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OBEX EU Privacy Policy
WHAT IS THIS PRIVACY POLICY FOR?
We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share (and generally “process” your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities if you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the EU’s GDPR (which applies across the European Union) and relevant French law, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Key terms
We start by explaining some key terms:
| We, us, our | OBEX Protection France SRL, SIRET 917 579 385 00019, siège sociale at 37 Rue Ambroise Paré 83100 TOULON, France. |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; data about health, sex life or sexual orientation |
Personal information we collect about you
We may collect and use the following personal information about you:
- Name and company name including email address and telephone number and company details
- Contact information including email address/ phone number
- Demographic information, such as postcode, preferences and interests
- Information to enable us to check and verify your identity, eg your date of birth
- Your gender information, if you choose to give this to us
- Location data, if you choose to give this to us
- Your billing information, transaction and payment card information
- Your personal or professional interests
- Your professional online presence, eg LinkedIn profile
- Your contact history, purchase history and saved items
- Information from accounts you link to us, eg Facebook
- Information to enable us to undertake credit or other financial checks on you
- Information about how you use our website, IT, communication and other systems
- Your responses to surveys,
- Cookies
- Website usage data
- Other information relevant to client enquiries, surveys, special offers. competitions and promotions
- Analytics from Google Analytics such as Cookies and Usage Data
- Contacting the User from the Contact form
- Traffic optimizing and distributing by Marketo (this is cookies and various data)
- Your details and information provided at exhibitions, site visits, open-days, webinars, seminars, presentations or other activities as required by the Company
This personal information is required to provide products (and on occasion services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing such products or services to you.
How we collect your personal information
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. We may also collect information:
- from publicly accessible sources
- directly from a third party, such as sanctions screening providers, , credit reference agencies, customer due diligence providers, purchased data bases
- from a third party with your consent
- from cookies on our website—for more information on our use of cookies, please the material towards the end of this Notice
- via our IT systems, for example: door entry systems and reception logs, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- from a third party with your consent
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide products and services to you, and to improve them | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you | For our legitimate interests or those of a third party – to minimise fraud potentially damaging for us and you |
| Conducting checks to identify our customers and verify their identity, Other processing to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulations | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information, to comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you, to comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For performing our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations, for our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our goods and services to existing and former customers, to third parties who have previously expressed an interest in our services, and to third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, ie to promote our business to existing and former customers eg to send promotional emails about products, services, offers and other things we think may be relevant, and to customise and improve our website |
| External audits and quality checks, eg for ISO and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards |
Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes. Correct?
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at Marketing-EU@obexglobal.com or via telephone on 04 94 65 86 14
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- updating your marketing preferences if you put them on our website
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our products (and/or services) to you, eg payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts, our professional advisers such as our legal advisers;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers; companies within our group
- credit reference agencies;
- our insurers (including credit insurers) and brokers;
- our banks;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors for the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the UK and European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Further details on this are available in our Data Retention Policy.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
- with our offices located outside the EEA;
- with your and our service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European data protection law. This means we can only transfer your personal information to a country or international organisation outside the EEA where:
- the European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
European Commission adequacy decision
The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary. It can take several years for the European Commission to issue an adequacy decision and only a small number of countries currently benefit from one. We may transfer personal information to the following countries that have the benefit of a European Commission adequacy decision: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, UK and Uruguay.
Other countries to which we are likely to transfer personal information (such Australia) do not have the benefit of an adequacy decision we are likely to transfer personal information to have the benefit of an adequacy decision. This does not necessarily mean they provide inadequate protection for personal information, but we must look at alternative grounds for transferring the personal information, such as implementing safeguards or relying on an exception, as explained below.
Transfers with appropriate safeguards
We may transfer your data to a third country on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using standard data protection contract clauses approved by the European Commission. To obtain a copy of the standard data protection clauses and further information about relevant safeguards, please contact us at Info-EU@obexglobal.com.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country where an exception applies under relevant data protection law, eg: you have explicitly consented to the proposed transfer after having been informed of the possible risks; OR the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request; OR the transfer is necessary for a contract in your interests, between us and another person; OR the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.
Further information
If you would like further information about data transferred outside the EEA, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal information |
| Rectification | The right to require us to correct any mistakes in your personal information |
| To be forgotten | The right to require us to delete your personal information — in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
If you would like to exercise any of those rights, please:
- email, call or write to us: see below: ‘How to contact us’; and
- w let us have enough information to identify you including your full name, address and customer or matter reference number;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in France is the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07. Tel. +33 1 53 73 22 22. Fax +33 1 53 73 22 00 Website: https://www.cnil.fr/en/contact-us
Changes to this privacy policy
This privacy notice was last updated in October 2022.
We may change this privacy notice from time to time – when we do we will inform you via our website.
Changes to this privacy policy
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
| Our contact details | |
| OBEX Protection France SRL, 37 Rue Ambroise Paré 83100 TOULON, France. Simon.Bartolomei-EU@obexglobal.com Telephone 04 94 65 86 14 |
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
Matters concerning our website
Use of cookies
This website uses cookies to better the user’s experience while visiting it. Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Where applicable, this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device, complying with legislation requirements for websites to get express user consent before leaving behind or reading files such as cookies on a user’s computer / device. Users wishing to deny the use and saving of cookies from this website onto their computers hard drive, should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
This website uses tracking software provided by Google Analytics to monitor its visitors to better understand how they use it, using cookies. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy for further information. Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact and communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details at their own risk. Every effort has been made to ensure a safe and secure form to email submission process but users using such form to email processes do so at their own risk.
Email newsletter
This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process if they wish, at their own discretion.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
Subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is set out at the end of each email campaign. If an automated un-subscription system is unavailable, clear instructions on how to unsubscribe will be provided.
External links
Although this website only looks to include quality, safe and relevant external links, users should be cautious of caution before clicking any external web links. The website owners website cannot guarantee or verify the contents of any externally linked website. Users click on external links at their own risk and this website’s owners cannot be held liable for any damages or implications caused by visiting any external links.
Adverts and sponsored link
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, who may have detailed privacy policies relating directly to the adverts they serve. Clicking on any such adverts will send you to the advertiser’s website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computer’s hard drive. Users click on sponsored external links at their own risk and this website’s owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social media platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform. Users should use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website’s owners will ever ask for personal or sensitive information through social media platforms and they encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users using such social sharing buttons do so at their own discretion: the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened links in social media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls. Users should take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published, many social media platforms are prone to spam and hacking and therefore this website’s owners cannot be held liable for any damages or implications caused by visiting shortened links.
Updated October 2022