Privacy Policy

The present Privacy Policy informs you how Clayrton’s collects and processes personal data concerning you through its website https://clayrtons.com (hereinafter referred to as the “Site”) as the data controller within the meaning of the provisions of the General Data Protection Regulation n°2016/679 of April 27, 2016 (“GDPR”) and the law known as “information technology and liberties” n°78-17 of January 6, 1978 (hereinafter collectively referred to as the “Regulation”).
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Definitions from the GDPR

The following definitions are those derived from the General Data Protection Regulation n°2016/679 of April 27, 2016 (GDPR) and the law known as “Information Technology and Liberties” n°78-17 of January 6, 1978.

Personal data

A personal data is any information relating to an identified or identifiable natural person. This person can be directly identified (e.g., name and first name) or indirectly identified (e.g., through a telephone number or license plate, an identifier such as a social security number, a postal or email address, but also the voice or image), thanks to a single piece of data or through the combination of several pieces of data (e.g., a woman living at a certain address, born on a certain day, and a member of a particular association).

Recipient

The natural or legal person, public authority, agency, or any other entity authorized to access data recorded in a file or processing due to its functions.

File

A file is a data processing operation organized as a stable and structured set of data. The data in a file is accessible according to specific criteria.

Data Controller

The data controller is the legal or natural person (company, municipality, etc.) who determines the purposes and means of processing, that is, the objective and the way it is carried out. In practice and generally, it refers to the legal entity embodied by its legal representative.

Data Processor

“The data processor is the natural or legal person (company or public organization) who processes data on behalf of another organization (the ‘data controller’), as part of a service or provision.”

Processing

A processing of personal data is an operation, or set of operations, carried out on personal data, regardless of the method used (collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission or dissemination, or any other form of making available, alignment).

A processing of personal data is not necessarily computerized: paper files are also covered and must be protected under the same conditions.

A processing of data must have a specific purpose, a predetermined objective before the collection and use of the data.

2. Who is responsible for the processing of personal data carried out through the Site?

“It concerns the company Clayrton’s (hereinafter “Clayrton’s” or the “Company” or “We”), which is a simplified joint-stock company with its registered office located at 41 Rue Saint-Antoine, 59100 Roubaix, represented by Alban-Josse Lepoutre.”

Whenever Clayrton’s has determined the purposes and means of processing your personal data, it will be considered the data controller and will assume all the obligations imposed on it by the Regulation.

A dedicated contact person for data protection can be reached at the following address: dpo@clayrtons.com.

3. How are your personal data collected ?

Personal data is collected from our contact form and newsletter subscription requests.

We collect the personal data that you directly provide to us:

These are the personal data that you directly provide to us by responding to our collection forms, including those available online on our website (such as: name, email address, etc.). These include contact details and any other information you wish to share with us.

It may also include data that you spontaneously provide to us when contacting our teams.

Furthermore, we also process data that you provide to us during our interactions (e.g., during a phone call or a demonstration of our software).

The data collected by Clayrton’s through these means may be mandatory or optional. The mandatory fields are marked with an asterisk (*) within each form. When data is collected orally, we will specify the mandatory or optional nature of the information. All the data that you spontaneously provide to us is, by definition, optional.

We collect some of your Personal Data automatically:

When you visit the Site, data is automatically recorded through your browsing activities on our Site, either:

• Indirectly through third-party cookies,
• Directly through server event logs (log files) managed by the individuals responsible for Site management (either within the Company or as IT service providers).

These are your Browsing Data.

When the collection of this Browsing Data is mandatory, it is collected to ensure the availability of the Site, its improvement, and the maintenance of a secure environment.

When the collection is optional, your prior consent is obtained for the Browsing Data used (the list will be modified according to the cookies actually used on the site and their purposes) to measure the audience of our Site and the performance of our campaigns, optimize lead management, analyze your behavior as an internet user, and/or provide targeted advertising.

It may include, in particular:

• Data related to your connection to the Site:

For example, your IP address, the website address you visit, your search engine and its settings, the date and time of the connection, how you browse the Site, and any other usage tracking data related to your use of the Site.

• Data related to the equipment that allows you to access the Site:

Depending on the equipment you use and the enabled settings, the following data may be collected: the type of equipment (mobile phone, tablet, PC, MAC, etc.) and the operating system you use and its settings.

4. For what purposes and how long do we use your personal data?

We use your Data for the following purposes, as explained in the table below.

These Data are collected under one of the conditions provided by the Regulations, namely the following legal bases:

• The performance of a contract to which you are a party or pre-contractual measures concerning you,
• Compliance with a legal obligation,
• Your consent to the use of your Data,
• Our legitimate interest in using your Data.

Below you will find detailed information concerning the processing carried out via the Site.

Informations included in resumes, letters, and emails sent by applicants, interview dates, salary position, follow-up on applications, type and duration of proposed contracts.The data is retained for 2 years from the last contact.Event OrganizationManagement of event organization including sending invitations, registration follow-up, satisfaction tracking, handling questions and requests during events.The processing is necessary for Clayrton’s legitimate interest in promoting and improving its events to a professional audience and organizing these events.

Identity and contact data;

Data related to event registration and participation;

Exchanges related to event organization and interventions.

Data is retained for 3 years from the last contact in the active database, then archived for probative purposes for 5 years.Management of Clayrton’s website

Technical administration of the Site (maintenance, hosting);

Securing the Site;

Improvement of user experience;

Production of audience and service usage statistics.

The processing is necessary for Clayrton’s legitimate interest in managing its showcase website and providing it securely;

Consent for third-party cookies.

Identity and contact data;

Data related to site navigation (timestamp, IP address, technical data related to equipment and browser used, cookies) and on digital platforms via sharing buttons and media (cookies and other trackers);

Data related to contact management (timestamp and subject of request, follow-up, actions taken, statistics);

Audience statistics.

13 monthsProspecting ManagementManagement of business relationships with clients regarding contracts; quotes; orders; invoices; accounting and, in particular, customer account management; customer relationship follow-up, including conducting satisfaction surveys, handling complaints and after-sales service; selecting clients for studies, surveys, and product testing.

The processing is necessary for Clayrton’s legitimate interest in managing its business and contractual relationships.

When the professional is a natural person considered a consumer under consumer law, the processing is based on the execution of the contract between Clayrton’s and the professional or on pre-contractual measures at the professional’s request.

Identity and contact data;

Information related to professional life;

Economic and financial data.

Data is retained for 3 years from the end of the contractual relationship in the active database, then archived for probative purposes for 5 years.Communication ManagementRegularly sending newsletters to subscribers.ConsentEmail addressFor the duration of the person’s subscription to the newsletter (unsubscription possible via the unsubscribe link included in the newsletters).Newsletter Management

If you have submitted a spontaneous application on the Site and it has not been accepted, we will contact you to ask if you want us to keep your personal data in order to offer you another position in the future, or if you want it to be destroyed. In any case, your personal data will be automatically destroyed 2 years after your last contact with Clayrton’s.

The data concerning identity documents related to the exercise of the rights of access, rectification, erasure, limitation, and portability are kept for 1 year from their receipt.

In the event of a legal procedure, personal data concerning you will be kept to enable Clayrton’s to defend its interests.

5. Who are your personal data intended for?

Within Clayrton’s

Whether in individual or aggregated form, your personal data is processed by Clayrton’s employees.

In any case, only data strictly necessary for the purpose of the processing is transmitted to employees who are authorized to know them due to their functions. All individuals who may have access to your personal data are contractually bound to confidentiality.

In specific cases, only the following individuals have access to your personal data:

• Legal representatives of Clayrton’s;
• The commercial manager of Clayrton’s;
• Your customer account manager;
• Members of Clayrton’s responsible for technical operations related to the exercise of individuals’ rights.

Transfers outside Clayrton’s

Several categories of third parties listed below may have access to your personal data. Only the personal data strictly necessary for the purpose(s) pursued by the envisaged processing is transmitted to them.

• Subcontractors, including our Service Providers:
  • Information Technology:
    • Responsible for the administration, hosting, and maintenance of the Site;
    • Responsible for the administration and hosting of the site: Planethoster – 4416 Louis-B.-Mayer, Laval, Quebec, Canada, H7P 0G1;
    • Provider of CRM solution;
    • Provider of analysis and advertising tools (Google Analytics).
  • Marketing providers (marketing agency and search engine management, solution for enrichment and validation of professional contacts).

We ensure that, in terms of personal data, these subcontractors are contractually bound to implement protection levels equivalent to ours and, in any case, compliant with the Regulation.

• The companies providing the third-party cookies for which you give your consent for their installation (see cookie policy).
• Exceptionally, competent authorities (administrative, judicial, police) due to a legal obligation or to ensure the rights, property, or safety of Clayrton’s

Clayrton’s undertakes not to transmit your personal data to third parties unless:

1. You have given prior consent for the sharing of your personal data with third parties;
2. The sharing of your personal data with said third party is necessary for the provision of requested products or services;

• A competent judicial or administrative authority requires Clayrton’s to communicate said personal data.

Transfer outside the EU

As of today, we do not transfer your data outside the European Union.

However, concerned

You can communicate your directives to us or register them with a certified digital trusted third party. You can designate a person of your choice who will be responsible for executing your directives. If not, your heirs will be responsible.

6.8 Regarding Consent

Several processing of your personal data is subject to your consent. For example, when you request information via the Site’s contact form.

You can withdraw your consent at any time by sending an email to the following address: dpo@clayrtons.com.

The withdrawal of consent does not affect the lawfulness of processing personal data based on your consent before its withdrawal.

Please note that personal data required to respond to your requests or provide requested services are marked with an asterisk on the collection form. Without this information, Clayrton’s may not be able to respond to your requests or provide the requested products or services.

7. How to Exercise Your Rights?

For any request to exercise your rights, please refer to: this link.

7.1 How to Exercise Your Rights

You can send your requests to the following addresses:

• Clayrton’s, 41, rue saint Antoine CS 59059 Roubaix Cedex 1 – France

• dpo@clayrtons.com

To exercise your rights regarding your data, please include a copy of a valid identification document (identity card or passport), unless the information provided in your request allows us to identify you with certainty.

To assist you in this process, you can use the following link to find a letter template developed by the Commission Nationale de l’Informatique et des Libertés (CNIL): https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces.

7.2 Response Time

Clayrton’s has a one (1) month deadline to respond to your request from the receipt of your request. This period may be extended by two months due to the complexity of your request and the number of requests received. Clayrton’s will inform the individual of this within the month of receiving the request.

Regarding commercial offers sent electronically, you have the option to unsubscribe at any time by clicking on the hyperlink provided in each email sent by Clayrton’s.

You also have the right to lodge a complaint with the CNIL, the supervisory authority (www.cnil.fr).

8. Use of Your Data by Third-Party Platforms

The Site may contain links to other sites. Similarly, other sites may reference or contain a link to our Site. We have no control over these other domains and websites. We encourage our users to read the privacy policies of each website and application they may interact with. We do not endorse, verify, or approve, nor are we responsible for the privacy practices or content of such websites or applications. If you visit the other relevant websites or applications, you do so at your own risk and are subject to their privacy policy.

8.1 Social Media Plugins

Our Site uses plugins (extensions) provided by third-party companies (e.g., Facebook, Twitter, Google+, etc.).

If you interact using the plugins by clicking on the icons available on our pages, some of your personal data, including technical and navigation data, will be transmitted and stored on a server belonging to the third-party company operating the corresponding social network of the icon you clicked. This data will then be processed by that third-party company in accordance with its terms and the settings of your account opened within that social network.

Your data may be hosted outside the European Union, including in the United States.

If you do not want a third-party company operating a social network to link the personal data collected through the Site to your user account within the relevant social network, you must log out of that social network before visiting the Site.

In any case, the use of these plugins is managed by the third-party companies that publish the social networks and is exclusively governed by the terms that bind you to the social network of which you are a member. We invite you to read the terms applied by these third-party companies that publish social networks.

8.2 Google Services

This site uses several features offered by Google. As such, some of your personal data, including your browsing data, may be transferred to this company, whose servers may be located outside the European Union, including in the United States. The use made of your personal data by Google is subject to the terms of use issued by the latter. We recommend that you read them carefully in order to fully exercise your rights in this regard.

The services concerned include YouTube, Google Analytics, Google Ads, and Google Maps.

1. The integration of YouTube videos accessible on the Site requires the installation of YouTube plugins.

When you view one of our pages that is equipped with a YouTube plugin, a connection is established to YouTube’s servers through which information about the pages you have viewed is transmitted.

Usually, if you are logged into your YouTube account, you allow YouTube to directly link your browsing behavior to your personal profile and offer you targeted advertising. You can prevent this by logging out of your YouTube account.

The use of YouTube is in the interest of an attractive representation of our online offers. We draw your attention to the fact that we have chosen to opt for the “enhanced privacy mode” offered by YouTube, which according to Google “allows you to integrate YouTube videos without using cookies that track viewing behavior”. This feature is intended to prevent the usual deposition of additional cookies by Google to subsequently enable them to offer you personalized advertising.

You can find more information about the use of user data in the privacy statement on data protection at YouTube, which can be found on its site: YouTube Privacy Policy.

1. Google Analytics uses cookies to analyze your use of the Site based on your consent.

Specific settings have been implemented to anonymize the user’s IP address.

You can prevent the storage of cookies by making the appropriate settings in your browser; however, we draw your attention to the fact that in such a case, you may not be able to use all the functions of the Site.

In addition, by downloading and installing the Browser Plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=fr, you can prevent:

• Google from collecting personal data generated by Google Analytics cookies relating to your use of the Website (including your IP address),
• The processing of this data by
  https://support.google.com/analytics/answer/6004245?hl=fr.