Personal data protection policy

The purpose of this personal data policy is to inform you about how Data Acteur, a limited liability  company (hereinafter « Data Acteur ») processes your personal data. This policy is essential for Data Acteur given its activities on data and particularly on personal data.

It complies with the provisions of the General Regulation on the Protection of Personal Data, EU Regulation 2016/679 of 27 April 2016 (hereinafter the « GDPR ») and Law No. 78-17 of 6 January 1978, known as the Data Protection Act (hereinafter the « LIL »), and any law or regulation that may supplement or replace it (hereinafter together the « Applicable Regulations »).

1 ⇒ Definition

The following definitions are taken from Article 4 of the GDPR.

4.1 « personal data »:
any information relating to an identified or identifiable natural person (hereinafter referred to as « data subject »); an « identifiable natural person » is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, a location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;

4.2 « treatment »:
any operation or set of operations which may or may not be performed upon personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limitation, deletion or destruction;

4.7 « person in charge of the treatment »:
the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria for designation may be provided for by Union law or the law of a Member State;

4.8 « subcontractor »:
the natural or legal person, public authority, department or other body which processes personal data on behalf of the controller;

4.9 « recipient »:
the natural or legal person, the public authority, the service or any other body that receives communication of personal data, whether or not it is a third party. However, public authorities that may receive personal data in the context of a particular inquiry in accordance with Union law or the law of a Member State are not considered as recipients; the processing of such data by the public authorities in question complies with the applicable data protection rules according to the purposes of the processing;

2 ⇒ Category of personal data processed
We take care to collect and process Personal Data that is relevant, adequate, not excessive and strictly necessary to achieve the purposes that have been previously determined.

2.1 « Data generated by the Data Acteur activity »:
We collect and process personal data in accordance with the principle of minimization:

Concerned peopleCategory of data
Clients, but also their employees, representatives, contractors and/or managers.identity data,
economic and financial data,
other personal data strictly necessary for the execution of our missions
Prospects (hereinafter the "Prospects") communicated by the latter during various exchanges.identity data
various external contacts within the framework of our missionsidentity data
other data strictly necessary for the execution of our missions.

2.2 « Data generated by the traffic of Data Acteur website »:
Within the framework of the use of the Data Acteur website accessible at https://www.dataacteur.com (hereinafter the « Website »), Data Acteur collects and processes certain Personal Data concerning you as a user of the Website (hereinafter « User(s) »).

Users’ Personal Data is collected when:

° You browse the Website: in this case we collect your technical and browsing information (please see our cookie policy);

° You contact us to ask questions about our news or any other subject related to our activity: in this case we collect your identity and contact data and any information you voluntarily provide us which would be relevant to the processing of your request.

When your Personal Information is transmitted to us via a form, the mandatory nature of the information you must provide is indicated at the time of collection. Any failure to reply or any reply deemed abnormal by Data Acteur may result in the refusal of Data Acteur to take your request into account.

3 ⇒ Purpose of the processing of your personal data and legal basis
Data Acteur undertakes to collect and process your Personal Data in a fair and lawful manner. The Processing implemented by Data acteur meets explicit, legitimate and determined purposes.

Your Personal Data may be processed for the following purposes:

3.1 Purpose and legal basis for the data collected and processed within the framework of the activity of Data Acteur:

CategoryAimsLegal basis
Client (mission)









In the absence of opposition
Customers can receive informational content, invitation to professional events organized by Data Acteur,
Personal Data of Clients processed for the purpose of managing the said Clients and the contractual relationship for the purpose of :
i).contact and communication,
ii). execution of the entrusted missions
iii). management of contract and invoice,
iv). management of accounting,
v). follow-up of the contractual relationship.

Personal Data collected for the purpose of analysis of marketing actions and commercial prospecting
Processing of your Personal Data for the purpose of fulfilling the contract and complying with our legal obligations (accounting and tax),
Art 6.1.b) contract
Art 6.1.c) legal obligations




Legitimate interest of Data Acteur art 6.1. f)
Prospect



In the absence of opposition, Prospects may receive informational content on various professional topics, invitations to professional events organized by Data Acteur
Personal Data processed for the purpose of contact and communication with said Prospects.

Personal Data collected for marketing analysis purposes,
Legitimate interest of Data Acteur art 6.1. f)


Legitimate interest of Data Acteur art 6.1. f)
External contact



In the absence of opposition, external contacts may receive informational content on various business topics, invitations to business events organized by Data Acteur
Personal data processed for the purpose of managing our activities and communicating with these persons

Personal Data collected for marketing analysis purposes,
Legitimate interest of Data Acteur art 6.1. f)


Legitimate interest of Data Acteur art 6.1. f)

3.2 Purpose and legal basis of the data of the visitors of the Data Acteur website:

CategoryAimsLegal basis
Website usersUsers' Personal Data are processed for
i). for the purpose of communication and management of submitted requests / inquiries,
ii). analysis of the navigation on the Website;
iii). commercial prospecting (sending of informational content on various professional subjects, invitations to training sessions or events organized by Data Acteur) when a User communicates his or her email address for this purpose on the Website and does not subsequently express opposition.

Legitimate interest of Data Acteur art 6.1. f)

4 ⇒ Retention period of personal data

Data Acteur keeps your Personal Data for the following periods:

Category of data Duration of storage
Costumers’ data
Data from external contacts collected for the realization of a client's mission
Data required for accounting purposes
Prospects Data
Data collected for commercial prospecting purposes
Cookies or other tracers not essential to the operation of the Website are deposited on your terminal
Data are collected in the context of questions relating to the Website
Duration of the contractual relationship and during the applicable statute of limitations (5 years in general).
same duration as the Customer data or for the duration necessary to achieve the intended purpose
10 years in total to comply with applicable accounting and tax requirements.
3 years following the last contact with the prospect
3 years following the last contact with the person concerned
Duration indicated in the cookie policy
Time needed to process the requests (1 month, if the request is complex the time can be extended to 2 months).

5 ⇒ Recipients
The Personal Data collected and processed by Data Acteur are accessible by the manager of Data Acteur.
This Data may be communicated to third parties, acting as Subcontractors, bound by a subcontracting agreement, to perform hosting, Website management and computer maintenance services.

In addition, your Personal Data may be shared with third parties to protect the rights and property of Data actor and to prevent fraud, security or technical problems.

6 ⇒ No transfer outside the European Union
The Personal Data collected by Data Acteur are hosted within the European Union and are not transferred outside the European Union.

7 ⇒ Our rights

In accordance with the GDPR, you have the following rights to your Personal Data:
Right of access:

You have the right to obtain confirmation as to whether or not your Personal Data is being processed and, if so, to obtain access to and a copy of such data (Article 15);

Right of rectification:
You have the right to obtain the rectification of your Personal Data that are inaccurate. You also have the right to have incomplete Personal Data completed (article 16);

Right to oblivion:
You may request right to oblivion in specific cases (article 17)

Right to restrict processing:
You have the right to have the processing of your data restricted in defined circumstances (article 18),

Right to the portability of your personal data:
You have the right to the portability of the personal data, which you have transmitted to us, in a structured, commonly used and machine-readable format and, if necessary, to transmit them to third parties (article 20);

Right to object:
You have the right to object to the processing of your personal data (Article 21). We will no longer collect your personal data upon receipt of your request.

Right to manage post mortem data:
You also have the right to give Data Acteur instructions regarding the use of your Personal Data after your death.

Exercising your rights:
To exercise your rights you can send a request:

° by email to: rgpd@dataacteur.com
° by mail to: RGPD, Data Acteur, 77 impasse Viro Souleu, 06460 Saint-Vallier-de Thiey, France

Claims to the Cnil

In case of difficulty related to the management of Personal Data, you can address a claim to the CNIL (3 Place de Fontenoy, 75007 Paris).

However, we invite you to contact us before contacting the CNIL.

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