Privacy policy

Each time an electronic communication for direct marketing purposes is sent, the recipient has the possibility to choose not to receive it in the future by means of an unsubscribe link by following the instructions detailed in the footer of the email sent. In addition, it is possible, at any time, to send an email to the following address dpo@eurosagency.eu in order to request to stop receiving these commercial communications.

The use of data and information as described above is authorised by the regulations applicable to the protection of personal data. In most of the cases, this processing of personal data for direct marketing purposes is based on the user’s consent and/or the Company’s legitimate interest.

In addition, when the data subject has consented directly with the Company’s partners (such as social networking platforms, marketing agencies and affiliate platforms, search engines, etc.), the Company may receive his/her personal data. The Company may then use this information to promote its services under the conditions described above.

It is specified that when the Company acts as a processor on behalf of a client (for example, when the Company sends communications to a client’s contact list on behalf of the client and according to the client’s instructions), all the principles and precautions applicable to direct marketing operations are the responsibility of the client as data controller. The Company only has a duty to alert its client if it considers that the instructions given are unlawful.

2.3. Data collected in the context of public relations consultancy and interest representation

Euros / Agency Group, as a public relations consultancy, collects personal data from public figures, in particular contacts of public and/or political figures (elected representatives, ministers, members of ministerial cabinets, representatives of public authorities, etc.): surname, first name, address, telephone number(s), e-mail address.

This data is collected with a view to compiling press files, managing and monitoring the Company’s relations with its professional contacts. This includes, in particular, carrying out commercial, communication and marketing operations and actions to represent interests by any means, in particular by email.

Euros / Agency Group shall collect such data in a fair and transparent manner. Where necessary, it shall inform data subjects of the characteristics and modalities of the processing of their personal data.

Within the framework of its “core business” activity, Euros / Agency Group may need to process data from open data in strict compliance with the regulations in force.

The use of this information as described above is authorised by the regulations applicable to the protection of personal data. The processing of this personal data is carried out in the context of the Company’s public relations consultancy and interest representation activities. This processing is therefore based on the pursuit of the legitimate interests of the Company to ensure the management and monitoring of its relations with its contacts in the context of its activity when acting as data controller.

Euros / Agency Group may also process sensitive data such as political opinions or philosophical beliefs, but only in the following cases:

• where such data have been manifestly made public by the data subject;
• or if the person concerned has given its express consent (active, explicit and preferably written, which must be free, specific and informed).

It is specified that when acting as a processor, Euros / Agency Group carries out the processing on behalf of its clients and according to the instructions provided by the latter (for example when collecting data in order to draft documents on behalf of its clients). In this case, the Company does not determine the purpose or means of the processing – i.e. the purpose and manner of carrying it out – which remain the responsibility of the clients.

2.4. Data collected in the context of the services provided

As part of the services provided by Euros / Agency Group, the following information relating to its clients is collected and processed: surname, first name, address, telephone number(s), e-mail address.

In addition, it processes and collects data for the execution of pre-contractual measures or the contract with the Company, when it implements the following actions:

• direct marketing, production, management and follow-up of its clients’ requests and files,
• drafting documents on behalf of its clients,

as well as in the context of compliance with legal and regulatory obligations when it implements processing for the purpose of:

• billing,
• accounting,

All elements necessary for these purposes are collected and processed.

This information is used to fulfill the purposes related to the services requested.

Such processing is authorised by the regulations applicable to the protection of personal data, and in all cases is based on the legal basis of the contract between the data subjects and the Company or on the legal basis of legitimate interest. Unless otherwise provided, the above information is necessary for the Company to fulfill its contractual obligations.

The data is kept for as long as the data subject has a contractual relationship with the Company.

In the event of termination of the contract between the data subject and the Company, as well as at the end of the requested service or provision, and if there is no other reason to continue processing, the information will be kept for the periods necessary to comply with the regulations and prescription rules in force, in particular contractual, accounting and tax regulations, or, where applicable, with a view to dealing with any claim or request relating to the services provided.

Clients’ personal data is kept for the duration of the contractual relationship plus three (3) years for the purposes of promotion and direct marketing, without prejudice to the retention obligations or limitation periods.

2.5. Data collected from the use of the Website

2.5.1 Cookies and other trackers

A cookie is a small file stored by a server for a limited period of time on a user’s terminal (computer, tablet, telephone, smartphone, etc.) and associated with a web domain (i.e. in most cases with all the pages of a single website). This file is automatically sent back during subsequent contacts with the same domain.
The Company’s website uses cookie technology to improve navigation and user experience. During the consultation of the Site, these cookies may be recorded on the browsers of the medium used, regardless of the terminal used.

In particular, they are used for identification purposes to analyse the number of visitors and the use of the Site’s elements. Cookies also enable the Company to recognise users, to retain certain information relating to their preferences and user path, and to understand how they use the services available on the Site.

The cookie has a validity period which varies according to the type of cookie and allows the visitor to be recognised the next time he or she uses the Site. In any event, this period shall not exceed thirteen (13) months.

Cookies are set by Euros / Agency Group.

At any time, visitors can choose to accept or decline the use of cookies and change their preferences.

Users can change their cookie preferences or delete them by adjusting their browser settings:

• Safari
• Chrome
• Firefox
• Internet Explorer
• iOS

Users can also manage their cookie preferences through the “cookies” information banner on the homepage of the Site.

As long as the visitor has not given his/her consent to the collection of cookies, no cookie may be deposited on his/her terminal, with the exception of cookies exempt from the collection of consent insofar as they are strictly necessary for the provision of a service expressly requested by the user.

The Company retains the user’s choices for six (6) months.

Users are informed that the setting of cookies may however modify the conditions of access to the services offered by the Company and alter their browsing comfort.

2.5.2 Contact form available on the Site

The following information is collected and processed via the “Contact Us” form available on the Site: surname, first name, e-mail address.

This information is used solely for the purpose of establishing contact with the person who filled in the online questionnaire and sending him/her the newsletter so that he/she can follow Euros / Agency Group news and be informed of events organised by the Company.

This contact will be made by e-mail. The data collected when the completed online questionnaire is sent is kept for a maximum of three (3) years.

The recipient has the possibility to choose not to receive the Euros / Agency Group newsletter in the future thanks to an unsubscribe link in the footer of each newsletter sent. In addition, it is possible, at any time, to send an email to the following address dpo@eurosagency.eu in order to request to stop the sending of this newsletter.

The use of this information as described above is permitted by the applicable regulations on the protection of personal data. The processing of such personal data is based on the consent of the data subject.

3. Transmission of data collected by the Company to third parties

The information collected may be transmitted to the Company’s partners.

List of partners and subcontractors with whom the Company collaborates:

The Company has entered into a written contract with each of these service providers containing strict confidentiality and security obligations, at least equivalent to those set out in this Privacy Policy.

Euros / Agency Group, as a representative of interests, also has reporting obligations. The Company may be required to transmit personal data to a number of authorities, including the High Autority for Transparency in Public Life (HATVP), pursuant to legislative and regulatory provisions.

In such a situation, the Company undertakes to communicate to the authorised third party only the information or documents that are strictly necessary for the exercise of its mission, in accordance with the principle of data minimisation.

4. Transfer of data outside the European Union

Personal data collected by Euros / Agency Group may be transferred to non-EU member states .

These transfers may take place to countries recognised by the European Commission as offering an adequate level of data protection (see European Commission adequacy decisions: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).

Failing that, such transfers shall be governed by the conclusion, with the recipients of such data, of contractual clauses in accordance with the recommendations of the European Commission enabling Euros / Agency Group to ensure that appropriate guarantees are taken concerning the protection of such data.

A copy of the reference documents referred to in this paragraph can be obtained from the contact person mentioned in the last article of this Privacy Policy.

5. Data retention

Euros / Agency Group undertakes to keep personal data for no longer than is necessary for the purposes for which the personal data are processed and for the retention periods imposed by the applicable laws in force.

In addition, the user’s personal data may be retained by the Company for evidential purposes or to comply with its legal retention obligations.

6. Rights of the data subject

In accordance with the GDPR, any person concerned by the processing of personal data has the following rights:

• The right to access personal data;
• The right to correct any errors in the files or to update his/her data;
• The right to the limitation of processing;
• The right to object to the processing of his or her data for legitimate reasons;
• The right to have personal data permanently erased (right to be forgotten);
• The right to withdraw consent;
• The right to object to receiving direct marketing material in the future;
• The right to data portability (transfer of data to the data subject or to a third party);
• The right to refuse an automated individual decision-making;
• The right to define directives concerning the fate of his/her personal data after his/her death.

To exercise the rights mentioned above, the user can send an email to the following address dpo@eurosagency.eu or by post to the following address:

Euros / Agency Group
To the attention of Mrs Abigail TEVES
Data Protection Officer
1 place d’Estienne d’Orves
75009 Paris

Euros / Agency Group may ask the user to prove his/her identity before processing his/her request, in compliance with the regulations in force.

ny person has the right to lodge a complaint with the French data protection authority: the Commission Nationale de l’Informatique et des Libertés (CNIL).

7. Protection of personal data

Euros / Agency Group undertakes to implement and maintain, at its own expense, appropriate technical and organisational measures for the processing and security of personal data having regard to the nature of the data processed and the risks involved.

The measures put in place are thus adapted to protect users’ personal data against accidental or unlawful destruction, loss, modification, unauthorised disclosure or access.

Only certain members of the Company’s personnel may have access to users’ personal data, through administrator accounts.

The Company also undertakes to keep, update and maintain complete and accurate records of the processing of personal data in connection with the services provided. These records detail its processing activities.

8. Notification of personal data breaches

In the event of a violation presenting a risk for the rights and freedoms of individuals, the Company will send a notification to the CNIL within a maximum of seventy-two (72) hours.

In the event of a high-risk breach of personal data, the Company will inform the persons concerned without delay and no later than twenty-four (24) hours after becoming aware of such a breach.

In all cases, the Company will document the incident internally in its “Data Breach Register” by identifying the nature of the breach, the categories and approximate number of individuals affected, the likely consequences of the data breach, and the measures taken or envisaged to mitigate the negative consequences of the breach and to prevent a recurrence.

9. Links to other sites

The Site may include links to other sites or other Internet sources.

As Euros / Agency Group has no control over the content and privacy policies of third party websites, Euros / Agency Group disclaims any responsibility for them.

The user is therefore invited to consult the privacy policy of each of the sites he/she visits.

10. Status and modification of the Privacy policy

This Privacy Policy was last updated on 8 April 2022.

This Privacy Policy may be modified by Euros / Agency Group in order to provide users with up-to-date and transparent information on how Euros / Agency Group collects and processes data.

Any changes will be implemented after informing all users via the e-mail addresses provided by them. In this case, the “Last Updated” date mentioned above will be changed.

The new version of the Privacy Policy will be effective as of that date.

The most current version of the Privacy Policy is available for review at any time on the Site.

11. Contact

All questions relating to this Privacy Policy are handled by the Data Protection Officer who can be contacted by email at dpo@eurosagency.eu or by post to the following address:

Euros / Agency Group
To the attention of Mrs Abigail TEVES
Data Protection Officer
1 place d’Estienne d’Orves
75009 Paris