This is a translation. The French version is the reference version and prevails in the event of any divergence of interpretation.
FAUBOURG CONSEIL, a société par actions simplifiée with share capital of €27,019.60, registered with the Paris Trade and Companies Register (RCS) under number 478 942 055, APE code 70.10Z, with its registered office at 5 rue Nollet, 75017 Paris (hereinafter “Faubourg Conseil”), attaches particular importance to the protection of personal data and to the privacy of the individuals whose data it processes.
The purpose of this privacy policy is to inform, in a clear, transparent and accessible manner, visitors to and users of the website https://letia.app/ (hereinafter the “Site”), as well as its prospective customers, how their personal data is collected and processed by Faubourg Conseil as data controller, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”) and with French Law No. 78-17 of 6 January 1978 as amended (“Loi Informatique et Libertés”).
It supplements the legal notice and terms of use of the Site, and may be updated at any time to reflect legal, regulatory or technical developments. The applicable version is the one in force on the date on which the data concerned is collected and/or processed, subject to any subsequent amendment to this policy brought to the attention of the data subjects in accordance with the applicable regulations.
The services and activities of Faubourg Conseil are intended exclusively for a professional clientele. The Site is aimed at companies, their representatives, employees and staff acting in a professional capacity, and is not intended to offer services to consumers or to process data collected in a consumer context.
This Privacy Policy was originally drafted in French and may be made available in other languages to facilitate understanding. In the event of any divergence of interpretation between the different language versions, the French version constitutes the reference version, subject to applicable mandatory legal provisions.
The sole purpose of the Site is to present the Letia platform. It does not give access to the platform itself and allows no operational use. No data relating to the staff of client companies, and no data originating from the platform, is processed on it. Apart from the information you choose to enter in the two forms, the Site records an anonymous measurement of its own traffic, described in section 10.
This policy does not apply to the processing of personal data carried out by Faubourg Conseil and/or its Affiliated Companies in the context of their employment relationships with their employees, nor to processing carried out on behalf of their clients as part of their fleet management services, which are covered by specific information or documentation.
Faubourg Conseil is the controller of the personal data processing carried out in connection with this Site.
The tools used for the Site, in particular hosting and the e-mail sending tool, are shared within the group to which Faubourg Conseil belongs. Certain data may be transmitted to Companies Affiliated with Faubourg Conseil which may, depending on the purposes pursued, act as separate controllers or as processors.
For any question relating to this policy or to the processing of your data, as well as to exercise your rights, you may contact the DPO at: dpo@groupe-faubourg.com.
Faubourg Conseil collects only the data strictly necessary for the purposes pursued (data minimisation principle). Data may be collected directly from you, through the newsletter sign-up form and/or the demonstration request form.
The table below summarises the processing carried out.
| Purpose | Description | Legal basis | Data concerned | Maximum retention period |
|---|---|---|---|---|
| Handling contact, information and demonstration requests | Responding to contact, information and demonstration requests submitted through the forms on the Site, following up on exchanges and directing requests to the relevant contacts. | Legitimate interest (responding to an enquiry) | Surname, first name, company, e-mail, telephone, content of the free-text message | 3 years from the last contact where no contractual relationship is entered into. |
| Commercial prospecting and marketing | Information campaigns (newsletters, e-mailings, etc.), questionnaires, assessments; commercial approaches; handling of objections, unsubscribe requests and suppression lists. | Legitimate interest (business development) and legal obligation for the handling of objections and unsubscribe requests | Surname, first name, company, business e-mail, telephone, answers to questionnaires | 3 years from the last contact that went no further, or from the end of the commercial relationship. |
| Customer relationship management | Handling information requests, contracts, complaints, support and follow-up of the commercial relationship. | Performance of the contract or of pre-contractual measures | Surname, first name, company, e-mail, telephone, content of the messages exchanged | For the duration of the contractual relationship, then intermediate archiving for the applicable limitation period, generally 5 years. |
When data is collected, mandatory fields are indicated (for example by an asterisk). If the mandatory fields are not completed, Faubourg Conseil may be unable to process your request. The other fields are optional.
As part of its commercial prospecting activities, Faubourg Conseil may process business contact details obtained from files acquired from specialist providers.
In accordance with the regulations, the data subjects are informed, at the latest at the time of the first contact, of the origin of their data, and may object to this processing at any time, in particular via the unsubscribe link included in every communication or by writing to the DPO.
The data is primarily intended for the authorised departments of Faubourg Conseil, which use it in accordance with this policy.
As a matter of principle, Faubourg Conseil does not share or disclose your personal data to third parties, except in the following circumstances:
In organising its activities, Faubourg Conseil may share certain personal data with the companies it controls, which control it, or which are under the control of the same beneficial owners, within the meaning of Article L. 233-3 of the French Commercial Code and Article L. 561-2-2 of the French Monetary and Financial Code. Such exchanges take place where they are necessary for the administrative, financial, commercial or operational management of the group's activities. The Affiliated Companies are then bound to comply with the provisions of this policy and with the applicable personal data protection regulations. The list of the Affiliated Companies concerned will be provided to you on simple request to the DPO.
Faubourg Conseil may disclose certain personal data to external providers and to its advisers where such access is necessary for the performance of their assignments. These recipients may include, in particular, IT providers, hosting providers, software publishers, maintenance providers, lawyers, accountants, statutory auditors, auditors, insurers, banking institutions or any other adviser involved in the management, security or development of Faubourg Conseil's activities. These recipients access only the data strictly necessary for the performance of their assignment and are subject to confidentiality obligations and, where applicable, to contractual commitments compliant with the applicable personal data protection regulations.
It is expressly stated that, for the provision of certain services, Faubourg Conseil uses processors acting on its instructions and providing sufficient guarantees within the meaning of Article 28 of the GDPR.
The main tools used on the Site are:
We may disclose personal data to administrative, judicial or regulatory authorities, as well as to any authorised person, where such disclosure is required by law, by applicable regulations or by a court decision, or where it is necessary to exercise, establish or defend our rights.
Faubourg Conseil ensures that personal data is hosted and processed within the European Union. Its policy is to keep all personal data within the European Economic Area.
The e-mail sending tool (SendGrid) may nevertheless involve a transfer of data to a country outside the European Union. Where such a transfer takes place, it is governed by the appropriate safeguards provided for in Chapter V of the GDPR (European Commission standard contractual clauses or adequacy decision).
Faubourg Conseil implements appropriate technical and organisational measures to preserve the security and confidentiality of personal data and to prevent it from being distorted or damaged, or accessed by unauthorised third parties (encryption of exchanges, access control, HTTPS protocol, protective measures at provider level).
Faubourg Conseil uses no automated decision-making mechanism and no profiling based on the personal data collected under this privacy policy.
The Site uses cookies and trackers. Cookies strictly necessary for the operation of the Site are set without consent. The Site also uses a facility for producing anonymous statistics on traffic and on the use of the Site's various features. This facility collects no data entered in the forms and no IP address, and does not allow visitors to the Site to be identified. It therefore does not require your consent either.
The lifetime of audience measurement trackers is limited to 13 months and is not automatically extended on your subsequent visits.
In accordance with the GDPR, you have the following rights regarding your personal data:
Exercising your rights may require proof of your identity so that we can verify its accuracy.
You may exercise these rights by writing to the DPO at dpo@groupe-faubourg.com. A reply will be provided within one month. This period may be extended by two months depending on the complexity or the number of requests; you will then be informed accordingly.
You also have the right to ask any question or to lodge a complaint concerning the processing of your personal data with the data protection authority of your Member State or of the Member State in which you consider that your rights under the GDPR have been infringed.
In this respect, if you consider that your rights are not being respected, you may lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr. We nevertheless invite you to contact us beforehand so that we can provide you with an appropriate response.
Faubourg Conseil reserves the right to amend this privacy policy at any time. The applicable version is the one published on the Site on the date on which the data concerned is collected and/or processed, subject to any subsequent amendment brought to the attention of the data subjects in accordance with the applicable regulations. We invite you to consult the corresponding page of the Site regularly. We will inform you of any significant change through our website or our other usual means of communication, and will seek your consent where necessary.