Personal data politic

1. PURPOSE

This Policy informs you about how your personal data is collected and used by the agency HAVAS PARIS, a limited company with a board of directors with a capital of 160,528 euros, headquartered at 29/30 quai de Dion Bouton, 92800 Puteaux (hereinafter the “Agency”) as part of the operation of the NEWDEAL website accessible at the URL www.newdealhavas.com as data controller.

This policy is accessible from our homepage and at the bottom of each page of the website.

For more information on our group policy regarding the protection of personal data, we invite you to consult our Group Policy.

We also invite you to consult our general terms of use accessible on the Site.

2. DEFINITIONS

The terms below, whether in the plural or singular, have the following meanings:

– “personal data”: any information relating to an identified or identifiable natural person, directly or indirectly, within the meaning of the regulations;
– “data subject”: natural person whose personal data is processed by Havas Paris;
– “regulation”: regulations in force in France, applicable to the processing of personal data, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (the “GDPR”) and law n°78-17 of January 6, 1978 “Informatique et Libertés” as amended;
– “data controller”: natural or legal person who determines the means and purposes of the processing of personal data within the meaning of the Regulation;
– “processor”: natural or legal person who processes data on behalf of the data controller as part of a service or provision;
– “Site”: NEWDEAL website accessible at the URL newdealhavas.com (the “Site”);
– “processing”: any operation or set of operations performed, whether or not using automated processes and applied to 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, restriction, erasure or destruction.

3. HOW DO WE PROCESS YOUR PERSONAL DATA?

During your navigation and interactions on the Site, we may collect and process data about you, for the management of activities carried out on its own behalf, as data controller.

Our agency respects the right of each individual, client, supplier, partner, candidate, prospect, or internet user to have their personal data protected. We observe the principles defined by the regulations:

– Process your personal data fairly, lawfully, and transparently.
– Collect your personal data for explicit, determined, and legitimate purposes, and not process it subsequently in a manner incompatible with these purposes.
– Ensure that the personal data collected are relevant, proportionate, and not excessive in relation to the purposes for which they are collected and processed. Personal data may be anonymized where possible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
– Maintain your personal data accurately, updating it if necessary. We will take reasonable steps to rectify or delete inaccurate or incomplete data.
– Personal data will be kept for the time necessary for the purposes for which it was collected and processed.
– The processing of personal data will be carried out in compliance with the rights of individuals.
– Technical, physical, and organizational measures are taken to secure your data and prevent unauthorized access, unlawful processing, and loss, destruction, or unauthorized or accidental alteration of personal data.
– Process your personal data only in compliance with the legal bases for processing, including obtaining consent when required.

4. WHAT TYPES OF PERSONAL DATA ARE COLLECTED?

As data controller, we collect and process your personal data after informing you appropriately.

The personal data we process include:

– your identification data (your first name, last name, email address);
– your login data: your IP address;
– your browsing data and expressed preferences: traffic and navigation history on the Site, data from cookies, and trackers.

We do not collect so-called “sensitive” personal data or special categories of personal data.

In general, and except for exceptions, the use of our websites is reserved for adults.

5. WHAT IS THE PURPOSE, LEGAL BASIS, AND RETENTION PERIOD FOR THE COLLECTION OF YOUR DATA?

In accordance with the regulations, the personal data we collect is used for the fulfillment of purposes for which it was collected and for the duration indicated in the table below.

The processing we implement has the following purposes, legal bases, and durations:

In the event of litigation/procedure, particularly judicial, initiated before the end of the above-mentioned periods and requiring the retention of personal data, especially for the establishment, exercise, or defense of rights, this data will be kept for the duration of said procedure and until the definitive extinction of the remedies.

11. YOUR RIGHTS REGARDING PERSONAL DATA

HAVAS PARIS is particularly concerned with respecting the rights granted to you in the context of the data processing it carries out, to ensure fair and transparent processing considering the particular circumstances and context in which your personal data is processed.

**Your Right of Access**

You have the right to obtain confirmation as to whether or not your personal data is being processed, and if so, you have the right to request a copy of your data and information concerning:

– the purposes of the processing;
– the categories of personal data concerned;
– the recipients or categories of recipients, including, where applicable, any international organizations to which the personal data has been or will be disclosed, in particular recipients established in third countries;
– where possible, the envisaged duration for which the personal data will be stored, or, if not possible, the criteria used to determine that duration;
– the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
– the right to lodge a complaint with a supervisory authority;
– information about the source of the data when it is not collected directly from you;
– the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

**Your Right to Rectification of Your Data**

You can request that your personal data be corrected, completed if it is inaccurate, incomplete, ambiguous, and/or outdated.

**Your Right to Erasure of Your Data**

You can request the erasure of your personal data in cases provided for by the regulations.

Please note that the right to erasure of data is not a general right and can only be exercised if one of the grounds provided for in the applicable regulations is present.

**Your Right to Limit Data Processing**

You can request the limitation of the processing of your personal data in cases provided for by the regulations.

**Your Right to Object to Data Processing**

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where the legal basis for the processing is the legitimate interests pursued by the data controller.

In case of exercise of such right of objection, we will cease processing your personal data for the processing concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

**Your Right to Data Portability**

You have the right to data portability of your personal data. Please note that this is not a general right. Indeed, not all data from all processing activities are portable, and this right only applies to automated processing, excluding manual or paper-based processing.

This right is limited to processing activities based on your consent or the performance of pre-contractual measures or a contract.

**Your Right to Withdraw Your Consent**

When the processing of data we carry out is based on your consent, you can withdraw it at any time. We will then stop processing your personal data without prejudice to the previous operations for which you had consented.

**Your Right to Lodge a Complaint**

You have the right to lodge a complaint with the data protection authority of your country of residence without prejudice to any other administrative or judicial remedy.

**Your Right to Define Post-Mortem Directives**

In accordance with the French Data Protection Act of January 6, 1978 as amended, you have the possibility to define directives concerning the storage, erasure, and communication of your personal data after your death according to the following terms.

**How to Exercise Your Rights**

You can exercise your rights with the Group DPO, at the email address: dpo@havas.com or by post to: Data Protection Officer, Havas Group, 29/30 Quai de Dion Bouton, 92800 Puteaux, France.

We will respond to you as soon as possible and in any case within a maximum period of one month from the receipt of the request. We may, if necessary, extend this period by two months, given the complexity and number of requests, and we will inform you specifically.

If you have any complaints about your rights, you can contact the supervisory authority (CNIL).

12. EVOLUTION OF THE SITE’S PERSONAL DATA PROTECTION POLICY

HAVAS PARIS reserves the right to modify this policy if necessary, for example, to comply with changes in law, regulations, practices, and procedures of the agency, or requirements imposed by the authorities responsible for the protection of personal data. The new policy will be published on the Site.

We invite you to consult it regularly.

If you have any questions or comments about this policy, please contact the Group DPO, whose contact details are set out in Article 11 above.

Date: January 2024