concerned can also, at any time, unsubscribe to newsletters or from the Company's information or business development actions by clicking on the unsubscribe link available in each newsletter.

Website hosting, technical data and external services

The Site is operated by Société de Participations Estin & Co, 58 rue de Monceau, 75008 Paris, France, and is hosted on OVHcloud Managed WordPress.

Hosting and security systems process technical connection data, which may include IP addresses, dates and times of access, requested pages, browser information and error records. Access attempts and administrative activity may also be logged. This processing serves the Company's legitimate interests in operating, maintaining and securing the Site and preventing misuse. Access to these records is restricted to authorised personnel and technical service providers for those purposes.

WordPress uses cookies necessary for authentication and administration. Security and privacy-preference features may also use strictly necessary cookies or similar technologies. These serve technical functions rather than advertising purposes. Browser settings can restrict cookies, but doing so may affect functions that require them.

The Site's public search and publication filters run in the visitor's browser. The current public pages do not include advertising or audience-measurement tracking scripts. This description concerns website browsing; email-campaign measurement is described separately above.

Contact and recruitment links open the visitor's email application. The current contact and application pages do not collect messages or CVs through an online submission form.

The Site's security tools include Cloudflare Turnstile. Where a Turnstile verification is displayed, Cloudflare processes technical browser and connection information to distinguish legitimate users from automated traffic. See Cloudflare's privacy policy. Links to external websites and map services take visitors to services governed by their own privacy policies.