Activity of Global Mobility Management
Article 1 – Definitions
- “Personal Data”: any data which enables the direct or indirect identification a private individual;
- “Executive Relocations”: simplified joint stock company incorporated under French law, with a share capital of 671 644,00 Euros, and head office at 9 rue Thomas Edison, 92230 Gennevilliers France, registered at the Trade and Companies Registry of Nanterre under number SIREN 378 473 532 RCS NANTERRE;
- “Website”: website operated by Executive Relocations which can be accessed at: https://www.executive-relocations.com ;
- “Client Account”: personal account of the Customer, which can be accessed from the Website by clicking on the “client access” tab or directly at: https://www.irise.info
- “User”: any individual who accesses the Website and/or uses its features;
- “Contract”: contract for the provision of services signed with Executive Relocations with the purpose of performing support services for geographic mobility (services of relocation, immigration, removal management or mobility administrative and financial management);
- “Client”: any individual who has signed a Contract with Executive Relocations;
- “Prospect”: any individual potentially interested by the provision of services proposed by Executive Relocations but who is not a Client of Executive Relocations.
Article 3 – Personal Data collected
3.1. Personal Data supplied by Users, Prospects and Clients
1. By means of forms which can be accessed on the Website
The Personal Data collected by Executive Relocations on its Website are those voluntarily supplied by the User to contact Executive Relocations, to send a spontaneous application or in reply to a job offer published on the Website, to subscribe to Executive Relocations’ newsletter, or to test online their eligibility for the “Mobili-Pass”.
Personal Data is thus:
- If need be, to be contacted by Executive Relocations: User’s contact details (name, first name, email address, telephone number (landline and/or mobile); User’s role and legal name of the company; any personal data communicated in the free text sections by the User to contact Executive Relocations;
- If need be, to spontaneously apply or reply to a job offer published on the Website: User’s contact details (name, first name, email address); any data contained and communicated in their CV; level of English (beginner, intermediate, fluent or bilingual); any personal data communicated in the free text sections by the User to answer the questions “How do you match this position?” and “What attracts you in your profession?”;
- If need be, to test online their eligibility for the “Mobili-Pass”: the answers to the questions asked including in particular professional mobility status, type of good wanted, distance between the old and the new residence, taxable income below the PLI resources ceiling;
- If need be, to subscribe to Executive Relocations’ newsletter: the User’s email address.
The Personal Data indicated by an asterisk at the time of collection must be communicated to Executive Relocations. Failing to supply such Personal Data, Executive Relocations will not be in a position to contact Users, who have requested so, nor to reply to Users’ online applications, nor to test their eligibility for the “Mobili-Pass”, nor to send them the requested newsletter.
2. Outside the scope of the forms which can be accessed on the Website and/or through the Client Account
In order to prepare detailed estimates or mission statements for the various services of geographic mobility support proposed by Executive Relocations (services of relocation, immigration, removal management, mobility administrative and financial management) and then, if applicable, in order to conclude, perform and follow up on signed Contracts, Executive Relocations shall collect additional Personal Data and, if applicable, depending on the services:
- The full contact details of the User, Prospect of Client and, if applicable, those of their spouse and children: name, maiden name, first name, postal address, telephone number (landline and/or mobile, personal and/or professional), email addresses (source, professional, personal);
- The data required for the creation of a Client Account: legal name, corporate name, name and first name of the contact person, email address, telephone number, and postal address;
- Data related to the identification of the Client to access their Client Account: identifier, password;
- Data related to the Contract: transaction number, service(s) bought, amount, period, Client relation history, correspondence with Clients and customer service, communication and comments of Clients;
- Data related to invoice payments: entity invoicing, invoicing address(es), payment methods, discounts applied, receipts, sales and non-payments.
- If need be, in order to prepare estimates, data relative to the User or Prospect’s geographic mobility (which may vary depending on the services desired): arrival address and departure address; mobility expected date, mobility reason (professional transfer or not), needs arising from their mobility; professional address; employer’s name and contact details, transfer conditions: local contract, expatriation, country of origin and expatriation, conditions of expatriation and remuneration, services desired, budget allowed, real estate preferences, type of lease considered: individual or company lease, guarantees and guarantors available,
- If need be, in the event a Contract is signed, additional data related to the Client and, if applicable, related to their spouse and children (which may vary depending on the services desired and the countries concerned): language, date, place of birth and nationality, passport of identity document number, copy of passport or identity document, passport expiry date, if need be children education level, family circumstances (single, married, civil union, married life, divorced, separated, widower), work permit and/or visa to entry the territory, identity photos, social security number, copy of driver’s licence, transfer certificate, rent receipts, salary and associated allowances, pay slips, employment contract, income tax notice, bank references (BBAN), bills related to accommodation: electricity, gas, water, telephone, etc., comprehensive house insurance certificate, housing lease or sale agreement, state of entry and exit, vehicle registration number, signing authority, detailed inventory of the goods to be moved and their value; photos of the goods to be moved; SIREN number; Client’s K-bis and information on managers and shareholders.
Personal Data indicated by an asterisk or indicated as compulsory by Executive Relocations at the time of collection must be provided to Executive Relocations. Failing to supply such Personal Data, Executive Relocations shall not be in a position to prepare detailed estimates or mission statements and if applicable perform the Contracts signed and ensure their monitoring.
3.2. Personal Data arising from cookies
User’s Personal Data is also collected by means of cookies present on the medium used by the User (laptop, tablet, mobile phone, smart phone) when they access the Website, subject to their consent which they can modify at any time.
Cookies are small volumes of information stored by the web browser on the medium used by the User (laptop, tablet, mobile phone, smart phone). Cookies can be permanent or temporary. Permanent cookies are stored on the User’s device for a period not exceeding thirteen (13) months. Temporary cookies disappear at the end of each browsing session.
Cookies used on the Website have several purposes:
3.2.1. Cookies used on the Website
(i) The following are cookies which do not require the User’s prior consent:
- Strictly necessary cookies: These cookies do not store any information allowing to identify the User. These cookies are however essential to browse the Website and use its features. These cookies are generally only defined in response to actions requested by the User, related to service requests, such as configuring the User’s privacy preferences, the connection and filling in forms. Authentication and security cookies are for example used to identify and recognise registered Users and to grant them access to the content or features requested.
- Feature cookies: These cookies facilitate the Website’s functionality as well as the use of all the Website’s features and the supply of improved and personalised features namely by memorising connection data (IP address), User preferences, etc. These cookies are defined by Executive Relocations or by its third-party suppliers whose services have been added to its pages by Executive Relocations. For example, these cookies allow to display the Website in English or in French depending on the language of the browser used by the User.
Although the presence of these cookies does not require the User’s prior consent, the User may, at any time, configure its browser to block them or be advised of their presence (see point 3.2.2.i)
However, by deleting these cookies, the User risks not being able to access the Website anymore, nor use its features.
Executive Relocations accepts no responsibility for consequences linked to the Website’s degraded functionality resulting from Executive Relocations not being able to register or consult these cookies.
(ii) Cookies subject to the User’s prior consent are analysis and performance cookies. These cookies enable the Website’s monitoring, and the creation of Website audience statistics in order to improve functionality, namely by determining number of visitors, pages most consulted, User connection duration, type of browser used, pages from which the User accessed the Website, search engines used to access it, geographical location from which the User accessed the Website. All the information collected by these cookies is aggregated and is thus anonymous.
Executive Relocations obtains the User’s consent before these cookies are placed.
The User may at any time withdraw its consent for placing these cookies and configure its browser to block them or be advised of their presence (see point 3.2.2.) Blocking these cookies does not impact the Website’s features. However, deactivating them will prevent the collection of information related to the User’s browsing of the Website and thus the proposal of adapted content.
3.2.2. Users’ choice concerning cookies
(i) Refusing all cookies or only the cookies which placing is subject to the User’s prior consent by means of the User’s browser software
The User may configure its browser software so that cookies are registered or, to the contrary, are rejected, either systematically or depending on the issuer.
The User may also configure its browser software so that the acceptance or rejection of cookies is occasionally proposed to them, before a cookie can be registered.
The User may at any time modify the configuration of its browser to accept or reject all or part of the cookies, and block or delete cookies which have been placed on its browser.
The configuration of each browser is different when it comes to cookies management. It is described in the help menu of User’s browser, which will enable them to know how to modify their preferences in terms of cookies:
- For Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
- For Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
- For Chrome™:http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
- For Firefox™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
The User may also consult the Website of the National Commission for Information Technology and Liberties (Commission Nationale de l’Informatique et des Libertés) (hereinafter the “CNIL”) in order to obtain the configuration instructions for the most used browsers at the following address: http://www.cnil.fr/vos-droits/vos-traces/les-cookies/conseils-aux-internautes/ or consult the “Help” section of the browser they use.
In this way, the User has the option to block all cookies or to only block cookies which placing is subject to their prior consent with the consequences that such blocking can generate, as has been clearly set out.
(ii) Only reject the cookies which placing is subject to the User’s prior consent by using a deactivation link
The User may click on the following deactivation link: Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=fr
Article 4 – Personal Data Processing
4.1. Personal Data Controller
Executive Relocations is the Data Controller for the Personal Data of Users, Prospects and Clients.
4.2. Personal Data protection officer
- email address: firstname.lastname@example.org
- telephone number: + 33 (0)1 81 92 10 67
- postal address: 9 rue Thomas Edison – 92230 Gennevilliers – France
4.3. Purposes of processing
The Personal Data of Users, Prospects and Clients are processed by Executive Relocations for its business needs, depending on the services concerned, and which are: contact Users and Prospects who have requested so on the Website; process applications, spontaneous or in reply to a job offer, sent by Users; test online the User’s eligibility for the “Mobili-Pass”; send newsletters to Users, Prospects and Clients who have subscribed to them; process quote requests from Users and Prospects, send the quotes, contact Users and Prospects after the quotation process; reply to questions and claims of Users, Prospects and Clients and provide Clients with customer service; perform Contracts, including in particular geographic mobility support (services of relocation, immigration, removal coordination and mobility administrative and financial management);inform Clients of the progress status of services contractually entrusted to Executive Relocations; create and manage Client Accounts: Personal Data will be used to identify the Client and allow them to access certain features of the Client Account, namely monitoring of the progress status of services entrusted; receive Client payments; manage Client non-payments and disputes; carry out operations related to prospection, such as contacting Users, Prospects and Clients to propose commercial offers and news; conduct satisfaction surveys; organise promotional campaigns; analyse the Personal Data of Users, Prospects and Clients to provide relevant commercial offers and information; test and improve the Website and services proposed; manage requests for access, rectification, deletion, opposition, limitation and portability of the Personal Data of Clients, Prospects and Users; verify the information communicated by Clients, Prospects and Users.
4.4. Business development
Failing the prior express consent of the User, and Prospect, Executive Relocations undertakes not to use their Personal Data for purposes of business development, namely sending promotional messages, news, newsletter subscription, or any information operation.
Executive Relocations informs the Client of the use of their Personal Data in order to send them business development messages concerning services similar to those supplied by Executive Relocations. In all other cases, Executive Relocations undertakes to obtain the prior express consent of the Client.
The User, Prospect and Client may at any time oppose or withdraw their consent to receive business development messages by clicking on a deletion link mentioned in the electronic business development messages sent to them, or by modifying the Client Account configurations.
4.5. Legal bases of Data Processing
The processing of Personal Data is necessary for the performance of the Contract and / or pre-contractual measures taken at the request of the Customer or the User (request for quotation, sending of application, etc.).
The processing of Personal Data for purposes of commercial prospecting is based on the prior and express consent of the User, the Client and the Prospect. When the commercial prospecting concerns services similar to those already provided to the Customer, the processing of his Personal Data is based on the legitimate interest of Executive Relocations to develop its commercial relations with its Customers.
Finally, the processing of Personal Data with specific purposes such as conducting satisfaction surveys, analysis of Personal Data to provide commercial offers and relevant information, testing and improvement of the Site, is based on the legitimate interest of Executive Relocations to develop and monitor its commercial relations with Customers, Users and Prospects.
4.6. Recipients of the Personal Data
The Personal Data of the Users, Prospects and Clients collected by Executive Relocations is intended for the authorised personnel of the customer service, marketing, recruitment, human and/or commercial resources of Executive Relocations, as well as for the authorised personnel of the subcontractors Executive Relocations hires and who need to access the Personal Data to carry out their tasks, namely transport provider, I.T. provider, technical provider, payment services provider, identity verification provider, analytical solutions supplier and collection and credit agencies.
The Personal Data of Clients may also be transmitted to the AXA Enterprises insurance company, Executive Relocations’ partner, in case the Client takes out the insurance policy proposed by Executive Relocations.
If need be, for the purposes of performing the Contract, depending on the services entrusted to Executive Relocations, the Client’s Personal Data may furthermore be transmitted to the following external authorities: CPAM, social security centres, police headquarters and sub-prefectures, real estate agencies, joint ownership managers, homeowner associations, private owners, insurance companies, utilities providers: electricity, gas, water, etc., Social security for French citizens living abroad, International Centre for Studies in Education (CIEP), police stations, Centre for the reception of foreigners, schools universities, National Old Age Pension Fund (CNAV), Family allowance fund (CAF), Business France, authorised customs agents, Customs legislation directorate, Customs Directorate, collectors of customs, customs officers, Relevant ministries for protected exportations, shipping companies, air and/or land transport companies who carry out removals, Directorate General of Customs and Excise (DGDDI), Action Logement Group and its subsidiaries.
Executive Relocations undertakes not to disclose the Personal Data of Clients, Prospects and Users to any other third party, except with the explicit and prior consent of the Client, Prospect and/or User, or under the circumstances set out below:
- Executive Relocations may need, as a legal result, within the framework of legal proceedings, disputes and/or any claim against it, to disclose the Personal Data of the Client, Prospect or User:
- Executive Relocations may also disclose that Personal Data if it deems the disclosure necessary or appropriate for purposes of national security, law enforcement or any other matter of public interest;
- Executive Relocations may also disclose Personal Data if it deems the disclosure to be reasonably necessary to assert the fulfilment of this clause or to protect its activities or the Client or User or Prospect;
- In case of restructuring, Executive Relocations may legitimately transfer all the Personal Data to its assignee.
4.7. Duration of Personal Data retention
The Personal Data of the Client is retained for the full duration of the performance of the Contract for its good implementation by Executive Relocations and its potential subcontractors.
The Personal Data of the Client which evidences the Contract is retained for a period of five (5) years from the end of the performance of the service, subject matter of the Contract.
The Personal Data of the Client collected in the process of taking out insurance is retained for the duration of the insurance contract taken out, and the duration necessary to manage a claim, if applicable.
Personal Data related to the Client Account is retained for a period of three (3) years from the last Client activity on its Client Account. At the end of this period, the Client shall be deemed inactive and its Client Account shall be automatically deactivated.
The Personal Data of the Client allowing Executive Relocations to fulfil its accounting obligations is retained for a period of ten (10) years from the end of the financial year concerned.
The Personal Data of the Client used for purposes of prospection is retained for a period of three (3) years from the end of the contractual relationship.
The Personal Data of Prospects and Users who have not signed a Contract with Executive Relocations, and are used for purposes of prospection, is retained for a duration of three (3) years from their collection on the Website. At the end of this period of three (3) years, Executive Relocations may contact the User and Prospect again in order to know whether they wish to continue to receive commercial offers.
Personal Data collected by means of cookies is retained for a period of thirteen (13) months from their collection on the Website.
In case an application has a negative outcome, Executive Relocations may inform the User of its wish to retain their file, in order to give them the opportunity to request the destruction of the same. If the User does not request the destruction of its file, its Personal Data is automatically destructed two (2) years after the last contact with the User. After the durations required in terms of the purposes for which they are processed, Executive Relocations undertakes to destroy and anonymise the Personal Data of Clients, Prospects and Users.
Article 5 – Rights of the User, Prospect and Client
The legislation in the area of personal data protection grants the User, Prospect and Client the various rights described below.
The right of access allows the User, Prospect and Client to permanently access their Personal Data.
The right of rectification allows the User, Prospect and Client to update their incorrect or incomplete data.
The right of opposition allows the User, Prospect and Client to oppose, for legitimate reasons, that their data be processed.
The right to limitation allows the User, Prospect and Client to restrict the processing of their Personal Data for a restricted list of cases under the law in force.
The right to data portability allows the User, Prospect and Client to receive Personal Data concerning them and which they supplied to Executive Relocations, and to transmit them to another data controller, under the conditions provided by the law in force.
The right to data deletion allows the User, Prospect and Client to obtain the deletion of their Personal Data for a restricted list of cases under the law in force.
The User, Prospect and Client may at any moment withdraw their consent for the processing of the Personal Data by Executive Relocations.
Furthermore, the User, Prospect and Client also have the right to anticipate the fate of their Personal Data after their death, by setting guidelines (general or special) regarding the retention, deletion or communication of their Personal Data after their death.
The User, Prospect and Client are advised that they may freely designate a person responsible for the execution of their guidelines and that they may modify or revoke their guidelines at any time.
The User, Prospect and Client have the possibility to exercise their rights of access, rectification, deletion, opposition, limitation, portability, of defining guidelines regarding the retention, deletion or communication of their Personal Data after their death, and of expressing their wish to withdraw their consent for the processing of their Personal Data by contacting Executive Relocations at the following contact details:
- By post : EXECUTIVE RELOCATIONS
For the attention of the Data Protection Officer
9 rue Thomas Edison – 92230 Gennevilliers – France
- By email: email@example.com
Or from their Client Account
Executive Relocations shall endeavour to respond to inquiries from Clients, Prospects and Users with a reasonable period of time and, in any event, within the periods set out by the regulation in force.
Executive Relocations shall take all useful precautions to verify the identity of the individual the request originates from, before accessing, if applicable, their request, in order to avoid the risk of abusive requests.
The User, Prospect and Client also have the right to submit a claim to the CNIL and to bring an action against Executive Relocations through the relevant courts if they find that Executive Relocations has infringed their rights relating to personal data. In the event that an infringement is found, the User, Prospect and Client may claim full compensation of the harm suffered.
Finally, the User, Prospect and Client have the right not to be the subject of a decision based solely on automated processing, including profiling, which results in legal effects concerning or affecting them significantly in a similar manner.
Article 6 – Personal Data Security
6.1. Security and confidentiality measures
Executive Relocations shall make its best efforts by taking all appropriate measures to ensure the security and confidentiality of the Personal Data of Users, Prospects and Clients and avoid that it is damaged or deformed or that non-authorised third parties access it and use them abusively. A Client who considers that its Client Account has been the object of abusive use, must contact without delay Executive Relocations at the following address: firstname.lastname@example.org
Executive Relocations implements technical and organisational measures in order to ensure the appropriate security of the Personal Data of Clients, Prospects and Users, namely: management and control of Personal Data access; installation of a network surveillance software for Executive Relocations ; use of Firewall materials for the protection of ER’s computer networks; installation and use of antivirus and firewalls; back up and encryption of Personal Data; server access restricted by an identifier and password and a virtual private network (secured VPN); regular assessment of the integrity of protection tools; encryption of computer communications with Executive Relocations’ partners; protection of current physical documents; storage of old physical files in an secure archiving warehouse; monitoring and renewal of our ISO 270001 certification.
6.2. Transfer of Personal Data outside the European Union