The General Data Protection Regulation (GDPR) entered into force on May 25th, 2018 and complements legislation on the protection of personal data.
For your information, a personal data corresponds to any information relating to an identified natural person or that can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to it (surname, first name, address, e-mail, telephone, contract number, CB number, ...).
Personal data processing refers to any operation on this type of data (collection, storage, transmission, deletion, etc.) whether on paper or computer. The controller is the person who determines the purposes of each processing and the means to achieve those purposes.
Therefore, we invite you to consult our Policy regularly, accessible from all pages of the Site, in order to keep you informed of the latest applicable online version. For changes that we consider to be the most significant, a notification will be made on the Site. We also invite you to check the date indicated on this Policy to know the date of the last update.
1. Why does JULIABAM-STM B.V. need to collect your data?
2. What data does JULIABAM-STM B.V. collect?
3. What is the legal basis for processing your data?
4. How long is your data kept?
5. What are your rights and how do you exercise them?
5.1. Your rights to your data
5.2. Exercising your rights
6. With whom does JULIABAM-STM B.V. share your data?
7. How does JULIABAM-STM B.V. secure the processing of your data?
8. Mandatory Fields
9. Cookies Policy
10. Privacy by Design/by Default
1. Why does JULIABAM-STM B.V. need to collect your data? The data that JULIABAM-STM B.V. collects are necessary to enable it to meet the following purposes:
• Respond to requests received via the contact form, • Monitoring your navigation on the site, • Manage business relationships, • Manage payment requests website and agencies, • Offer you commercial offers, • Perform customer management operations related to contracts, order processing, deliveries, invoices, accounting, and in particular customer account management; • Commercial prospecting and marketing (sending of advertising messages (SMS or email)); • Conducting customer studies including survey, trade statistics; • Updating its prospecting files for the management of the opposition list to telephone canvassing; • Management of requests for access, rectification and opposition rights; • Managing people’s opinions about products, services or content. For Supplier Partner data, • Supplier file management: perform administrative operations related to contracts; orders; deliveries and invoices, accounting for the management of supplier accounts; • Maintain supplier documentation. With regard to candidate data, • Management of applications. Generally speaking, JULIABAM-STM B.V. does not process any of your data for purposes incompatible with those for which it was collected, unless you have given your prior consent.
4. How long is your data kept? Your data are kept by the Company JULIABAM-STM B.V. for the time necessary to achieve the purposes referred to in point 1 hereof, plus the statutory limitation periods. In terms of cookies . JULIABAM-STM B.V. may keep the data for 13 months. In terms of commercial management and business development. JULIABAM-STM B.V. may keep the data for 3 years from the last contact with JULIABAM-STM B.V. and you. (Simplified Standard n°48) In terms of invoicing . The Company JULIABAM-STM B.V. may keep the data for 10 years (Art L123-22 paragraph 2 of C.COM. Simplified standard n°48) When it comes to accounting. The Company JULIABAM-STM B.V. may keep the data for 10 years (Art L123-22 paragraph 2 of C.COM. Simplified standard n°48) For more information on the retention periods of your data, you can contact the DPO of JULIABAM-STM B.V. : email@example.com. 5. What are your rights and how do you exercise them? 1. Your rights to your data Right of access to your data You may obtain confirmation from JULIABAM-STM B.V. that your data are or are not processed and, where they are, access to all data and information held by JULIABAM-STM B.V. Right to rectification of your data You can obtain from the Company JULIABAM-STM B.V., as soon as possible, the rectification of data concerning you which would be inaccurate or erroneous. You can also request that your data be completed, if necessary. Right to erasure of your data Unless there are legal exceptions, you may request that JULIABAM-STM B.V. delete your data as soon as possible, if in particular, you feel that the processing carried out by JULIABAM-STM B.V. on your data is no longer necessary in view of the purposes for which it was collected.
Right to data portability You can retrieve part of your data in an open and machine-readable format or ask JULIABAM-STM B.V.to transmit it to another organization. Only the data that you have provided actively and consciously to JULIABAM-STM B.V. are concerned by this right (for example, the data that you have entered in an online form) or data generated during the use of a service or device in connection with the conclusion or management of your contract, which is processed automatically, on the basis of consent or the performance of a contract. Right of opposition
If your data is processed for prospecting purposes, you may object to it at any time (See section 5.2 of this Policy). Similarly, you may object to the distribution of targeted advertising (Cookies). Right to limit the processing of your data You can ask JULIABAM-STM B.V.to keep your data without being able to use it, in one of the following cases:
You dispute the accuracy of the data used by JULIABAM-STM B.V.,
You object to the processing of your data,
In case of illicit use but you oppose their erasure,
You need it for the recognition, exercise or defense of rights in court.
2. Exercising your rights
To exercise your rights, you can go to this page : https://privacyportal-de.onetrust.com/webform/4fe2eaf0-48b2-46ba-a637-860caa064c34/707de958-6fb7-43da-bae4-8d2f614278e0?Site=Europcar%20SXM&Source=www.europcar-sxm.com
To exercise one of your rights, you can also send your request to: firstname.lastname@example.org or JULIABAM-STM B.V. Airport Road #122 – Simpson Bay – Sint Maarten - specifying “JULIABAM-STM B.V.- For the attention of the DPO. Any request must specify, in subject matter, the reason for the request (exercise of the right of access, opposition, etc.) and the company concerned by the request. The application must also be accompanied by a double-sided copy of a valid piece of identification bearing the applicant’s signature and the address to which the reply must be sent. The Company JULIABAM-STM B.V. will send you its reply within a maximum of one month, from the date of receipt of your request. However, this period may be extended to two months due to the complexity and number of requests. If you feel, after having contacted the Company JULIABAM-STM B.V., that your IT rights and Freedoms are not respected, you can address a complaint to the CNIL. Prospecting and targeted advertising Once you have agreed to receive commercial offers from JULIABAM-STM B.V., you may, at any time, respond to STOP. In general, for any question relating to this data protection policy or for any request relating to the management of your personal data by JULIABAM-STM B.V., you can send your request by email or mail, as indicated above.
6. With whom does JULIABAM-STM B.V.share your data? The JULIABAM-STM B.V. Company may also transmit your data to the following entities where this is necessary to meet one of the purposes referred to in point 1 of this Agreement: Regarding the collection of payment information your data can be transmitted: • Paybox (Payment on the website)
7. How does JULIABAM-STM B.V. secure the processing of your data? JULIABAM-STM B.V. implements all technical, physical and organizational measures to ensure the security and confidentiality of your data during the collection, processing and transfer of your data. JULIABAM-STM B.V. Company’s infrastructures are protected against malware (viruses, spyware, etc.); the security of your terminal is your responsibility. In the event that we may use service providers to process part of your data, we undertake to verify that they provide sufficient guarantees to ensure the protection of personal data entrusted to them and to have them sign confidentiality clauses in accordance with Article 28 of the GDPR. In the event of a breach of personal data, that is to say in the event of a security incident, whether malicious or not and occurring intentionally or unintentionally, resulting in a compromise of integrity, the confidentiality or availability of your personal data, we undertake to comply with the following obligations: FOR YOU, DATA BREACH CREATES NO RISK A RISK A HIGH RISK Internal documentation in the “Violation Register” X X X We inform you as soon as possible - - X The “Violation Register” contains the following:
The nature of the violation;
The categories and approximate number of people involved;
The categories and approximate number of files involved;
The likely consequences of the violation;
The measures taken to remedy the violation and, if necessary, to limit the negative consequences of the violation;
If applicable, the justification for the lack of notification to the CNIL or information to the persons concerned.
However, and in accordance with the regulations in force, we are not required to inform you of a violation in the following cases:
Your personal data is protected by measures that make it incomprehensible to anyone who is not authorised to access it;
Steps have been taken to ensure that the risk is no longer likely to materialize;
This communication requires disproportionate efforts on our part, including not having any contact information to inform you. 8. 9. Mandatory Fields The fields indicated by an asterisk in our forms are mandatory. The consequences in case of failure to respond are only the lack of consideration of your request. The obligation to provide the requested data is contractual, as it is necessary for the performance of the contract to which you are a party or for pre-contractual measures carried out at your request, in particular in the event of a request for information or quotation concerning our products and services. 9. Cookies Policy See Cookies Policy 10. Privacy by Design/by Default We undertake to integrate the protection of personal data from the conception of a project, a service or any other tool related to the handling of personal data, in particular the minimization of personal data, limitation of the purposes of data collection, respect for the integrity and confidentiality of data, limitation of retention periods.
11. Accountability In order to respect the principle of Accountability, our company:
Adopts internal procedures to ensure compliance with the Regulation (IT Charter, Personal Data Protection Charter);
Keeps a record of any processing carried out under its responsibility or that of the subcontractor (maintenance of the processing register, confidentiality agreements for employees and service providers, company security policy, procedures for managing access requests, rectification, opposition...);
Conducts Impact Assessments (IAA) for treatments that pose specific risks with respect to rights and freedoms.
The aim is to provide rich documentation to demonstrate compliance with data protection rules at all times.
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