Pursuant to Articles 13 and 14 of the General Data Protection Regulation, we provide you with some information necessary to illustrate how we will collect, use and process the personal data (hereinafter referred to as “Personal data” or “data”) that you provide to us directly or that we will obtain from your company during our business relationship.
1) Data Controller
The Data Controller of the Personal data is Toray Films Europe S.A.S with registered office located Place d’Arménie, 01700-Saint-Maurice-de-Beynost, France which is responsible for the legitimate and correct processing of Your Data.
2) Personal Information collected
When you access our website on your device, our server automatically collects certain browser- or device-generated information (so called server log files): date and time of access, duration of visit, your operating system, volume of data sent, type of access, IP address, domain name, browser information including version and language setting.
Furthermore, we collect relevant data from people who contact us via digital, telephone or physical channels to ensure a better experience. The data collected relates to the discussion partner, the company and the purchasing information when you contact us, visit our website, interact with us or place an order.
In the case of digital communications, this personal data is obtained through the traffic data of our website, survey contents, contact forms and our newsletter.
We will collect any information you provide us when you use our contact forms. The transmission of your Personal data via our contact forms is not a regulatory or contractual requirement. When you contact us, we keep this correspondence in order to keep track of the origin of your request.
We collect all the Personal Data (such as identifying data, date of birth, contact data – e.g. e-mail, address, telephone number, company you work for, business role, tax code, VAT number) that you will provide us or we will acquire during the negotiation, conclusion and/or execution of the commercial relationship that we will establish with you or with the company you work for.
3) Purpose of the Data processing
(i) We use your personal data to ensure a better quality of service. The information collected is processed to feed and maintain our customer relationship management systems, to enable the best execution of your orders, to handle any claim, to invoice and obtain payment of amounts due.
(ii) We use your personal data to provide you with a better customer experience. The information collected allows us to communicate with you more efficiently, providing reliable and relevant information by sending e-mail and newsletters tailored to your needs, segmenting data such as your industry.
(iii) We may use your personal data to comply with our legal and regulatory obligations, such as disclosure to the appropriate authorities or regulatory bodies.
4) Legal basis of the Data processing:
Our use of your personal information is authorized by the RGPD and by the amended Act n° 78-17 of 6 January 1978 relating to data processing, files and personal freedom and privacy:
- The legal basis for the processing of Your Data for the purpose under i) is represented by the need to give execution to the commercial relationship between us, or between TFE and the company you work for, pursuant to Article 6.1 letter b) of the GDPR.
- The legal basis for the processing of your Data for the purpose under ii) is represented by our legitimate interest in carrying out marketing activities, pursuant to Article 6.1 letter f) of the GDPR, which we believe is not overridden by any of your rights, interests or fundamental freedoms.
- The legal basis for the processing of your Data for the purpose under iii) is represented by the need to comply with a legal obligation to which the Data controller is subject, pursuant to Article 6.1 letter c) of the GDPR;
No sensitive personal data as defined in paragraph 51 of the GDPR is collected. Pursuant to paragraph 71 of the GDPR, we do not make any decisions based solely on automated processing, and do not use a “profiling” technique based on personal data for the purpose of assessing personal aspects to a natural person producing legal effects affecting you or affecting you in a significant way.
5) Data storage period
The retention period of your personal data depends on the purpose of the processing of these data and the tool used for their processing. It is not possible to describe here the different periods of conservation of data in a reasonably understandable way.
The criteria used to determine the applicable data retention period are as follows: we will retain the personal data defined in this policy as long as (1) necessary to achieve the intended purposes, (2) necessary for the purpose of our business relationship with you, (3) you consent to and/or (4) required by applicable data retention laws and regulations.
6) Communication to third Parties
In the processing of data for the purposes mentioned in paragraph 3) above, your data may be disclosed or made available to third parties such as:
- Suppliers, service providers: we commit with or appoint other companies to perform certain functions on our behalf. For example, this may be the case for the hosting and/or maintenance of the content of the website and our CRM tools.
- Government or law enforcement authorities: if we determine, in our sole discretion, that we are legally bound to do so.
Your personal data is confidential: third-party recipients to whom we transmit your data have access to them only to the extent necessary to perform their functions, and are not authorized to use your personal data for any other purpose. These recipients are subject to contractual confidentiality obligations.
7) Where are your personal information stored and processed?
As explained in paragraph 4 above, we communicate your personal data to suppliers, providers: when we use a supplier or a service provider, your data remains under our control and means of verification are put in place to guarantee appropriate protection of your personal data.
We strive to take all necessary steps to ensure that your personal data is securely processed and complies with this Policy.
Our data are all stored in the European Union.
8) Data subject rights
Pursuant to Articles 13, paragraph 2, letters b), c) and d), 15, 16, 17, 18, 19, 20 and 21 of the GDPR:
a) you have the right to request access to your Personal Data together with information on the processing purpose, category of data processed, whenever possible the storage period and/or the criteria used to determine such a period, the existence of your rights to correct and/or delete personal data, limit and object to the processing.
You have the right to lodge a complaint with a supervisory authority, the French “Commission Nationale de l’Informatique et des Libertés (CNIL)” to know the origin of the Data, the existence of any automated decision-making and its logic.
If you exercise this right you will receive an electronic copy of your data that are being processed unless you provide us with other instructions.
b) You also have the right to obtain:
i. the correction of your Data, if they are incorrect or incomplete;
ii. the erasure of your Data, given one of the conditions set out in Article 17 of the GDPR
However, this right is subject to any rights or obligations that may be assigned to us by law, in terms of data retention. When we determine, in accordance with the law, that your request is acceptable, we will proceed to the deletion of your personal data, as soon as possible;
iii. the restriction of the processing of your Data 1) for the time necessary for TFE to ascertain the accuracy of your data (if you objected), or 2) if the processing is unlawful and you request the restriction of related processing instead of the erasure of your Data, or 3) when TFE no longer needs your Data but they are necessary for you to ascertain, exercise or defend a right in court, or, finally, 4) for the time necessary to assess the possible prevalence of the Data Controller’s legitimate reasons with respect to yours, if you have objected to the processing of Your Data pursuant to point c) below;
iv. Your Data in a structured, commonly used and readable by an automatic device, also in order to send the Data to another data controller if the processing is based on consent or on a contract and is carried out by automated means.
c) You have the right to object to the processing of Your data, if such processing is carried out pursuant to Article 6.1 letter e) (i.e. to fulfil a legal obligation to which the Data Controller is subject) or letter f) (i.e. to pursue a legitimate interest of the Data Controller) of the GDPR, unless there are legitimate reasons for the Data Controller to proceed with the processing, pursuant to Article 21 of the GDPR, the exercise of the above rights is not subject to any form of constraint and is free of charge. We may only ask you to verify your identity before taking further action on your request.
To exercise your rights, you can contact Toray Films Europe by sending a registered letter with acknowledgment of receipt to the address specified in paragraph 1) above or by email to the following address: email@example.com.
9) Date of update
In the interests of transparency, we make sure that this privacy statement is regularly updated.