CONFIDENTIALITY CHARTER

TROPHY SAS, a simplified shareholding company, société par actions simplifiée, registered on the Versailles Companies and Business registry under number 538 081 860 whose registered office is situated at 1, Avenue Eiffel 78420 Carrières-sur-Seine, and the Data Controller for your personal data, processed for the following purposes:

TROPHY has appointed a Data Protection Officer (Ernst & Young, Lawyers) who are contactable by email on dpo@trophy-group.com or at the following postal address TROPHY – DPO, 1, Avenue Eiffel 78420 Carrières-sur-Seine. 

TROPHY processes the following categories of personal data: identification data (surname, first name, contact references etc.) data relating to your centres of interest, data relating to orders, to claims and data relating to contracts and payments. Data also relating to your professional skills, your CV and your qualifications in relation to applications for employment.

Information collected on the forms, by TROPHY which are essential to meet the purposes mentioned above are identified by an asterisk in those data collection forms. If you do not complete obligatory fields, TROPHY will not be able to provide the service in question.

Personal Data is collected by TROPHY directly from the person concerned or may be provided by our marketing partners.

Your personal data is principally provided or made accessible to TROPHY staff who are responsible for commercial and marketing aspects… Information systems security, the Financial Department, the Legal Department and the Human Resources Department. 

In addition to TROPHY, your data is provided to:

• TROPHY’s computer services providers (in particular, those responsible for IT maintenance and hosting). 
• Subcontractors working for the purposes of sales prospection (routing etc.)
• Partners acting in the context of recruitment management (recruitment agencies etc.)
• Companies in the same group as TROPHY (the 2-RIDE Group) 

Subcontractors acting in accordance with TROPHY instructions will be bound to implement appropriate protection measures.

Where some TROPHY partners are established outside the European Union we ensure that transfers are carried out in compliance with French regulatory requirements (for example setting up contractual clauses which have been adopted by the European Commission). You may contact the TROPHY Data Controller to obtain further information on these subjects and a copy of relevant documents.

Your personal data, which is processed by TROPHY, is held pursuant to legislation relating to the protection of data and according to terms prescribed by law. Thus, for example:

• Data relating to prospects is held for three years from the last commercial contact.
• Data relating to employment applicants not accepted are held for two years with their consent.

• You have the right to request access to your personal data.
• You have the right to request correction to your personal data.
• You have the right to request limits to the processing of your personal data (i) where you dispute the accuracy of your data, for a period enabling us to check its accuracy, (ii) where you consider that we are illegally processing your data and you require a limit to their use rather than deletion, (iii) where we no longer have need of your data having regard to the purposes set out above but this is still necessary for recognition, exercise or defence of your legal rights, (iv) in the event of exercising your right to opposition during the verification period relating to whether the legitimate grounds that we have take precedence over those that you have.
• You have the right to request deletion to your personal data.
• You have the right to request exercise of your rights to opposition relating to processing used for reasons relating to your particular situation.
• You have the right, at any time without any requirement to provide reasons, to oppose marketing prospection.
• You have the right not to be subject to a decision exclusively based on automatic processing resulting in legal consequences relating to or significantly affecting you.
• You have the right to exercise your rights to portability of data which means that you can obtain a copy of your data and transfer it to a third party in a format which is structured and currently in use and machine-readable.
• You have the right to withdraw your consent at any time where processing your data is based on this consent.
• You also have the right to give instructions relating to holding, deletion and communication of your personal data post-mortem.

Otherwise, these rights may be exercised at any time by sending an email to dpo@trophy-group.com or by post to the following address: TROPHY – DPO, 1, Avenue Eiffel 78420 Carrières-sur-Seine

You may also, if you wish, make a claim to the Personal Data Protection Commission, the Commission Nationale de l’Informatique et des Libertés (CNIL). Additional information is available on their Internet Site at www.cnil.fr.