Personal Data Privacy Policy
Personal Data Privacy Policy
1- Our philosophy
In accordance with European Regulation 2016/679 of 26 April 2016 (hereinafter the "GDPR") and Law No.
78-17 of 6 January 1978 on information technology, files and freedoms (hereinafter the "Data Protection Act"), BDL Capital Management makes strong commitments to data subjects (hereinafter "you", "your" and "yours").
The purpose of this policy is to detail the processing of your personal data carried out by BDL Capital Management, as data controller, from this website: www.bdlcm.com
Indeed, in the context of its collective management, BDL Capital Management collects personal data from visitors to its website www.bdlcm.com.
2- The 6 legal bases provided for by the GDPR
As a reminder, one processing operation corresponds to one purpose, and must therefore be based on a legal basis.
- Consent
- Performance of a contract
- Legal obligation
- Protection of vital interests
- Public interest mission
- Legitimate interest
3- For what reasons is your data processed?
BDL Capital Management collects and processes your data solely to enable you to benefit from all the features of the website. This concerns the processing of your information requests, the conduct of electronic commercial prospecting, and the downloading of content from our website. BDL also processes and collects your data in connection with job postings to which you may apply via the BDL website (www.bdlcm.com) or via dedicated websites (Welcome to the Jungle, LinkedIn, Jobteaser, etc.). However, we are not responsible for the way these websites use your personal data.
BDL Capital Management collects and processes your data through various channels.
This data is collected and processed in order to:
Process information requests, based on the legitimate interests of BDL Capital Management in contacting website visitors. The provision of this data is necessary to respond to the request from the contact form. Consequently, failure to provide this data will prevent the processing of your request, but will not prevent your access to this website.
Conduct electronic commercial prospecting, based on your consent. The provision of this data is necessary to receive commercial offers for goods or services that you have not already purchased. Consequently, failure to provide this data will prevent any reception of commercial offers for goods or services that you have not already purchased, but will not prevent your access to this website.
In accordance with regulations, your prior consent to receive such solicitations is not mandatory and is based on the legitimate interest of BDL Capital Management to develop its commercial relationships and maintain a coherent and relevant commercial relationship in two cases:
- Where they concern similar goods and services already subscribed to;
- Where they are part of a business-to-business commercial approach.
Nevertheless, you are free to object to such prospecting by exercising your right of objection under the conditions detailed in Section VI of this document.
BDL Capital Management works with partner organisations and may transfer your data to them. BDL Capital Management may share your data with its commercial partners, based on your consent. The provision of this data is necessary to allow you to receive commercial offers.
- Enable the downloading of content from this website (articles, white papers, guides...) based on the legitimate interests of BDL Capital Management to distribute its content and enhance its brand image. The provision of this data is necessary to allow you to download our content. Consequently, failure to provide this data will prevent downloading, but will not prevent your access to this website.
- Enable candidates to apply for job postings published by BDL Capital Management. Any personal data that the candidate may transmit (via questionnaires, information requests) is processed in accordance with the provisions of applicable laws and regulations. This data processing is necessary for the execution of pre-contractual measures taken at the request of candidates.
4- What data is processed?
BDL Capital Management collects and processes only the data necessary to provide you with all the features of the website. The data is limited to identification data, data relating to your personal life, data relating to your professional life, economic and financial information, and connection and location data.
BDL Capital Management collects and processes the data you provide, and is also led to collect and process in particular the following data:
- Civil status, identity, identification data
- Contact details (postal address, email address, telephone number, etc.)
- Professional life
- Economic and financial information
- Connection data (IP addresses, event logs, etc.)
5- Who has access to your data?
BDL Capital Management works with service providers and partners to provide you with all the features of the website. These organisations are contractually bound to BDL Capital Management to ensure the security, confidentiality and integrity of your data.
All your information is collected and recorded by BDL Capital Management. The data is accessible only by strictly authorised personnel of BDL Capital Management who have been made aware of personal data protection.
BDL Capital Management works with partner organisations and may transfer your data to them.
As a reminder, BDL Capital Management may transmit data to the competent authorities to follow up on complaints filed against BDL Capital Management and to comply with administrative and judicial proceedings. Any regulated profession authorised to receive the data to satisfy legal and regulatory obligations may also have access to the data, such as in particular auditors, lawyers, or any auditor of a competent authority.
In the event of subcontracting, BDL Capital Management signs an agreement in compliance with the requirements of Article 28 of the GDPR and informs the stakeholders.
6- How long is your data retained?
The data you transmit to BDL Capital Management is retained for a defined and respected period.
- Commercial prospecting management: Up to 3 years from the last contact (form submission, telephone or email exchange, click on a hypertext link in an email, registration for a webinar, downloading a white paper, connection to a personal space on the website, etc.).
- Contact request management: Up to 3 years, must be proportionate to the purpose pursued (having a limited history of requests over time. Beyond this period, deletion or anonymisation)
- Management of content downloads from the website: Up to 3 years, must be proportionate to the purpose pursued (having a limited history of downloads over time. Beyond this period, deletion or anonymisation)
- Client management: 5 years from the redemption or withdrawal of units.
- Recruitment management: 3 years from the last contact with the candidate.
7- What are your rights and how can you exercise them?
We remind you that you have various rights:
- A right to withdraw your consent at any time when the processing of your personal data is based on consent;
- A right to access your personal data and obtain a free copy (except for repeated or excessive requests) as well as to obtain a description of the main characteristics of the processing implemented in relation to your personal data;
- A right to information regarding the collection, processing, and the rights available to you
- A right to rectify your data without undue delay when it is inaccurate, incomplete or outdated;
- A right to erase your personal data without undue delay, under certain conditions (the request must be based on legitimate grounds referred to in Article 18(I) of the GDPR);
- A right to request the restriction of the processing of your data within the limits provided by the regulations;
- A right to request the portability of your personal data when the processing is based on your consent or on the performance of a contract;
- A right not to be subject to an automated individual decision, including profiling or segmentation.
- A right to object, at any time and for legitimate reasons related to your particular situation, to the processing of your data;
- A right to lodge a complaint with the CNIL;
- A right to define specific directives regarding the fate of your data after your death.
For more information, visit the CNIL website.
The GDPR Representative of BDL Capital Management is your contact for any request to exercise your rights. To this end, you may contact them:
➢ By post: BDL Capital Management, 24 rue du Rocher 75008 PARIS
➢ By email: bdlcm-compliance@bdlcm.com
They may request that a copy of an identity document or any other proof of identity be attached to a request if this proves necessary.
If the request is submitted by a person other than you, without proof that the request is legally made on your behalf (for example, on the basis of a power of attorney), the request will be rejected.
In the event that the response provided to a request is not satisfactory, you have the right to lodge a complaint with the CNIL whose contact details can be found at the following website: http://www.cnil.fr.