Privacy policy
Below you will find details of how we handle your personal data.
LOCKSELF SAS (hereinafter "LOCKSELF") is a société par Actions Simplifiée (simplified joint stock company) with capital of €278,216, having its registered office at 22 avenue chevreul, 92600 Asnières-sur-seine and registered with the Nanterre Trade and Companies Register under number 800 034 043.
LOCKSELF undertakes to comply with the legislation in force in France and Europe (Regulation 2016/679 of April 27, 2016), to ensure the protection, confidentiality and security of personal data, and to ensure respect for privacy.
This Personal Data Protection Policy (hereinafter "the Policy") describes how LOCKSELF collects and processes the personal data of LOCKSELF and of all other persons concerned by the processing implemented by LOCKSELF.
The Policy also specifies the legal bases on which we rely to process personal data, with whom we share it and how it is stored.
LOCKSELF is, depending on the processing, either the Data Controller or the Data Processor. LOCKSELF respects the following principles:
- Your data is used solely for explicit, legitimate and specific purposes related to LOCKSELF's various businesses. It is processed lawfully and fairly;
- Only data that is useful to us is collected;
- You are informed, in a clear and transparent manner, of the purpose for which your data will be used, the optional or compulsory nature of your answers in the forms and your rights in terms of data protection.
Article 1 - Definitions
- Personal data": any information relating to an identified or identifiable natural person, either directly, for example by surname or first name, or indirectly, in particular by reference to an identifier, such as an identification number, location data or online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
- "Processing": any operation or set of operations which may or may not be performed using automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction.
- Data subject" / "You": identified or identifiable natural person whose personal data is processed.
- Data Controller": the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing - "Data Processor": the natural or legal person who processes personal data on behalf of the Data Controller.
- Recipient": natural or legal person who receives the communication of personal data, whether a third party or not.
- "Third party": authorized natural or legal person, public authority, service or body other than the data subject, the controller, the processor and persons who, placed under the direct authority of the controller or processor, are authorized to process personal data.
- "Personal data breach": a breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.
- You" / "Your": refers to the person concerned by LOCKSELF's processing of his/her personal data.
Article 2 - Purposes of processing your data
Your personal data is used for the following purposes:
- To enable authentication and identification of persons within the LOCKSELF platform;
- To manage requests from customers or prospects;
- Management and execution of your contracts;
- The analysis, examination and management of claims/litigations; - The fulfilment of legal, regulatory or administrative obligations; - The carrying out of satisfaction surveys, in particular to solicit your opinion and to improve our services;
- To compile statistics, particularly of a commercial or audience nature; - To respond to job applications;
- Build up a CVLibrary.
When subscribing to a contract, certain data are mandatory, in particular to enable contractual execution. LOCKSELF will not be able to execute the contract or respond to your request if this data is not provided.
Article 3 - Legal basis for data collection
Personal data is collected, depending on the case, on different legal bases:
- In the legitimate interest ;
- As part of the performance of a contract;
- In compliance with a legal or regulatory obligation;
- When we have obtained your consent.
Article 4 - How long we keep your data
Your personal data will be kept for as long as is necessary for the purpose of processing your file and for as long as is necessary to meet our legal obligations.
Article 5 - Recipients of your data
Only those persons who need to know your data in order to carry out their duties have access to it. This includes :
- LockSelf employees;
- authorized partners and professional bodies
- subcontractors;
- administrative and legal authorities to meet legal and regulatory obligations.
Article 6 - Storage of your data
Your data is stored on the territory of the member states of the European Union.
Article 7 - Your rights regarding your personal data
You have the following rights with regard to your personal data:
Right of access: You have the right to obtain confirmation from us as to whether or not your personal data is processed by us, as well as certain other information on how it is used.
Right of rectification: You can ask us to take steps to correct your personal data if it is inaccurate or incomplete (for example, if we have the wrong name or address).
Right to erasure ("Right to be forgotten"): You can request the erasure or deletion of your personal data (e.g. where there is no compelling reason for us to continue to use it, or if its use is unlawful).
Right to restriction: You have the right to limit or prevent the further use of your personal data. Limiting processing does not prevent us from keeping your personal data, but we will not be able to use it beyond the limits you wish.
Right to portability: You have the right to retrieve and reuse certain personal data. This right applies only to personal data that you have provided to us, that we process with your consent and for the purpose of performing the contract and that are processed by automated means.
Where appropriate, we will provide you with a copy of your data in a structured, commonly used and machine-readable format (where technically possible). We may also transmit your data directly to another data controller.
Right to object: You have the right to object to certain types of processing, for reasons relating to your particular situation, at any time, insofar as such processing has taken place for the purposes of legitimate interests pursued by LOCKSELF.
We will be allowed to continue processing your personal data if we can demonstrate that the processing is justified by freedoms or if we need it for the establishment, exercise or defense of legal claims.
Right to withdraw consent: Right to provide LOCKSELF with instructions on the use of your personal data after your death.
Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time.
The data subject is informed that the withdrawal does not affect the lawfulness of the processing that took place prior to the withdrawal.
You can contact LOCKSELF to provide advance directives on the fate of personal data after your death.
To find out more about your rights, please visit the CNIL website(http://www.cnil.fr/fr/comprendre-vos-droits).
If you wish to exercise your rights, you may be asked to provide proof of identity, in particular to ensure the security of the processing operation to which the request relates.
A reply will be sent to you, depending on the complexity of your request within the time limits prescribed by Article 12.3 of the RGPD.
For any complaint to the Commission Nationale Informatique et Libertés (CNIL), you can write to the following address: CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris cedex 07.
Article 8 - Protection of your personal data
LOCKSELF ensures that data is treated with the utmost security and confidentiality, including when certain operations are carried out by subcontractors.
To this end, we implement appropriate technical and organizational measures to prevent the loss, misuse, alteration or deletion of your personal data.
These measures are adapted to the level of sensitivity of the data processed and the level of risk presented by the processing or its implementation.
In the event of a breach in the security of your personal data, we will inform you within the time limits and according to the procedures specified by the legal and regulatory provisions in force.
Article 9 - Exercising your rights
To exercise your rights, LOCKSELF's Data Protection Officer (DPO) is at your disposal at the e-mail address dpo@lockself.com or at the postal address DPO - LockSelf - 22 avenue chevreul, 92600 Asnières-sur-seine.
LOCKSELF has, in accordance with Article 12 of the RGPD, one month to respond to your request. This period may be extended by two months, taking into account the complexity and number of requests.