Privacy policy

Euros / Agency Group, a simplified joint stock company with a capital of 533,060 euros, registered in the Paris Trade and Companies Register under number 879 600 096, whose registered office is located at 1 place d’Estienne d’Orves, 75009 Paris (hereinafter the “Company” or “Euros / Agency Group“), writer of the present document, implements personal data processing.

The Company may act as a “data controller” when processing personal data on its own behalf, or as a “data processor” when processing personal data on behalf of its clients.

 

  • Purpose of the Euros / Agency Group Privacy Policy

Euros / Agency Group is committed to protecting the privacy and personal data of its website users and clients.

The Euros / Agency Group privacy policy is intended to set out how the Company collects and processes personal data (hereinafter the “Privacy Policy).

The personal data collected or held is either directly communicated by the data subject himself/herself, or is collected indirectly through public sources, or comes from third parties, or is collected from the www.eurosagency.eu website (hereinafter the “Site).

The Privacy Policy has been drafted in consideration of the applicable legal and regulatory provisions, in particular the General Regulation of the European Parliament and of the Council on the protection of personal data No. 2016/679 of 27 April 2016 (hereinafter the “GDPR) and the French Data Protection Act (Loi Informatique et Libertés) as amended to incorporate the provisions of the said GDPR into French law. 

The Privacy Policy supplements the Legal Notice and the Terms of Service of the Site.

 

  • Personal data collected by the Company 

The Company collects data:

  • as part of its recruitment process;
  • for commercial and marketing purposes; 
  • in the context of its public relations and interest representation activities;
  • as part of the services provided;
  • through its website.

 

    • Data collected as part of the recruitment process

Euros / Agency Group collects the following data through the recruitment form available on its Site: first name, last name, e-mail address, telephone number, years of experience, language skills, curriculum vitae and cover letter, in order to carry out recruitment and selection activities.

The processing of personal data by means of the job application form is based on the legitimate interests of the Company with a view to recruiting potential new employees.

Only people involved in the recruitment process can access to the applicant’s information.

The data of selected candidates may be kept in an active database for the duration of the recruitment procedure until the hiring decision. After the hiring decision, the data may be reused and stored for personnel management purposes.

In the event of a negative outcome to an application, the Company will inform the applicant that it wishes to retain the file, in order to give the applicant the opportunity to request its destruction.

If the applicant does not request the deletion of his/her file, the data will be automatically deleted two (2) years after the last contact. 

Only the consent of the applicant allows a longer conservation.

 

    • Data collected for commercial and marketing purposes

The following information is collected and processed: contact details, such as surname, first name, home address, country of residence, telephone number, e-mail address.

This information constituting personal data is used for the following purposes: 

  • To send communications about the services offered by the Company, for direct marketing purposes. These communications may take the form of an e-mail or a letter, an SMS, a telephone call or targeted advertising. These data are kept for direct marketing purposes for a maximum period of three (3) years.
  • Where data has been collected in connection with the provision of a service or enquiries, information on similar or targeted services or enquiries based on previous requests may be sent, unless the data subject requests to stop receiving such commercial communications or chooses not to receive them. These data are kept for direct marketing purposes for up to three (3) years after the data collection.

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 authorized 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.

 

    • 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 authorized 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.

 

    • 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 authorized 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. 

 

    • Data collected from the use of the Website

 

      • 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 recognize 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 recognized 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:

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.

 

      • 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 organized 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.

 

  • 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:

Activity concerned

Subcontractor

Activity carried out on behalf of Euros / Agency Group

Operational service

NFFRANCE CONSEIL

Hosting of the Site

HELLOSIGN

Electronic signature service

HR and payroll solutions

Lucca

Internal process management (HR)

Payroll & HR solutions

Outsourcing of payroll and related processing

Audience measurement

Google Analytics

Analysis of Site usage data and performance of the Company’s marketing operations

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 Authority for Transparency in Public Life (HATVP), pursuant to legislative and regulatory provisions.

In such a situation, the Company undertakes to communicate to the authorized 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. 

 

  • 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 recognized 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.

 

  • 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. 

 

  • 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.

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

 

  • Protection of personal data

Euros / Agency Group undertakes to implement and maintain, at its own expense, appropriate technical and organizational 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, unauthorized 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. 

 

  • 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. 

 

  • 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.

 

  • 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.

 

  • 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