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Submitted URL:
https://www.cegid.com/en/privacy-policy
Effective URL:
https://www.cegid.com/global/privacy-policy/
Submission: On November 14 via api (November 14th 2023, 9:16:42 am UTC) from PT — Scanned from PT

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PRIVACY POLICY & COOKIES

This page describes how Cegid processes the personal data collected from data
subjects (clients, leads, etc.).

If you have any questions regarding this policy, please contact
dataprivacy@cegid.com


PRIVACY POLICY

Last updated: January 2023


1. INTRODUCTION

The aim of this privacy policy is to introduce the rules related to the
protection of personal data that Cegid Group (hereinafter “Cegid”) agrees to
respect as data controller and data processor, for all personal data covered by
this policy. These rules were drafted pursuant to Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April 2016 (General Data
Protection Regulation, hereinafter “GDPR”) on the protection of individuals with
regards to processing of personal data and on the free movement of such data,
and repealing Directive 95/46/CE.

This document is subject to change where necessary in order to implement the
obligations imposed by personal data protection legislation. We encourage you to
periodically review this privacy policy on our dedicated page:
https://www.cegid.com/global/privacy-policy/

The concepts related to personal data protection used in this document have the
meaning given in the GDPR, notably in accordance with article 4 of the GDPR.

 


2. GENERAL PRINCIPLES ON PERSONAL DATA PROTECTION

When Cegid acts as a data controller

Pursuant to article 5 of the GDPR, Cegid ensures that personal data are:

 * processed lawfully, fairly and in a transparent manner
 * collected for specified, explicit and legitimate purposes and not further
   processed in a manner that is incompatible with those purposes
 * adequate, relevant and limited to what is necessary in relation to the
   purposes for which they are processed
 * accurate and, where necessary, kept up to date
 * kept for no longer than is necessary for the purposes for which the data are
   processed
 * processed in a manner that ensures appropriate security of the personal data,
   including protection against unauthorised or unlawful processing and against
   accidental loss, destruction or damage, using appropriate technical or
   organisational measures.

When Cegid acts as a data processor

Pursuant to article 28 of the GDPR, Cegid ensures that:

 * the purposes of the processing are described in the contract signed between
   Cegid and the client
 * the client’s personal data are processed solely for the purpose for which
   they were originally collected based on their instructions, in accordance
   with the terms of the contract
 * the deletion of personal data is carried out at the end the of contractual
   relationship and under the conditions laid down in the contract, unless the
   applicable law requires the preservation of personal data.

 


3. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING

When Cegid acts as data controller

For internal needs, Cegid collects personal data for purposes such as:

 * management of customer contacts and leads (sending marketing, product or
   Group information, satisfying customers and leads, producing statistics,
   etc.)
 * management of commercial contracts (fulfilling orders, billing, debt
   recovery, etc.)
 * management of Cegid’s staff, recruitment and careers (evaluating and
   contacting candidates, etc.)
 * creation and administration of user accounts
 * development and management of services to which the client has subscribed
   (recording calls to the helpdesk, etc.).

Depending on these different purposes, Cegid ensures that at least one of the
following applies:

 * the data subject has given consent to the processing of his or her personal
   data for one or more specific purposes
 * processing is necessary for the performance of a contract to which the data
   subject is party or in order to take steps at the request of the data subject
   prior to entering a contract
 * processing is necessary for compliance with a legal obligation to which Cegid
   is subject
 * processing is necessary for the purposes of the legitimate interests pursued
   by Cegid, except where such interests are overridden by the interests,
   fundamental rights and freedoms of the data subject.

When Cegid acts as data processor

Cegid may need to access and process personal data provided by its clients in
order to provide offerings and services to which the customer subscribes.

This access and processing are governed by a contract containing specific
clauses for data protection signed between Cegid and the client.

Cegid processes personal data only on behalf of the client based on their
documented instructions, in accordance with the provisions of the contract.

 


4. SECURITY AND NOTIFICATION OF PERSONAL DATA BREACHES

Cegid has taken technical and organisational measures to ensure a level of
security appropriate to the risks.

Cegid’s Information Security Management System is certified ISO 27001 for the
following scope: “Application hosting services in a Cloud environment,
containing data provided by the clients”.

This certification ensures that a certified security policy is applied to
Cegid’s processes and workflow throughout the duration of the SaaS service
provided to the client.

More generally, all employees of Cegid are subject to an IT security charter
appended to the internal policy to ensure an appropriate level of security.

Pursuant to articles 33 and 34 of the GDPR, personal data breaches shall be
notified:

 * to the French supervisory authority (CNIL) and, if necessary, to data
   subjects affected by the breach, when Cegid acts as a data controller
 * to its clients affected by the breach in accordance with the contract signed
   between Cegid and its clients, when Cegid acts as a data processor

 


5. DATA SUBJECT’S RIGHTS

When Cegid acts as a data controller

Under the conditions set forth in articles 15 and 22 of the GDPR, data subjects
have the right to:

 * access their personal data processed by Cegid
 * request the rectification, erasure or restriction of processing of personal
   data carried out by Cegid
 * in certain circumstances, object to the processing of their personal data
 * request the portability of personal data
 * withdraw their consent when it is the legal basis of the processing
 * give instructions regarding the handling of their personal data after their
   death (pursuant to Law no. 78-17 of 6 January 1978 on Data Processing, Data
   Files and Individual Liberties).

All requests related to these rights may be made by filling out the form
available on the following page: https://www.cegid.com/global/privacy-policy/

Cegid reserves the right to ask for clarifications in relation to any request
and to verify the identity of the requester.

An “Unsubscribe” link is also available in our marketing emails.

In any event, Cegid recommends contacting the CNIL for more information about
data protection regulations, the rights of data subjects and the possibility of
lodging a complaint with this authority: https://www.cnil.fr/

When Cegid acts as data processor

In the event Cegid receives a request from a data subject whose data is
processed in the course of performing the contract between Cegid and the client,
Cegid will communicate this request to the client at the earliest opportunity
upon its receipt and, taking into account the nature of the processing and the
terms of the contract, will take appropriate technical and organisational
measures to assist the client with fulfilling its obligation to respond to these
requests, insofar as this is possible.

The client remains nevertheless responsible for replying to the data subject
concerned.

 


6. INFORMATION TO BE GIVEN TO THE DATA SUBJECT

When Cegid acts as a data controller

When collecting personal data, Cegid undertakes to provide data subjects with at
least the following information, to the extent possible and regardless of the
processing carried out:

 * the contact information of the controller and its Data Protection Officer
 * the purposes of the processing and its legal basis
 * the recipients
 * transfers of data outside the EU, if applicable
 * the length of time the data will be kept
 * the possibility to request the exercise of any available rights pursuant to
   the applicable regulations
 * the right to submit a complaint with the supervisory authority

Cegid may also receive personal data (name, company, phone, email address) from
external sources such as lead providers.

Such data is used only to:

 * update, develop and analyse its client/lead database
 * generate leads
 * provide information relating to the appropriate Cegid products and services.

When Cegid acts as data processor

Pursuant to article 13 of the GDPR, the controller has the responsibility to
inform data subjects.
In accordance with the terms of the contract, Cegid provides clients acting as
data controllers with any information that might help them enforce article 13 of
the GDPR.

 


7. TRANSFERS OUTSIDE THE EUROPEAN UNION

Personal data may be processed outside European Union. As a consequence,
pursuant to data protection legislation, Cegid cannot transfer personal data,
without implementing the appropriate safeguards according to article 46 of the
GDPR, outside:

 * the European Union, or
 * the European Economic Area, or
 * countries recognised by the European Commission as having an adequate level
   of security.

 


8. DATA RECIPIENTS

Cegid may share personal data with third parties solely under the conditions of
this document and/or the applicable contract.

Services provider

Cegid may share personal data with third parties who provide services,
including:

 * on Cegid’s behalf, as part of the performance of the client contract
   (hosting, consulting, subcontracting, etc.) and in accordance with its terms
 * to help Cegid fulfil the financial and administrative conditions of the
   contract (debt recovery, invoicing, etc.)
 * to send marketing communications on behalf of Cegid.

Commercial or distributor Cegid partners

Cegid has developed a network of partners (distributors, publishers, etc.) for
several of its offerings in order to help it deliver and develop its products.

Depending on which product is or may be of interest to the contact, Cegid may
need to share this contact’s information with an appropriate partner.

Subsidiaries of Cegid Group

Cegid may share personal data with the subsidiaries of Cegid Group for the
purposes that are described in this privacy policy, if necessary for its
implementation (signing a contract, applying for a position in a subsidiary
outside France, etc.).

Public authorities

In certain situations, Cegid may be required to disclose personal data in
response to a request by a public authority, a subpoena, or any other lawful
request pursuant to the applicable legislation.
In such cases, Cegid will disclose the necessary data, particularly when it
believes in good faith that disclosure is necessary to protect your rights,
ensure your safety or the safety of others, investigate fraud, or meet a legal
requirement.

For more information about the recipients, please contact dataprivacy@cegid.com

 


9. COOPERATION OF CEGID WITH ITS CLIENTS AND WITH THE SUPERVISORY AUTHORITY

In accordance with article 28 of the GDPR and its contractual commitments, Cegid
undertakes to reasonably cooperate with its clients in order to help them meet
their obligations pursuant to articles 32 to 36 of the GDPR.

More generally, Cegid agrees to cooperate with the French supervisory authority
(CNIL) where necessary and to reasonably consider its recommendations.

 


10. PRIVACY BY DESIGN REGARDING PRODUCTS AND SERVICES

If Cegid plans to develop a new service or offering, Cegid, in its capacity as a
software publisher, will make every effort to introduce “privacy by design”
principles from the beginning of the project, thereby helping its clients comply
with the applicable regulations using specific features and resources.

 


11. CEGID STAFF AWARENESS

All new Cegid employees must take an awareness training concerning personal data
protection.

More generally, Cegid will make every effort to offer its employees regular
awareness training regarding personal data protection.

Awareness training or more specific trainings may be conducted for employees
working on a regular basis with personal data.

 


12. GOVERNANCE OF PERSONAL DATA PROTECTION

To manage personal data protection, Cegid has a dedicated governance structure
in place.

A Data Protection Officer (DPO) has been appointed to the CNIL to oversee this
governance.

 


13. RECORDS OF PROCESSING ACTIVITIES

Pursuant to article 30 of the GDPR, Cegid maintains two records of personal data
processing:

 * a record describing the processing carried out as data controller
 * a record describing the processing carried out on behalf of its clients
   acting as data controllers, based on their instructions

These records are made available to the CNIL upon request.

 


14. CONTRACTUAL POLICY

Pursuant to article 28 of the GDPR, Cegid has incorporated the new mandatory
contractual stipulations into all contracts concerned.

Accordingly, specific contractual clauses on data protection pursuant to the
applicable regulations have been added to:

 * client contracts (GTC/GTU)
 * contracts between Cegid and its own data processors

 


15 CONTACT

If you have any inquiries regarding this privacy policy or wish to contact our
Data Protection Officer, please send an email to the following
address:dataprivacy@cegid.com


PERSONAL DATA COLLECTED AS PART OF A COMMERCIAL RELATIONSHIP WITH CEGID

In order to provide the required service and manage its commercial
relationships, Cegid SAS, acting as data controller, located at 52 quai Paul
Sedallian, 69009 Lyon (France), collects and processes the following personal
data: Surname, name, email address, telephone number, position and company name.

These personal data are processed by Cegid SAS to manage its commercial
relationships and provide the required service or product. Unless prohibited by
law, the personal data collected for these purposes are processed for at most
five years after the end of the commercial relationship.

Cegid may disclose some of your data to third parties, including for the
purposes of debt recovery or for commercial communications by a limited number
of Cegid partners.
For more information about these partners, please contact dataprivacy@cegid.com.

Cegid or its partners may also send you commercial communications.
These promotions are sent based on our legitimate interest in sending you
communications related to your business activities. You may unsubscribe at any
time by clicking on the link available in all our communications.
The personal data collected for this purpose are processed for at most three
years after the end of the commercial relationship or the last communication
sent by the subject concerned.

You may also exercise your rights in accordance with this policy by filling out
the “Data subject’s rights” form below.


PERSONAL DATA COLLECTED THROUGH THE FORMS PROVIDED ON CEGID.COM

Depending on the nature of the form, Cegid SAS, acting as data controller,
located at 52 quai Paul Sedallian, 69009 Lyon (France), may collect the
following personal data: Surname, name, email address, telephone number,
position and company name.

These personal data are processed by Cegid SAS in order to respond to your
request, manage its client/lead files and commercial communications, and produce
statistics.

The personal data collected for this purpose are retained for at most three
years after the last communication sent by the subject concerned.

Cegid SAS’s subsidiaries and partners may be the recipients of these personal
data for the purposes described above. Partners may be distributors of Cegid
products that are likely to be of interest to the contact.

Cegid SAS, its subsidiaries and its partners may transfer the data to third
countries only if it is necessary for these purposes. In each case, Cegid
implements the necessary safeguards to secure these transfers.
Commercial communications are sent based on our legitimate interest in sending
you communications related to your business activities. You may unsubscribe at
any time by clicking on the link available in all our communications.

You may also exercise your rights in accordance with this policy by filling out
the “Data subject’s rights” form below.


PERSONAL DATA COLLECTED IN THE COURSE OF PROVIDING CEGID SAAS SERVICES

In order to provide the required service, Cegid SAS, acting as data controller,
located at 52 quai Paul Sedallian, 69009 Lyon (France), collects and processes
the following personal data: Surname, name, email address, telephone number,
position, company name, usage data (log).

These personal data are processed in accordance with Cegid SAS’s legitimate
interests, for the purposes of traceability and data security, as well as user
account management, security, traceability and communications related to Cegid
offerings.

The data are retained for as long as the service is used, with the exception of
logs, which are retained for at most one year.

You may exercise your rights in accordance with this policy by filling out the
“Data subject’s rights” form below.

When third-party products are contracted through one of Cegid’s offerings, the
relevant commercial partners may process these same data. In this case,
processing terms are defined by the relevant partner.


PERSONAL DATA PROCESSED AND/OR COLLECTED WITHIN THE CONTEXT OF HELPDESK CALLS
(”CUSTOMER CARE”)

In the case of helpdesk calls (“Customer Care”), Cegid may listen to and/or
record calls between the operator and the client for the purposes of:

 * Evaluating the quality of service provided by the operator to the client. In
   this case, recordings are retained for 6 months, while the analysis report
   may be retained for up to one year.;
 * Retaining evidence in the event of litigation. In this case, recordings are
   retained for 5 years.

In the event that your call will be recorded and listened to, a voice message
will inform you in advance.
You may exercise your rights in accordance with this policy. More specifically:

 * If you would like to exercise your right to oppose any recording and/or
   listening in on your call, you can inform the operator. If you would like to
   exercise this right after the call, you can complete the “Data subject’s
   rights” form below on this page. Please be sure to specify your request.
 * For other rights, including access rights, you may submit a request by
   completing the “Data subject’s rights” form below. Please be sure to specify
   your request.

In each case, Cegid collects the following personal data for the purposes of
tracking Customer Care requests: surname, first name, contact details (email
address, telephone number), position.

After processing their request, a satisfaction survey may also be sent to the
requester to evaluate the service provided, in furtherance of our legitimate
interests.

Depending on the product and the countries in which this survey is provided,
subsidiaries of Cegid SAS may be recipients of these data.

Cegid SAS, its subsidiaries and its partners may transfer these data to third
countries only if it is necessary for these purposes.

You may also exercise your rights in accordance with this policy by filling out
the “Data subject’s rights” form below.


PERSONAL DATA PROCESSED IN THE CONTEXT OF INTRA-GROUP RELATIONS WITH TALENTSOFT
SA

Cegid SAS is a recipient of the personal data processed by its subsidiary
Talentsoft SA. Then, Cegid SAS and Talentsoft SA process these data as joint
controllers.

An arrangement has been signed between them in order to reflect their respective
roles and relationships with data subjects.

In case of the merger (or any equivalent transaction), Cegid SAS will be
regarded as the new processor of data initially processed by Talentsoft SA. De
facto, the Cegid’s privacy policy will apply.


COOKIES POLICY

Customize cookies

The Web servers of Cegid Group websites automatically collect from the users of
Cegid group sites (hereinafter referred to as “the sites”), the information
relating to the use of the sites (as well as certain other information such as
browser type and the operating system or IP addresses).
Cegid group websites may use cookies, small text files sent and stored on your
computer that allow web servers to recognize users’ habits, facilitate their
access to Cegid group sites, and allow the sites to compile global data that
will improve the sites and their content.Cookies do not damage the computers or
files. The cookies themselves cannot be used to discover the identity of the
user.

The law states that we may only store cookies on your device if they are
strictly necessary for the operation of this site. For all other types of
cookies, we need your permission.

This site uses different types of cookies. Some cookies are placed by
third-party services that appear on our pages.
At any time, you may change or withdraw your consent on our Privacy Policy page.
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Your consent applies to the following area: www.cegid.com

How to manage your cookies on your browser?

You have several options to delete the cookies.

Indeed, if most browsers are set by default and accept the installation of
cookies, you have the option, if you wish, to choose to accept all the cookies,
or reject them systematically or choose the ones you accept according to the
issuer.
You can also set your browser to accept or refuse cookies on a case-by-case
basis prior to their installation. You can also regularly delete cookies from
your device via your browser.

For the management of cookies and your choices, the configuration of each
browser is different. It is described in the help menu of your browser, which
will allow you to know how to change your configuration on cookies.

However, if you set your browser to refuse the cookies or refuse the
installation of a cookie, such deactivation could prevent the use of certain
features of the Cegid group sites or prevent the access certain services, for
which we cannot be held responsible.

We thank the users of the site to inform us of any omissions, errors, or
corrections, by using our contact form.


DATA SUBJECT’S RIGHTS

In accordance with the Regulation (EU) 2016/679 of the European Parliament and
of the Council of 27 April 2016 (« GDPR »), you have the right of access,
rectification, data portability, restriction of processing, object and to
erasure (“right to be forgotten”) concerning your personal data processing by
Cegid.

To exercise your right, please complete the following form.

To lodge a complaint, please visit the website of your national supervisory
authority

Are you a Cegid’s client or a prospect ?ClientProspect
Are you a Cegid’s client or a prospect ?
Client
Prospect


*
If you are a client, please fill in your client number




*
What is your request ?

Right of accessRight to rectificationRight to erasure (‘right to be
forgotten’)Right to restrictionRight to data portabilityRight to object






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When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
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which amount to a request for services, such as setting your privacy
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or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

PERFORMANCE COOKIES

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
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or all of these services may not function properly.

TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
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relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
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