PRIVACY POLICY AND COOKIE POLICY

1/ PRIVACY POLICY

The processing of personal data covered by this confidentiality policy is subject to French law, and in particular the amended French Data Protection Act of 6 January 1978 and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), hereafter referred to as the “Data Protection Regulation”.

  1. Data controller

HighCo, with its head office at 365 avenue Archimède, 13799 Aix-en-Provence cedex 3, France

Trade and Companies Register Number: 353 113 566

Hereafter referred to as “HighCo”

  1. Who is this Data protection policy for?

This policy applies to all visitors to the www.highco.com (hereafter referred to as “our website”), our registered subscribers and any person who requests information from us.

The term “personal data” (hereafter referred to as “Data”) has the meaning set out in the Data Protection Regulation.

So that you can browse our website safely, we agree to process your Data in accordance with the Data Protection Regulation. This confidentiality policy aims to provide a transparent explanation of how and why your Data are processed.

  1. Categories of Data processed

We are likely to process the following Data which we collect in the section “Contact” on our website:

The Data that we collect:

  1. Uses of your Data, legal basis and storage period 
Purposes Legal basis Data category Storage period in an active database
Communication on HighCo website (newsletter, etc.) Consent Identity (email, surname, first name, job title, etc.) Data stored until the data subject unsubscribes (using the unsubscribe link included in the newsletters).
Manage recruitments thanks to HighCo’s jobs website (please check our privacy policy https://jobs.highco.fr/)     Contract Identity (email, surname, first name, job title, etc.)   Professional Data (expertise, degrees, etc.)   Photography     2 years after the last contact with the candidate
Answer questions via our website or every other communication Consent Identity (email, surname, first name, etc.) 3 years from the last contact received from the data subject.
Statistical analysis Legitimate interest Attendance cookies 13 months
Answer the authorities’ requests (police, tax authorities, etc.) and fight against fraud     Legal obligation   Identity (email, surname, first name, etc.)     Time of the legal obligation

You can withdraw your consent at any time under the conditions described in Article 8 below.

Your Data are kept for a retention which is strictly necessary for the purposes pursued. Your Data may also be stored longer for other purposes, and particularly for compliance with our legal obligations (disputes, accounting and tax obligations). Access to archived Data is restricted.

  1. Transfer of your Data to third parties 

 Your Data may be communicated to some of our subcontractors performing services on our behalf (High Co’s subsidiarises, hosting service providers, etc.) and only in accordance with our instructions.

Your Data are not transmitted to third parties without your consent.

  1. Transfer of Data outside the European Union

Your Data are not transferred outside the European Union. In the event that we change our policy, such transfer will take place to countries recognised as providing an adequate level of protection of your Data or, at the very least, on the basis of the suitable safeguards set out by law.

  1. Security of your Data 

HighCo attaches particular importance to the security of personal data.

HighCo has introduced physical, software, administrative or organisational measures appropriate to the degree of sensitivity of the Data, in order to ensure the integrity and confidentiality of the Data and protect them from any malicious intrusion, loss, damage or disclosure to unauthorised third parties.

When it uses a service provider, HighCo only communicates Data to it after verifying that it complies with these security guidelines.

HighCo may perform audits in order to verify the satisfactory operational application of the rules relating to Data security.

  1. Your rights

8.1 Exercising your rights

You can send us your request at the following address, quoting “HighCo” in the subject line:

delegue-protection-donnees@highco.com or by letter sent to HighCo’s head office to the attention of the DPO/legal department), 365 avenue Archimède, 13799 Aix-en-Provence, France.

In accordance with the Data Protection Regulation, your request will be processed within thirty days from the time when we are in possession of all of the information necessary to process it. If your request is complex, this period may be extended by a maximum of two months, but we will inform you of this in advance.

8.2 Your right to access, rectification and Data portability (including the right not to be profiled upon an automated data processing)

In accordance with the Data Protection Regulation, you have the right to obtain confirmation that your Data are processed (or not) and the right to access them, if applicable, and request a copy of them.

You also have the right to ask us to complete and/or rectify the information concerning you.

You may request that we transfer the Data that you have given us to another data controller in a structured, commonly used and machine-readable format, within the limits set out by the Data Protection Regulation. In such an event, we will transfer them to the recipient of your choosing. You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affecting you, unless this decision is necessary for the entering into, or performance of, a contract, or is authorised by law.

8.3 Your right to object and erasure of your Data

This is your right to object at any time, without justification, to the processing of your Data by HighCo. However, HighCo may refuse to grant your request if there are legitimate, compelling grounds for this.

You may obtain from HighCo the erasure of your Data from our databases, on the conditions set out by the Data Protection Regulation, without prejudice to our legal retention obligations.

8.4 Your right to restriction of processing

In the event that you contest the processing of your Data, you may request that the processing of your Data be suspended while the dispute is investigated. In this case, we will not use your Data until the dispute has been resolved.

You may exercise this right when you object to processing, you contest the accuracy of your Data, you believe that the processing of your Data is unlawful or you need your Data for the establishment, exercise or defence of legal claims.

8.5 Your right to bring an action before the CNIL

You may bring your complaint before the French supervisory authority, the CNIL (Commission Nationale de l’Informatique et des Libertés) by bringing an action.

8.6 Your right to give instructions in the event of death

You have the right to give instructions about what happens to your Data after your death.

2/ COOKIE POLICY

This web site and its third party partners provide various services on their web sites and mobile applications by using cookies. We place cookies on your device to provide enhanced, personalised access to essential services and to provide you with other services with the aim of making your visit more relevant.

  1. What is a cookie?

Cookies are small text files placed on the hard drive of your device (computer, tablet or mobile phone), by a web site publisher or a mobile application, through your browser software. The cookie allocates a unique identifier to your device. However, it does not store your Data and does not therefore recognise you as an individual. It only recognises the device that you are using.

The cookie helps with moving between pages on a web site, adapting the content of our services, providing secure connections and remembering your browser preferences.

  1. The cookies used on our web site

The services provided through the use of cookies include: user login, protection and security. They are essential to the smooth operation of the site.

Types of cookie Cookie’s Name  Purposes Storage period
Necessary for the website’s operation (can’t be deactivated)       WordPress   This cookie allows the conservation of users’ parameters through pages demands   Session
Necessary for the website’s operation (can’t be deactivated)   tarteauxcitrons Store your choice on your consent about cookies 6 months
  1. Your cookie choices

You can express or change your cookie choices at any time clicking on “Cookie”, in the bottom right corner of our websites.

You can manage your cookie choices via your web browser too.

To make it easier for you, below are links to the “Help” sections of the most commonly used browsers:

– Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ,
– Safari™: https://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR,
– Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 ,
– Firefox™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies ,
– Opera™: http://help.opera.com/Windows/10.20/fr/cookies.html .

For further information about how cookies and targeted advertising work, please see the www.youronlinechoices.eu and www.allaboutcookies.org web sites.