PERSONAL DATA PROTECTION POLICY
1 – What is the purpose of this document?
In accordance with the General Data Protection Regulation No. 2016/679 and the "IT and Liberties" Law of January 6, 1978 in its latest version, this personal data protection policy is intended to inform you of all processing implemented on your personal data on the site accessible at the address https://www.gravitao.com.
2 - Who is responsible for processing?
The person responsible for the processing of personal data implemented on the website https://www.gravitao.com is NOW-W, a simplified joint stock company, registered in the Bordeaux Trade and Companies Register under the number 892 137 738, whose head office is located at 26T Allée de Campes, 33470 GUJAN-MESTRAS.
3 – Definitions
The following terms shall have the following meaning, plural or singular:
“NOW-W” or “we”: refers to the NOW-W company;
“Personal Data”: means any personal data within the meaning of Article 4 of the General Data Protection Regulation (GDPR);
“CNIL”: refers to the National Commission for Computing and Liberties;
“GDPR”: refers to the General Data Protection Regulation n°2016/679 of April 27, 2016;
“Data Protection Act”: refers to Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, in its latest version;
“Website”: refers to the GRAVITAO website published by the company NOW-W accessible at the URL address https://www.gravitao.com/.
4 – What Personal Data is processed and under what circumstances?
NOW-W collects, via the Website, the following categories of data:
• The data allowing your identification that you communicate to us via the contact form on the Website (title, surname, first name, email, telephone number, country, city, etc.);
• The data relating to the personal contribution that you wish to provide in order to filter your searches on the Website;
• Data relating to your contact requests (subject of the request, message);
• Browsing and traffic data collected automatically during your use of the Website.
Personal data is obtained directly from you or results from your use of the Website.
In the event that your Personal Data is collected through a contact form, you are informed of the mandatory nature of the information by an asterisk (*). In the absence of a response from you, the processing cannot be taken into account and your request cannot be completed.
Only Personal Data that is strictly necessary for the purposes described below is collected. Please note that this personal data protection policy only concerns your Personal Data collected and processed via the Website and does not relate to the subsequent processing implemented by NOW-W in the context of the contractual or commercial relationship with you.
5 – For what purposes and on what legal bases are your Personal Data processed? How long are they kept?
The processing of your Personal Data is based on the legal bases and for the following retention periods:
THE WEBSITE USERS RELATIONSHIP MANAGEMENT
Purposes / sub-purposes:
Communication and exchange of information in order to respond to contact requests and your messages.
Legal basis
Legitimate interest of NOW-W to respond to user requests via the contact form.
Data retention periods
6 months from the last exchange.
THE WEBSITE USERS RIGHTS MANAGEMENT
Purposes / sub-purposes:
Management of requests for the exercise of user rights on the processing of their personal data (rights of access, right of opposition, right to limit processing, etc.).
Legal basis
Legal obligations.
Data retention periods
1 year for the rights of access, rectification, erasure and right to restriction of processing.
6 years for exercising the right to object to processing.
6 – Who are the recipients of your Personal Data?
Your Personal Data may be communicated, according to their attributions and according to the purposes pursued, to the recipients set out below:
Category of data recipients
Recipients internal to NOW-W: The personnel responsible in particular for the sales department, communication and IT of NOW-W.
Recipients external to NOW-W: Subcontractors in charge of the implementation of personal data processing, or within the framework of consulting and assistance missions. Interveners in the context of operations relating to the life of the data controller (transfer, merger, absorption of companies, universal transmission of heritage…).
7 – Are your Personal Data transferred outside the European Economic Area (EEA)?
Your Personal Data is not transferred outside the EEA. They are hosted in France and/or within the European Union.
In the event of a transfer of your Personal Data to a country outside the European Union, NOW-W will implement all appropriate measures to guarantee a sufficient level of protection for your data, such as:
• Favoring so-called “safe” countries, i.e. offering significant protection of your personal data;
• Obtaining guarantees of security and confidentiality by formalizing standard contractual clauses from the European Commission, reserving the possibility of checking them regularly.
8 – What are your rights regarding your Personal Data?
You have the following rights over your Personal Data:
• Right of access: you can at any time obtain a copy of your Personal Data as well as information on the nature, origin and use of these, the identity or categories of any recipients of those;
• Right of rectification: you can request that Personal Data concerning you that is inaccurate or incomplete be modified or completed;
• Right to erasure: you can request the erasure of your Personal Data, in particular if it is no longer necessary for the processing carried out, unless legal obligations are incumbent on the data controller to keep this data or it is necessary to the recognition, exercise or defense of legal claims;
• Right to limit one or more processing of your personal data: you can request that your Personal Data be made temporarily inaccessible in order to limit their future processing in the following situations:
• When you dispute the accuracy of your Personal Data, for a period allowing the controller to verify the accuracy of the data;
• When you believe that the processing is unlawful and you oppose the erasure of your Personal Data;
• When your Personal Data no longer has a reason to be kept but you want them to be kept for the exercise or defense of your legal rights;
• When you have objected to the processing, during the verification of whether the legitimate grounds pursued by the controller prevail over yours.
• Right to portability: you can request to receive communication of the Personal Data concerning you that you have provided to the data controller and processed by automated means, in a structured and commonly used format. This right can only be exercised if the processing is based on your consent or on the performance of a contract or pre-contractual measures;
• Right of opposition: you may object at any time, for reasons relating to your particular situation, to the processing of your Personal Data based on the legitimate interests of the controller unless there are legitimate and compelling reasons for processing that overrides your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims;
• Right to define instructions in the event of death: you can give instructions relating to the storage, erasure and communication of your Personal Data. In the event of death, your Personal Data will in principle be deleted, unless legal and regulatory obligations and legal limitation periods require it to be kept;
• Right to withdraw consent: you can withdraw your consent at any time regarding the processing of your Personal Data based solely on this.
9 – How to exercise your rights?
You can
make any request relating to the exercise of your rights concerning your Personal
Data at the following email address:
You may be asked for proof of identity. The exercise of one of these rights may be refused if your request does not meet the conditions laid down by the regulations. In this case, you will be duly informed.
10 – How to lodge a complaint with the CNIL?
If you believe that the processing of your Personal Data does not comply with legal and regulatory provisions, you can file a complaint with the CNIL at the following address: 3 place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, or directly online via the CNIL website https://www.cnil.fr/.