PRIVACY POLICY


The website available at the following address: https://lesnouveauxbureaux.com/ (hereinafter referred to as the” Site ”) is published by WELLBAW

(LES NOUVEAUX BUREAUX), a general partnership with a share capital of 10,019,800 euros, registered with the Paris Trade and Companies Register, under number 844 587 063 and whose head office is located at 90 Avenue de Wagram in Paris 75017 (hereinafter referred to as the “Company”).


This privacy policy is intended to inform, while browsing the Site, any person using the Site (hereinafter referred to as the” Users ” or the” User ”) WELLBAW's practices concerning the conditions for the collection, use and sharing of information that Users are required to provide as well as their rights.


The Site complies with French and European standards relating to the protection of privacy and personal data and in particular to law No. 78-17 called” Computing and Freedoms” of January 6, 1978 relating to information technology, files and freedoms, amended by Law 2004-801 of August 6, 2004 and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, relating to information technology, files and freedoms, amended by Law 2004-801 of 6 August 2004 and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the” RGPD ” relating to the protection of natural persons with regard to the processing of personal data and to the free movement of such data.

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IMPORTANT: NOTE TO USERS

ANY BROWSING ON THE SITE AFTER THE PUBLICATION OF THIS PRIVACY POLICY IMPLIES UNRESERVED ACCEPTANCE OF IT.

If the User wishes to withdraw their consent to the processing of their data, simply request it directly by email to the following address: info@lesnouveauxbureaux.com

In addition, in the event that this is required by law and/or in certain circumstances, the User's consent will be obtained or a possibility of refusal will be arranged before any data transmission.

Responsible for processing the personal data collected

The person responsible for processing personal data is the manager of the company.

Nature of the data collected

The data collected on the Site as part of the use of the Site is that allowing WELLBAW to identify Users directly or indirectly.

These may include the following categories of data concerning Users:

  • civil status, identity, identification data such as name, first name, email address, telephone number;
  • data relating to professional life such as the position held; and
  • login data such as the IP address and navigation data such as cookies.

The mandatory or optional nature of the personal data collected and the possible consequences of a lack of response are indicated at the time of their collection (s) on the associated forms.

Users who communicate the personal data of a third party must confirm that they have the consent of this third party to the exploitation of the latter's personal data by the Site.

Purpose and legal basis of processing activities

Purpose of the personal data collected

The personal data collected on the Site is used only for and during the execution of services for the following purposes:

  • business relationship management:some text
    • processing and management of User orders;
    • communication with the User;
    • managing registrations for events organized by WELLBAW;
  • sending newsletters;
  • proper functioning and continuous improvement of the Site and its functionalities: some text
    • general administration of the Site;
    • general management of the security of the Site;
  • deposits of cookies and other tracers.


In addition, WELLBAW may use the data to meet, if necessary, its legal and/or regulatory obligations.

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Legal basis for processing activities

The processing activities and the collection of personal data are authorized on the basis of the following legal bases:


  • The execution of contractual obligations, for the management of the commercial relationship;


  • The consent of the User, for:


  • sending newsletters; and


  • the deposit of cookies and other tracers.


The legitimate interest in guaranteeing the best level of functioning and quality of the Site for the proper functioning and continuous improvement of the Site.

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Aggregation with non-personal data


WELLBAW reserves the right to publish, disclose, and use aggregated information (information about Users or about specific groups or categories of Users combined so that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.

Time of collection

The data collected by WELLBAW is freely communicated by Users during the ordering process or registering for the newsletter on the Site.

They may also be collected automatically when using the Site, in particular when the User:

  • navigates the pages of the Site;


  • subscribe to the newsletter; and/or


  • Place an order.
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In any event, the personal data collected:


  • will be obtained and processed fairly and lawfully;


  • will be recorded for specific and legitimate purposes;


  • will be used in accordance with these purposes;


  • are adequate, relevant and not excessive in relation to these purposes; and


  • will be subject to precautions to ensure the security and confidentiality of the data in order to prevent them from being damaged, modified, destroyed or communicated to unauthorized third parties.

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Recipients of personal data


The recipients of the personal data collected on the Site are primarily the company.


Personal data is not communicated to third parties with the exception of WELLBAW partners whose communication of personal data is necessary in order to provide the services offered by the contact manager.


However, the partners undertake to scrupulously respect the provisions of the Data Protection Act, the RGPD as well as the new future provisions.

In addition, other recipients may have access to personal data. Where applicable, these are the resource providers in charge of the Site (administration, sales, marketing, legal, etc.) and external service providers (technical service providers, access providers, communication agencies, etc.).


In the event of a change in control of WELLBAW, a merger transaction, an acquisition, a collective procedure or any other form of asset transfer, the data collected by WELLBAW may be transferred to third parties.

However, WELLBAW is committed to ensuring the confidentiality of the personal data collected and to informing Users before they are transferred or subject to new confidentiality rules.


In the event that this is required by law, the User's consent will be obtained or a possibility of refusal will be arranged before any data transmission.

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User Rights


In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 says the” RGPD ” relating to the protection of natural persons with regard to the processing of personal data and to the free movement of such data and to Law No. 78-17 known as” Computers and Freedoms “of January 6, 1978, amended by law 2004-801 of August 6, 2004 relating to information technology, files and freedoms, the User has:


  • a right of access to their personal data;


  • the right to rectify their personal data;


  • the right to delete and delete their personal data;


  • the right to object to the processing of personal data;


  • a right to limit the processing of its data;


  • a right to the portability of its data, when the data is subject to automated processing based on consent or on a contract;


  • the right to withdraw consent at any time; and


  • the right to define the fate of his data after his death.



Users wishing to exercise one of their rights may send their request by email or post to the following addresses:



  • Postal mail: 90 Avenue de Wagram — 75017 Paris


  • Email: info@lesnouveauxbureaux.com


In the event of exercising one of these rights, the User must send WELLBAW the elements necessary for identification: name, first name, email address and possibly postal address.


In addition, in accordance with the regulations in force, the User's request must be clear and specify in detail the right he wishes to implement as well as the address at which he wishes to receive a response in the event of the implementation of one of the rights listed above. WELLBAW may ask him to provide a photocopy of an identity document bearing his signature in order to be able to verify his identity.


WELLBAW then undertakes to respond within a maximum of one (1) month following receipt of the User's complete request.

Due to the complexity of the request and/or the number of requests, this period may be increased by two (2) months provided that WELLBAW informs the User within one (1) month from the receipt of his request of the reasons for the delay.


WELLBAW informs Users of their right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (hereinafter referred to as the “CNIL”) in one of the ways indicated below:



  • By postal mail:
    National Commission for Information Technology and Freedoms — CNIL
    3 Place de Fontenoy
    TSA 80715 — 75334 PARIS CEDEX 07

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Data retention period

Data retention for the duration of the contractual relationship

The personal data of Users collected is not retained beyond the time necessary for the performance of WELLBAW's obligations defined at the time of the conclusion of the contract or the predefined duration of the contractual relationship, except with regard to the data that WELLBAW would need to keep as evidence, for legal, administrative needs or in accordance with the legislation in force.

Retention of anonymized data beyond the contractual relationship

WELLBAW keeps the personal data of Users collected for the period strictly necessary to achieve the purposes described in this privacy policy.

At the end of the commercial relationship, WELLBAW will keep for three (3) years from
At the end of the commercial relationship the information provided by the User, namely:


  • the first and last name or the corporate name;


  • email addresses; and


  • telephone numbers.


Navigation data will be kept for a maximum of six (6) months in accordance with the recommendations of the CNIL.


Beyond this period, they will be anonymized and kept for exclusively statistical purposes and will not give rise to any exploitation of any kind whatsoever.

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Transfer of personal data abroad


As far as possible, WELLBAW processes User data only within the European Union and does not transfer this data outside this space.


However, in the event of an international transfer of User data outside the European Union, a distinction should be made between:


  • countries that have been the subject of an adequacy decision by the European Commission: in this case, the data is transferred to a country ensuring a level of protection considered sufficient and adequate to the provisions of European data protection regulations; and


  • countries whose level of data protection has not been recognized as adequate: in this case, to ensure a transfer in accordance with European regulations, and in particular to ensure data security, WELLBAW will base its transfer on protection mechanisms adapted to each service provider and subcontractor, such as the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism.

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security

WELLBAW undertakes to implement appropriate and reasonably necessary technical and organizational measures under the regulations applicable to the protection of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage in order to guarantee a level of security adapted to the risks incurred for the rights and freedoms of natural persons in the context of the treatments referred to in this privacy policy.

When personal data is transferred to third parties for processing, WELLBAW ensures that these third parties implement all appropriate technical and organizational measures to ensure the protection of personal data in accordance with applicable laws.


These measures are defined taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the treatment as well as the risks identified.


Depending on the needs, risks, costs and purpose of processing, these measures may include the pseudonymization and encryption of data.


This protection can be ensured by the mention “https” in the browser's URL address as well as by the representation of a closed padlock at the bottom of the screen.


Finally, in the event of a violation of rights concerning personal data likely to generate a high risk for the User's rights and freedoms, WELLBAW undertakes to inform the User of this violation within a maximum of seventy-two (72) hours.

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Links


On the Site, Users may have access to various links directing them to third party sites.


WELLBAW will not be responsible for information that is sent to or collected by these third parties.


This privacy policy does not govern third party sites or third party content accessed by the Site User.


WELLBAW has no control over hypertext links and/or other promotional formats.


Therefore, WELLBAW does not give any guarantee concerning in particular the personal data protection practices of indexed websites and can in no way be held responsible in the context of a dispute arising between a website indexed on the Site and one of the Users, in particular due to losses or damages suffered, in particular due to losses or damages suffered, the operators of the indexed websites being solely responsible for their practice in terms of personal data protection.

Cookies

A cookie (or connection cookie) is a text file that can be saved, in a dedicated space on the hard drive of the User's computer when consulting an online service using their browser software.


In practice, cookies are small text files that are placed on the User's computer by the websites that the User visits. They are used to make websites work and improve the usability of these sites.


The cookie is transmitted by the server of a website to the User's browser. Each cookie is assigned an anonymous identifier. A cookie cannot be traced back to a natural person.


When consulting the Site, Users are informed that cookies or other means of recording navigation data are used by the Site or by third parties, service providers for the Site and placed on the User's terminal (computer, mobile or tablet).


WELLBAW or its partners may install, subject to the acceptance of the User, various cookies and in particular:


  • session cookies, which disappear as soon as the User leaves the Site;


  • permanent cookies, which remain on the User's terminal until the end of their lifespan or until the User deletes them using the functionalities of his browser; and


  • statistical cookies (making it possible to measure the audience of the Site).



Only the sender of a cookie can read or modify the information contained in it.


In application of the recommendations of the CNIL, when connecting to the Site for the first time, the User will be asked to expressly accept the Site's cookies.


Purpose of cookies


The cookies used by WELLBAW or its partners make it possible to identify Users, to recognize their browser when they connect to the Site, to record their access frequencies (traffic measurement) and their preferences for displaying Users' terminals, to adapt and/or personalize the presentation of the Site to adapt and/or personalize the presentation of the Site to improve the User experience and to optimize the Site for the sole purpose of providing the services requested by the User.

In addition, the cookies used on the Site are based on the guide of the International Chamber of Commerce by categories:


  • functional cookies;


  • preference cookies;


  • statistical cookies;


  • marketing cookies.



Functional cookies


Functional cookies are strictly necessary and allow the User to navigate on the Site.


These cookies do not collect any information about the User that could be used for marketing purposes.


WELLBAW uses these cookies to:


  • ensure the functioning of the Site;


  • secure forms and protect them from malicious scripts.


WELLBAW does not use these cookies to:



  • gather information that could be used to promote products or services to Users; or


  • remember the preferences or user name after the visit.

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Preference cookies


These cookies are used to provide services or to remember the User's settings in order to improve their visit to the Site.

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Statistical cookies


These cookies are used for anonymous statistical purposes.


Marketing cookies


These cookies are used to promote products or services for the User on other sites. They can also be used to limit the number of times the User sees a particular advertisement on the Site and to measure the effectiveness of a particular campaign.


WELLBAW uses Google's functionalities in particular, so you will find the privacy and use rules below: Google's Privacy & Terms site


Cookie storage period


In accordance with the recommendations of the CNIL, the maximum duration of storage of cookies is a maximum of thirteen (13) months after their first deposit in the User's terminal, as is the duration of the validity of the User's consent to the use of these cookies. The lifespan of cookies is not extended with each visit. The User's consent must therefore be renewed at the end of this period.

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User's right to refuse cookies


When you first browse the Site, an explanatory banner on the use of cookies appears. It allows the User to activate or deactivate certain cookies. It will only disappear when the User has accepted, or not, accepted the use of cookies to continue browsing.


The registration of a cookie remains subject to the will of the Users. In accordance with legislative and regulatory provisions, WELLBAW collects consent prior to the deposit of cookies.


Users also have the option of configuring their browser software in such a way as to oppose, totally or partially (in particular depending on the sender) the recording of cookies. The configuration also offers the possibility of accepting or refusing cookies from time to time, before they are registered in the Users' terminal.


Therefore, Users who wish to prevent the recording of cookies can follow the procedure specific to each browser and described in the browser's help menu.








However, in the event of opposition to the registration of cookies or the uninstallation of a cookie, Users are informed that some services may no longer function properly.

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Modification of the privacy policy


WELLBAW reserves the right to modify and update this privacy policy at any time, in particular to take into account any legal and/or jurisprudential developments and to meet the requirements of the regulations applicable to the protection of personal data.


The version that prevails is the one that is accessible online on the day the Site is consulted.


Any consultation of the Site after publication of the amended privacy policy implies unreserved acceptance by the latter of the new privacy policy.

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contacts


For any inquiries or to find out more about the processing of their personal data, including the exercise of their rights indicated above, the User may contact WELLBAW by email or post at the following address:


  • Postal mail: 90 Avenue de Wagram — 75017 Paris


  • Email: info@lesnouveauxbureaux.com



For any complaint or dissatisfaction with the use of his personal data by WELLBAW, the User may contact WELLBAW by email or post at the following address:


  • Postal mail: 90 Avenue de Wagram — 75017 Paris


  • Email: info@lesnouveauxbureaux.com



When the User contacts WELLBAW, he will be asked to identify himself.

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