Privacy policy
politique de confidentialité
Within the framework of its activity and for the needs of the supply of Services, SANDHAMN PARTNERS is led to collect and treat the personal data of its users (hereafter the “Users”).
The present privacy policy, established by SANDHAMN PARTNERS, is intended to provide Users with synthetic and global information on the processing of personal data by SANDHAMN PARTNERS.
SANDHAMN PARTNERS consider it particularly important to respect the privacy of Users and the confidentiality of their personal data, and thus undertakes to process data in compliance with applicable laws and regulations, and in particular Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms (hereinafter the “Data Protection Act”), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”).
Definitions
Personal Data : Personal data is any information relating to an identified or identifiable natural person, i.e. a person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.
Treatment of Personal Data : any operation or set of operations concerning personal data, whatever the process used, and in particular the collection, recording, organization, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as blocking, erasure or destruction, shall constitute processing..
Cookie : A cookie is a piece of information deposited on the hard disk of an Internet user by the server of the site he or she visits. It contains several pieces of information: the name of the server that placed it, an identifier in the form of a unique number, and possibly an expiration date. This information is sometimes stored on the computer in a simple text file that a server accesses to read and record information.
Collected Data
SANDHAMN PARTNERS collects data from Users in order to provide them with the services for which they have subscribed to the platform.
The obligatory or optional nature of the data provided (in order to finalize the User’s registration and provide him/her with SANDHAMN PARTNERS services) is indicated at the time of collection by an asterisk.
In addition, certain data is collected automatically as a result of the User’s actions on the site (see paragraph on cookies).
PURPOSES
The personal data collected by SANDHAMN PARTNERS in the course of providing services is necessary for the execution of contracts concluded with the User, or to allow SANDHAMN PARTNERS to pursue its legitimate interests in respecting the rights of the User. Certain data may also be processed on the basis of the User’s consent.
The purposes for which SANDHAMN PARTNERS processes data are as follows:
- Commercial and accounting management of the contract;
- Management of activation and marketing activities;
- the detection of malicious behavior (fraud, phishing, spam, etc.);
- the improvement of the users’ experience on the site;
- more generally, any of the purposes referred to in Article 2 of Deliberation No. 2012-209 of June 21, 2012, creating a simplified standard concerning the automated processing of personal data relating to the management of users and prospects
Recipients of Data
The Personal Data collected are intended for the commercial and accounting departments of SANDHAMN PARTNERS. It may be transmitted to SANDHAMN PARTNERS subsidiaries or to subcontracting companies that SANDHAMN PARTNERS may call upon for the execution of its services.
In this context, Personal Data may be transferred to a country within or outside the European Union. SANDHAMN PARTNERS puts in place guarantees ensuring the protection and security of this data, in conformity with the regulations.
SANDHAMN PARTNERS does not assign or rent Personal Data to third parties for marketing purposes without the express consent of the Users of SANDHAMN PARTNERS.
Apart from these hypotheses, the disclosure of Personal Data to third parties will only occur in the following cases:
- upon authorization from them;
- on request of the legally competent authorities, on judicial requisition, or within the framework of a legal dispute.
Duration of data retention
In order to satisfy its legal obligations or to have the necessary elements to assert its rights, SANDHAMN PARTNERS may archive data under the conditions provided for by the regulations.
Thus, Personal Data collected by SANDHAMN PARTNERS relating to the identity and contact details of its Users are archived for a maximum period of two years after the termination of contractual relations for client Users, or from the date of their collection by the data controller or the last contact from the prospect User for data relating to the latter.
Termination of the contractual relationship is understood to be the express termination of the contract by the User or the non-use of SANDHAMN PARTNERS services for a period of five years.
User Rights
In accordance with the regulations, the User has the right to access and rectify data concerning him/her, which allows him/her to rectify, complete, update or delete data that are inaccurate, incomplete, equivocal, outdated or whose collection, use, communication or storage is prohibited.
The User also has the right to request the limitation of the processing, and to object for legitimate reasons to the processing of his personal data. The User may also communicate instructions on the fate of his personal data in the event of his death.
Where applicable, the User may request the portability of his/her data, or, where the processing has consent as its legal basis, withdraw his/her consent at any time.
The User may exercise his rights by sending an email to contact@sandhamn-partners.com or by mail to :
SANDHAMN PARTNERS – 82 rue de la faisanderie, 75116 Paris
The User may unsubscribe from the SANDHAMN PARTNERS newsletter or marketing emails by following the unsubscribe links in each of these emails.
In the event of a dispute, the User may file a complaint with the CNIL, whose contact information is available at https://www.cnil.fr.
The User may access detailed information on the use of his personal data, in particular concerning the purposes of the processing, the legal bases allowing SANDHAMN PARTNERS to process the data, their retention periods, their recipients and, if applicable, the transfer of such data to a country outside the European Union as well as the guarantees implemented. To do this, the User can send his request by email to contact@sandhamn-partners.com
ADDITIONAL TERMS OF USE FOR THE INBOX FUNCTIONALITY
Notwithstanding any other provision of this Privacy Policy, if the User provides SANDHAMN PARTNERS with access to their Gmail user data, SANDHAMN PARTNERS agrees to:
- Use this access only to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings in order to provide a web-based email client for users to compose, send, read, and process their email;
- Never transfer this data to a third party except as required to provide and improve these features, comply with the law, or as part of a merger, acquisition, or sale of assets;
- Never use this data to manage its customer acquisition or marketing activities;
- Never use this data to serve advertising;
- Never allow individuals to read this data without express and explicit consent for certain messages, for security reasons such as the detection of fraud or abuse, to ensure compliance with the law in force, or for internal operations of SANDHAMN PARTNERS, and only when the data has been aggregated and anonymized
What is a cookie ?
A cookie is a file that is downloaded to your terminal (computer, smartphone, tablet…) when you visit certain websites. Cookies allow these websites to store and retrieve information about the browsing habits of the user of a site or his equipment and then, based on this information, to recognize him. However, the data obtained is limited. It only concerns the number of pages visited, the city where the IP address of the connection to the website is located, the frequency and recurrence of visits, the duration of the visit, the browser, the operator or the type of terminal from which the visit is made. Data such as the name, surname of the user or the postal address of the connection are not, under any circumstances, obtained.
Cookies used on this website
The cookies used on this website facilitate the user’s navigation on our site and store a session identifier. They expire during or after the session, or after a period not exceeding 13 months, in accordance with the recommendations of the CNIL.
Cookies and third party trackers
These are cookies or tracers downloaded to your terminal by third parties (audience measurement, interactive map display, content sharing button via social networks…) when you browse certain pages of our site. The user can activate or deactivate third-party cookies at any time by going to the cookies section below.
If you wish to change your cookie preferences again, simply delete the recent history of your browser (last 24 hours), then refresh the page of the site you are on.
A banner will automatically reappear at the bottom of the page allowing you to modify your previously saved settings.
Security
SANDHAMN PARTNERS has taken all necessary precautions to preserve the security of Personal Data and, in particular, to prevent it from being distorted or damaged or accessed by unauthorized parties.
These measures cover in particular :
- Multi-level firewall,
- Proven anti-virus and intrusion detection,
- Encrypted data transmission using SSL/https/VPN technology,
- Tier 3 and PCI DSS certified data centers
In addition, access to the processing by SANDHAMN PARTNERS’ recipient services requires authentication of the persons accessing the data, by means of an individual access code and password, sufficiently robust and regularly renewed.
Data transmitted over unsecured communication channels are subject to technical measures designed to make them unintelligible to any unauthorized person.
Any question about the security of the Sandhamn Partners website can be addressed to contact@sandhamn-partners.com
Amendment to the Privacy Policy
SANDHAMN PARTNERS reserves the right to change this Privacy Policy in order to comply with changes in applicable laws and regulations.
The modifications made will be notified via our website.
Contact
Any question related to the Privacy Policy of SANDHAMN PARTNERS can be sent via email to contact@sandhamn-partners.com or per mail to : SANDHAMN PARTNERS – 82 rue de la Faisanderie, 75116 Paris