Data Protection Policy
This document-policy has been produced by Franck Ardourel in compliance with the General Data Protection Regulation (GDPR). Franck Ardourel is a company headquartered in Bay Area, which offers and sell Digital and Marketing Consulting Services across the worldwide market.
Franck Ardourel is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using these corporate assets, then you can be assured that it will only be used in accordance with this Data Protection Policy.
Context and overview
Policy prepared by: Franck Ardourel, Head of Growth @FranckArdourel
Policy became operational on: April 1, 2018
Next review date: NA
Franck Ardourel needs to gather and use certain information about individuals and organizations to run its business.
These can include prospects, customers, suppliers, vendors, partners, other businesses, employees and other people the organization has a relationship with or may need to contact.
This policy describes how this personal data is collected, handled and stored to meet the company’s data protection standards – and to comply with the new law (GDPR).
Why this policy exists
This data protection policy ensures Franck Ardourel:
- Complies with Data Protection Law (GDPR) and follows good practice(s)
- Protects the right of staff, prospects, customers, suppliers, businesses, and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
What is Data protection law
The Data Protection Act 1998 describes how organizations must collect, handle and store personal information. These rules still apply regardless of whether data is stored electronically, on paper or on other materials.
EU Data Protection Directive (also known as Directive 95/46/EC) is a regulation adopted by the European Union to protect the privacy and protection of all personal data collected for or about citizens of the EU, especially as it relates to processing, using or exchanging such data.
General Data Protection Regulation (GDPR) replaces the EU Data Protection Directive of 1995. The new directive focuses on keeping businesses more transparent and expanding the privacy rights of “data subjects” (also known as consumers).
GDPR is legislation that primarily updates and unifies data privacy laws across in the European Union. GDPR was approved by the EU Parliament on April 14, 2016 and goes into effect on May 25, 2018.
To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data collected in the European Economic Area (EEA) must:
1. Be processed fairly and lawfully.
2. Be obtained only for specific, lawful purposes.
3. Be adequate, relevant and not excessive.
4. Be accurate and kept up to date.
5. Not be held for any longer than necessary.
6. Processed in accordance with the rights of data subjects.
7. Be protected in appropriate ways.
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
The policy applies to:
- The head office of Franck Ardourel
- All branches of Franck Ardourel
- All staff and volunteers of Franck Ardourel
- All contractors, suppliers, partners and other people working on behalf of Franck Ardourel
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- — PLUS any other information relating to individuals
Data protection risks
This policy helps to protect US, Franck Ardourel, from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be FREE to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Franck Ardourel has some responsibility for ensuring data is collected, stored, and handled appropriately.
Each team that handles personal data must ensures that it is handled and processed in line with this policy and data protection principles.
Franck Ardourel employees and other people the organization has a relationship with or may need to contract are responsible for:
- Reviewing all data protection procedures and related policies.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Franck Ardourel holds about them (Also called “subject access requests”).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, Digital Marketing Services.
- Approving any data protection statements attached to communications such as emails.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guideline
The only people able to access data covered by this policy are those who need it for their work at Franck Ardourel.
Data is not shared informally. When access to confidential information is required, employees can request it from their managers or/and mutually sign a Non-Disclosure Agreement (NDA) with suppliers, partners, businesses, and other people the organization has a relationship with or may need to work with.
Franck Ardourel provides training to all employees to help them understand their responsibilities when handling data.
Employees keep all data secured, by taking sensible precautions and following the guidelines below:
- In particular, strong passwords are used and are never shared.
- Personal data is not disclosed to unauthorized people, either within the company or externally.
- Data is regularly reviewed and updated if is found to be outdated. If no longer required, it is deleted and disposed of.
- Employees request help from their manager if they are unsure about any aspect of data protection.
General data practices
Data we collect
We may collect the following information:
- Name and job title.
- Contact information including email address.
- Demographic information such as postcode, preferences and interests.
- Other information relevant to customer surveys and/or offers.
We may collect the above information through cookies:
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
What we do with data we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes.
- We may contact you by email, phone, fax or mail.
- We may use the information to customize the website according to your interests.
These rules describe how and where data is safely stored. Questions about storing data safely can be directed to privacypolicy@FranckArdourel.com
When data is stored on paper, it is kept in a secure place where unauthorized people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reasons:
- When not required, the paper or files is kept in a locked drawer or filling cabinet.
- Employees make sure paper and printouts are not left where unauthorized people can see them, like on printer.
- Data printouts is shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorized access, accidental deletion ad malicious hacking attempts:
- Data is protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), theses is kept locked away securely when not being used.
- Data is stored on designated drives and servers, and is only be uploaded to an approved cloud computing services.
- Servers containing personal data is sited in a secure location, away from general office space.
- Data is backed up frequently. Those backups are be tested regularly, in line with the company’s standard backup procedures.
- Data is never saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data are protected by approved security software and firewall.
The law requires FranckArdourel to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Franck Ardourel puts in ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Staff do not create any unnecessary additional data sets.
- Staff takes every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- FranckArdourel makes it easy for data subject to update the information FranckArdourel holds about them. For instance, via the company website.
- Data is updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephones number, it is be removed from the database.
- It is the Head of Marketing’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Securing and disclosing data
Franck Ardourel is committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Subject access requests
We do not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to FranckArdourel Software Ltd, 60 Windsor Avenue, London, SW19 2RR, United Kingdom, or email your request to privacypolicy@FranckArdourel.com.
All individuals who are subject of personal data held by Franck Ardourel are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to FranckArdourel at privacypolicy@FranckArdourel.com.
Individuals will be Charged $10 per subject access request. FranckArdourel aims to provide the relevant data within 14 days.
FranckArdourel always verify the identity of anyone making a subject access request before handling over any information.
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstance, Franck Ardourel is obligated to disclose requested data. However, Franck Ardourel ensures the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or contact us as soon as possible, at email@example.com. We will promptly correct any information found to be incorrect.
Franck Ardourel aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has created this privacy statement, setting out how data relating to individuals is captured, used, stored, and handled by the company.
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