ELTEA’s Privacy Policy

1. What data processing is carried out by the Firm?

The categories of personal data processed by the Firm differ depending of the context in which they are collected.

1.1 Website users’ personal data

Through the website accessible at the following address  https://eltea.legal/ (hereinafter the “Website”), the Firm may collect identification data (including first and last names, e-mail, phone number) when you fill out the contact form, as well as data relating to your browsing on the Website.

In this context, your personal data are processed by the Firm for the following purposes: (i) managing your request or claim and (ii) enhancing your browsing on the Website.

The processing relies on the following legal basis:

• your consent for the management of your request or claim (article 6. 1. a of the GDPR);
• the legitimate interest of the Firm to enhance your browsing on the Website (art 6. 1. f. of the GDPR).

1.2 Candidates’ personal data

In the context of the hiring process and applications, the Firm may collect identification data (including first and last names, date and place of birth, citizenship, civil status), contact information (including mailing address, e-mail and phone number), information relating to your studies and professional experiences (level of study, years of professional experiences, fields of intervention and/or specialization, level of remuneration requested, previous positions held, languages level, driving licence, type of contract sought) along with any other information relating to your career or education on the resume or spontaneously disclosed by the candidate to the Firm.

These data are collected directly from the candidate when he/she applies for a position or are provided by third parties to the Firm (including job websites or recruitment agencies).

The processing of candidates’ personal data is based on the following legal basis :

• the implementation of pre-contractual measures at the request of the data subject, in the context of the evaluation of the application (article 6. 1. b. of the GDPR);
• the legitimate interest of the Firm to further contact the candidate in case of subsequent employment opportunities (article 6. 1. f. of the GDPR).

1.3 Contacts and clients’ personal data

The Firm also collects personal data of contacts and clients in the context of the execution of the missions it was entrusted with and of the contracts concluded with its service providers.

The collected data include identification data (including first and last names, functions), contact information (including e-mail and phone number) and economic and financial data. Depending of the missions it has been entrusted with, the Firm may collect data relating to the personal and family life or sensitive data if need be.

Those data are processed for the following purposes:

• performance of the advisory, assistance and representation missions the Firm was entrusted with;
• management of the contractual relationship with the Firm;
• sending of information relating to the Firm’s activities and news;
• management of the Firm’s accounting and fulfilment of the Firm’s legal obligations (including tax obligations).

In this context, the processing of personal data is based on the following legal basis:

• the performance of the fee agreement and/or contract with the Firm (article 6. 1. b. of the GDPR);
• your consent regarding the sending of information relating to the Firm’s activities and news (article 6. 1. a. of the GDPR);
• compliance with the legal obligations applying to the Firm (article 6. 1. c. of the GDPR).

2. Who has access to your personal data?

Only the competent internal services of the Firm have access to your personal data, where strictly needed (lawyers, employees and interns) for the sole abovementioned purposes.

If necessary, your personal data may be transmitted to external legal service providers for the purpose of the performance of the mission you entrusted the Firm with (bailiffs, experts, third party lawyers), to subcontractors that process personal data under the sole instructions of the Firm (IT service providers) and to judiciary and administrative authorities the Firm is required to work with.

Any person who may have access to your personal data are in any case subject to a strict obligation of confidentiality (professional secrecy, legal or contractual obligation) and is required to ensure the security of your personal data.

The Firm does not transfer your personal data outside the European Economic Area, except where such transfer is necessary in the context of your case. In this event, the Firm will inform you prior to the transfer and will take any appropriate measures to ensure that the transfer and the processing of your personal data outside the European Economic Area is adequately safeguarded.

3. How long are your personal data kept by the Firm?

The Firm only keep your personal data for the strictly necessary duration to achieve the above-mentioned purposes:

• data collected through the Website’s contact form are kept for the duration of the processing of your request;
• data relating to your browsing on the Site are kept for a period of thirteen months upon their collection;
• data collected in the context of recruitment are kept for a period of two years from the last contact between the Firm and the candidate;
• data of clients and contacts are kept for the duration of the contractual relationship.

4. How are protected your personal data?

The Firm has implemented security, technical and organizational measure to protect your personal data from any forbidden access, intrusion, degradation or destruction, in compliance with the Applicable Regulation.

These measures include the implementation of specific technologies designed to protect your privacy, such as secure servers, backup of personal data within a redundant system, firewalls and SSL encryption or secure access by login and password, a demanding and complex password renewal frequency policy (minimum 8 characters, consisting of numbers, letters, an uppercase letter and a special symbol), and secure remote access by VPN access.

The Firm ensures that any person who may have access to your personal data is duly authorized and is subject to a strict obligation of confidentiality.

In addition, the Firm also ensures that any third-party service provider who has access to your personal data implements security measures at least equivalent to those implemented by the Firm.

5. What are your rights with regards to your personal data?

In accordance with the Applicable Regulation, you have the rights detailed below on your personal data, subject to applicable limitations.

5.1 The right to be informed

You have the right to obtain clear, transparent, understandable and easily accessible information on the way your personal data are processed by the Firm and on the rights you have, with regards to your data.

5.2 The right of access, to rectification or to the erasure of your personal data

The right of access enables you to obtain the confirmation that your personal data are processed, to have access to those data and to obtain a copy of those data, upon your request.

If your personal data processed by the Firm are incomplete, obsolete, or non-compliant, you have the right to ask for a rectification.

Finally, subject to the applicable limitations, you have the right to request the erasure of your personal data at any time, including (but not limited to):

• when your data are no longer necessary for the purpose of the initial processing;
• when you consider that your data should be deleted pursuant a legal obligation.

5.3 The right to data portability

You have the right to obtain communication of your personal data processed by the Firm, in a structured and commonly used format, in order to transmit them to another data controller of your choice, in compliance with the ethical rules of the legal profession. Depending on your choice, and provided that this is technically feasible, the data may be directly transferred by the Firm to the controller you indicate (in particular in the event of successive lawyers in the same case).

5.4 The right to limitation

You may request the limitation of the processing of your personal, in particular in the following cases:

• when you consider that your personal data are inaccurate, the processing will be limited during the time necessary for the Firm to verify the accuracy of your data;
• when the Firm no longer needs to process your data, but your data are still necessary if the Firm needs to establish, exercise of defend its rights;
• when you object to the processing of your personal data, the processing will be limited during the time necessary to verify and process your request.

Moreover, if you do not want the Firm to process your personal data, but however do not request the total erasure of your data, you have the right to request the limitation of the processing of your data.

5.5 The right to object

You may, at any time, object to the processing of your data by the Firm, on legitimate grounds relating to your particular situation.

The Firm may however refuse to accept your objection to the processing, in particular when the processing is (i) carried out for legitimate and compelling reasons, (ii) required by a legal obligation or (iii) necessary for the establishment, the exercise and the defence of a right.

Please note that the exercise of the right to object only applies to the future and therefore does not affect the lawfulness of the processing carried out by the Firm.

5.6 The right to decide of the handling of your data after your death

You have the right to decide of the handling of your personal data after your death, by giving instructions that the Firm undertakes to respect. These instructions may relate in particular to the erasure and the storage of your personal data, by appointing a trusted third party responsible for ensuring that they are duly observed.

5.7 The right to file a complaint before a supervisory authority

If you believe, despite the attention that the Firm gives to privacy and the protection of personal data, that your rights have not been properly observed, you can report the Firm’s policy to any supervisory authority with jurisdiction and in particular to the French Information Technology and Freedoms Commission.

6. How to contact the Firm?

Should you have any question relating to this privacy policy or for any request about your personal data, including any request to exercise your rights, you can contact the Firm directly at the following e-mail address: hello@eltea.legal or by sending a postal mail at the following mailing address: ELTEA Avocats Law Firm, 39 Boulevard Malesherbes, 75008 Paris.

The Firm is entitled to ask you for proof of your identity when your request relates to the exercise of any of the aforementioned rights.

7. Modification of the privacy policy

The Firm may have to amend this privacy policy from time to time in order to complete it and/or adapt it to regulatory changes, particularly in terms of personal data protection.

When necessary, we will inform you of significant modifications or changes made to this privacy policy.

In other cases, we will change the date on which this privacy policy was last updated.

In any event, we advise you to regularly refer to the Firm’s privacy policy to be aware of any updates or changes made.

Last update : January 23, 2020