1. PRIVACY POLICY

Confidentiality and security are of the utmost importance to TIAMA and we strive to ensure that our technical and organizational measures in place respect your data protection rights.

This Privacy Policy describes our rules regarding the management, processing and storage of personal data submitted as part of our services. The term “personal data” means information relating to a natural person identified or who can be identified.

Consent

By subscribing to our services or by filling out a contact form on our website youniverse.tiama.com you agree that TIAMA may collect, process, store and / or use the personal data submitted in accordance with the rules set out below.

By giving us your consent, you also retain the right of rectification, the right to be forgotten and / or the right to the deletion of your personal data.

Personal data collected

We may collect or receive personal information for a number of purposes connected with our business operations.

CNIL declaration

You are entitled to lodge a complaint with the competent supervisory authority regarding the processing of your data. In France, the supervisory authority for the protection of personal data is the CNIL (www.cnil.fr).

For which purposes and on which legal basis do we use your personal data?

  • Managing client and prospect relationships
    – Purpose of the processing: information needed to manage the contractual or business relationship with you (e.g., contracts, orders, transactions, invoices, etc.), sending communications about products, services, offers, promotions, benefits, and events, as well as information that may be of interest to you.
    – Legal basis: our legitimate interest (management of client and prospect relationships); or your consent.
  • Responding to your requests via our website forms
    – Purpose of the processing: responding to your questions submitted via the Contact form or other similar forms, including for job applications, depending on the subject of your request.
    – Legal basis: our legitimate interest in responding to requests or job applications sent to us; or your consent.
  • Ensuring the security of the website
    – Purpose of the processing: you may generally browse the website without having to provide us with data that allows you to identify yourself. However, information relating to your browsing is automatically collected in order to ensure the security of the website. For more information, please read our Cookie and Privacy Settings.
    – Legal basis: legitimate interest in the proper functioning of the website, its optimization, and its security.
  • Management of disputes and litigation
    – Purpose of the processing: management of disputes and litigation.
    – Legal basis: legitimate interest in defending our interests in court and preparing our defense in litigation proceedings.
  • Compliance with applicable laws, court orders, other legal proceedings, or the requirements of any authority
    – Purpose of the processing: compliance with applicable laws, court orders, other legal proceedings, or the requirements of any authority.
    – Legal basis: legal obligation.

Will we share your personal data with third parties?

We share personal data with our affiliates within the Kestrel Vision group to improve your experience by offering you tailored content, personalized offers and services, as well as communications that better match your expectations, and to enable us to understand your preferences and purchase history of our products and services, in order to also improve their visibility, accessibility, and performance.

Our duly authorized staff who need to access your data in the course of their duties in relation to the purposes described here may have access to your personal data.

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and TIAMA’s internal policies.

If our website or organisation is taken over, sold, or involved in a merger or acquisition, your details may be disclosed to our advisers and any prospective purchasers and will be passed on to the new owners.

What about sensitive data?

We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What is the nature of the collected data?

TIAMA may collect personal data at its website in three ways and processes the following information:

  •  Information you provide when you access the “contact” form. This includes last name, first name, your email, your company, as well as a free zone “message”.
  • Information you provide by completing the form on our website for your motivated application (“careers” page). This includes last name, first name, your diplomas, the languages ​​spoken and the subject of your application as well as a free zone “message”, and 2 attachments: your CV and your cover letter.
  • Information you provide to receive our news-letter: civil status, email address, company, appellation glassware, function, address and a free zone “message”.

In case you contact us directly, we reserve the right to keep a record of this correspondence.

Our website collects information about your computer, including (if applicable) your IP address, operating system, and browser, administration system, to filter information, check user domains, and report statistical.

The details of your visits to our website: the pages you visit and the information you search for or download, including, but not limited to, the number of your connections, location data, weblogs and other communication data. When this information concerns you or is likely to identify you, we will treat it as “personal data”.

How do we use personal data that we collect from our websites?

We use personal data for the purposes described above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected.

For example:

  • To fulfill your requests for white papers, articles, newsletters or other content.
  • For surveys or research questionnaires.
  • To personalize your experience at our website.
  • To contact you for marketing purposes where you have agreed to this.
  • Answer your requests for information and give you advice
  • Provide you with relevant personalized offers and information
  • Evaluate the effectiveness of our offers and emailing campaigns
  • Minimize an identified risk for the data
  • Protect against possible fraudulent actions

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the cookies section  for more information.

Data recipients

The data collected on the website is intended for TIAMA and may be transmitted to the subcontracting companies to which TIAMA may call in the performance of its services and to the extent necessary for the accomplishment of the tasks entrusted to them.

TIAMA ensures that its staff and subcontractors comply with the applicable regulations on personal data and this privacy policy. TIAMA requires subcontractors and staff to pay special attention to the confidentiality and security of the data.

Recruitment

If you use our online application forms, TIAMA collects the personal data you submit on the site and uses it for recruitment purposes. We may also use cookies, other targeting technologies and the same technologies to conduct Marketing actions (including our Customer Relationship Management (“CRM”) databases, targeted emails and the combination and analysis of data) to provide candidates with personalized access to the site, send relevant information on opportunities and careers at TIAMA and analyze the effectiveness of our recruitment efforts and resources. Additional information on how your data will be used by TIAMA during the recruitment process will be provided as part of the recruitment process.

Marketing

Below, our use of personal data for commercial purposes:

Marketing Data Sources

Most of the personal data we collect and used for marketing purposes relates to employees of our customers or other companies with which we have a business relationship. We may also obtain contact information from public sources, including content posted on social media, to establish a first contact with a person within a current or potential client company.

Targeting email

We send advertising emails to employees of our customers or other companies with whom we want to develop or maintain a business relationship. Our targeting emails typically include web beacons, cookies and similar technologies that let us know if the mails are being read or deleted and if the links have been clicked. When you click on a link in an advertising email that you receive from TIAMA, we record via a cookie the pages of our websites you visit and the content you download, even if you are not registered to or connected to our site.

TIAMA’s targeting emails may include additional information about the processing of your personal data when required by applicable laws.

Databases Customer Relationship Management

Like all large companies, TIAMA uses a Customer Relationship Management (“CRM”) database to manage and track its marketing efforts. Our Customer Relationship Management (“CRM”) databases include personal data belonging to persons employed by our clients or other partners with whom we have a business relationship or with whom we wish to develop a business relationship. Personal data used for these purposes includes business information necessary for the development of a business relationship such as: contact data, publicly available information (e.g., Board of Directors, published articles, press releases, public messages published for commercial purposes, on social networks the responses to targeted emails (including the web activity relating to the links followed in our e-mails), the activity of users registered on our website, our online catalogs and other information recorded by TIAMA staff based on interactions with our customers and partners If you wish to be removed from our Customer Relationship Management (“CRM”) databases, please use the “Contact” form.

The combination and analysis of data

As explained above, we may combine data from the public domain and data generated by our various interactions with you (personal contacts, e-mail or website, including information collected on our various sites such as our career pages and our corporate sites, as well as the information collected when you register or connect to our sites, or when you connect to our sites using your social network credentials (such as LinkedIn and Xing)). This data is combined to better evaluate your experience with TIAMA and to perform the other tasks described in our privacy policy.

Your rights regarding collection by TIAMA marketing

You may exercise your right to refuse to receive our marketing communications by ticking certain boxes on the forms we use to collect your personal data, or by using the opt-out mechanisms in the emails we send you. You may also exercise the right to discontinue marketing communications addressed to you or you may also choose to delete your data in our Customer Relationship Management (“CRM”) databases at any time by using our “Contact” form.

2. YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA

In accordance with the Data Protection Act of 6 January 1978 as amended, and the General European Data Protection Regulation 2016/679 (GDPR), you have the rights of access, rectification, forgetting and deletion of personal data about you that you can exercise by sending us a message to the address rgpd@kestrel-vision.com or by using the “Contact” form. You can withdraw at any time your consent to any processing of your data that is based on your consent.

The response to the exercise of all these rights is subject to the transmission to TIAMA of the copy of an identification document.

TIAMA undertakes to consider the exercise of your rights as soon as possible except in cases where the law or a legitimate reason requires TIAMA to keep some of your data.

In accordance with article 40-1 new of the law of 6 January 1978, you can define and transmit to TIAMA the directives relating to your data which you wish to apply to your death. You can send your instructions by e-mail to rgpd@kestrel-vision.com.

In the event of an unsatisfactory answer, you have the option of contacting CNIL, as detailed above.

3. WHAT ABOUT DATA RETENTION ?

  • Managing client and prospect relationships: during the commercial relationship, and then 3 years from your last contact with us (clients) and 3 years from your last contact with us (prospective clients).
  • Responding to your requests via our website forms: for the duration of the processing of your request, then, depending on the nature of your request, archived for a period of up to three (3) years from the resolution of the request.
  • Ensuring the security of the website: for the duration of security and integrity operations, which may vary depending on the operations carried out (from 3 to 6 months).
  • Management of disputes and litigation: for the duration of the complaint, then retention in accordance with the applicable statutory limitation periods, calculated from the date the complaint is resolved; or, in the event of legal action: retention of the data for the duration of the proceedings until full enforcement of the court decision or the settlement agreement.
  • Compliance with applicable laws, court orders, other legal proceedings, or the requirements of any authority: for the period provided for by the applicable law or by the relevant judicial or administrative decision.

4. WHERE WILL YOUR PERSONAL DATA BE PROCESSED?

Our processors may transfer your personal data outside the European Union. In the absence of an adequacy decision by the European Commission under Article 45 of the GDPR, any such transfer will be governed by appropriate transfer mechanisms under Article 46 et seq. of the GDPR (such as standard contractual clauses adopted by the European Commission).

5. WHAT ABOUT DATA SECURITY ?

TIAMA attaches the utmost importance to the security and integrity of the data being processed on the Site. Also TIAMA aims to always keep your data in the most secure way and only for the time necessary to achieve the purpose pursued by the processing.

In accordance with the provisions of the GDPR, TIAMA undertakes to implement, both at the time of the determination of the means of the treatment and at the time of the processing itself, the appropriate technical and organizational measures to guarantee a level of security adapted to the risk.

TIAMA puts in place ways to ensure the ongoing confidentiality, integrity, availability and resilience of treatment systems and services.

In the event of a technical or physical incident relating to the data, TIAMA will endeavor to restore to the extent possible the availability and access of the data within an appropriate period of time.

TIAMA regularly tests its processes in the event of a technical or physical incident in order to guarantee and maintain a level of reactivity and optimum efficiency.

However, given the structure of the Internet and the networks, TIAMA cannot commit itself to an obligation of result with regards to security. In case of detection of a security breach likely to create a high risk for your rights and freedom, TIAMA undertakes to make its best efforts to neutralize the situation or intrusion and minimize the impacts.

6. AMENDMENT OF PRIVACY POLICY

TIAMA reserves the right to modify this privacy policy at any time, in particular in application of the laws and regulations in force.

7. CONTACT US

Please, visit our contact page at https://youniverse.tiama.com/contact/ if you have questions, if you do not wish to receive commercial communications, if you wish to have your personal data deleted from our CRM database or you can directly contact the Data Protection Officer by email at rgpd@kestrel-vision.com or by mail at:

TIAMA, for the attention of the Data Protection Officer,

215 Chemin du Grand Revoyet
69230 Saint-Genis-Laval
France

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