Who is responsible for processing?
What personal data is processed?
How long is your data stored?
How secure is your data?
Who can access your data?
Does Lex Persona transfer data
to a country outside the European Union?
What are the rights of the people concerned?
Has Lex Persona appointed a Data Protection Officer?
How can I contact the national data protection authority?
Privacy policy
Preamble
As a trusted third party, Lex Persona ("we" or "us") is committed to the respect and protection of personal data. Consequently, compliance with the regulations applicable to the Processing of Personal Data is paramount. The reference texts are EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the "GDPR", and amended Law no. 78-17 of January 6, 1978, relating to information technology, files and freedoms.
The persons concerned by this policy (hereinafter referred to as "you") are varied, they may be visitors and users of one of our websites or our products and services.
The websites concerned are :
- / https://extranet.lex-persona.com
- / https://support.lex-persona.com
- / https://www-test.lex-persona.com
The concepts used in this policy are defined in Article 4 of the GDPR, in particular the concepts of "processing", "personal data" or "personal data", "data subjects", "controller" and "processor".
Who is responsible for processing?
Lex Persona acts as Data Controller for all processing relating to visits to and use of the websites, as well as for direct marketing and customer relationship management.
Lex Persona may also act as a subcontractor when using one of our products or services. As our customers are responsible for data processing, we act as a service provider under their instructions. As such, we are committed to assisting our customers in their efforts to bring their data processing into compliance.
What personal data is processed?
Lex Persona only processes your personal data in accordance with applicable laws. This data is collected either during your visit to one of our Sites or in the course of your exchanges with our technical, commercial or administrative staff.
If you have created and registered your profile on one of our Sites, you have been invited to consult this policy before accessing our Services or displaying our content. The data you provide :
The data you provide :
- / The title of civility,
- / First and last name,
- / Email address,
- / Telephone number(s),
- / Login and password,
- / Personal address,
- / The company,
- / Service,
- / Job title
This data is communicated when you register on one of our websites, send a contact request or subscribe to our newsletters.
Information collected automatically :
We automatically record information about you, your computer or your mobile device when you access one of our Sites. This is referred to as browsing data:
- / Your public IP address,
- / The operating system version of your computer or mobile device,
- / Your browser type and language
- / The pages of our Sites that you have visited.
| Processed data | Legal basis | Purpose(s) of processing |
|---|---|---|
| Identification and contact data |
Legitimate interest Consent Contract between the Customer and Lex Persona Contract between the Customer and Lex Persona Legitimate interest |
Legitimate interest Newsletter registration; information on our offers and determination of the offer best suited to your situation Manage commercial relations and/or provide the subscribed service Support service management Enable the Site to function properly and be secure; produce technical message logs, statistics and reports |
| Navigation data | Legitimate interest | Enable the Site to function properly and be secure; produce technical message logs, statistics and reports |
How long is your data stored?
The length of time personal data is kept varies according to the purpose of the processing. Lex Persona undertakes not to retain personal data beyond the period required for processing.
| Processed data | Purpose(s) of processing | Data retention period |
|---|---|---|
| Identification and contact data |
Creating a user profile Newsletter subscription Personalized information about our offers Customer relationship management Support service management |
5 years from last activity 3 years from the date of collection or last contact with the prospect 3 years from the date of collection or last contact with the prospect 5 years from last activity 1 year from last activity |
| Navigation data |
1 year from last activity Produce technical message logs, statistics and reports |
6 months (french CNIL recommendation) 6 months (french CNIL recommendation) |
Who can access your data?
Access to personal data is restricted to certain employees who are aware of the principle of data confidentiality.
Personal data processed by Lex Persona is neither rented nor sold to third parties. Some data is shared with Lex Persona service providers duly selected for their compliance with the GDPR, only the data necessary to provide the service is communicated to the service providers.
| Activity requiring the intervention of a subcontractor | Personal data provided | Company name of subcontractor |
|---|---|---|
| Prospect, Partner and Customer Management (CRM) | Last name, first name, company, position, e-mail address, telephone number | Zoho |
| Support service management | Support service management | Zoho |
As far as Zoho is concerned, no data is transferred to the parent company in India; data is hosted in the Netherlands.
In accordance with its legal obligations, Lex Persona may be required to disclose personal data at the request of public or government authorities.
Does Lex Persona transfer data to a country outside the European Union?
Any contract with a company located outside the European Union or in a country not subject to an adequacy decision by the European Commission, includes standard contractual clauses.
What are the rights of the people concerned?
You have the right to access your data at any time. When Lex Persona acts as Data Controller, you may exercise your rights directly with Lex Persona's DPO:
- / E-mail address: dpo@lex-persona.com
- / Postal address: 9 Av Maréchal Leclerc - 10120 ST ANDRÉ LES VERGERS - FRANCE
Right of access. You have the right to know what data is processed within the company, and to have it communicated to you in a comprehensible format.
Right to object. This allows you to object to your data being used for a specific purpose. It is necessary to present "reasons relating to your particular situation", except in the case of commercial prospecting.
Right of rectification. This allows you to avoid using or circulating incorrect data about yourself by correcting it.
Right to erasure. In accordance with the GDPR and french CNIL recommendations, at least one of the following conditions must be met in order to exercise the right to erasure of data:
- / Your data is used for prospecting purposes
- / Your data is no longer necessary for the purposes for which it was originally processed.
- / You withdraw your consent to the use of your data
- / Your data is processed unlawfully
- / Your data must be deleted to comply with a legal obligation
- / You have objected to the processing of your data and the data controller has no legitimate or compelling reason to retain the data
Right to restriction. This consists in asking an organization to temporarily freeze the use of some of your data.
Right to portability. This allows you to recover part of your data in a machine-readable format.
When you are an external signatory, Lex Persona acts as a subcontractor. Consequently, requests to exercise rights must be made to the organization that uses our services as part of your electronic signature procedure. Lex Persona undertakes to assist the Customer in the exercise of his rights.
Where the processing of your data is based on your consent, it may be withdrawn by writing to Lex Persona by e-mail (dpo@lex-persona.com) or by post (9 Av Maréchal Leclerc -10120 ST ANDRÉ LES VERGERS - France), stating your surname, first name, e-mail address and address (if applicable your Customer references), as well as the precise purpose of your request for withdrawal.
How can I contact the national data protection authority?
If, after contacting us, you feel that your rights under the Data Protection Act have not been respected, you may submit a complaint to the CNIL.
Website: https://www.cnil.fr/fr/plaintes
Updating this policy
Please note that this privacy policy may be amended or supplemented at any time by Lex Persona, in particular in order to comply with any changes in legislation, regulations, case law or technology. In such a case, the date of the update will be clearly identified at the top of this policy. Such modifications are binding on the person concerned as soon as they are put online. It is therefore advisable to consult this policy regularly in order to take note of any changes.