Privacy Policy

Version dated 07/02/2022

Preamble

The General Data Protection Regulation (GDPR) came into force on 25th May 2018 and completes the legislation on personal data protection.
For your information, personal data is any information relating to an individual person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to him or her (surname, first name, address, e-mail, telephone, contract number, credit card number, etc.).
Processing of personal data means any operation carried out on this type of data (collection, storage, transmission, deletion, etc.), whether on paper or by computer. The person in charge of processing is the person who determines the purpose for each processing operation and the means to achieve these purposes.
For SARL TAMARINA, the protection of your data is a priority. Therefore, in the interest of transparency, this Privacy Policy aims to explain to you why your personal data is collected and processed by SARL TAMARINA, in its capacity as data controller, how it is processed, what rights you have over your data and how you can exercise them.
SARL TAMARINA reserves the right to modify this Privacy Policy at any time. Any modification will take effect immediately.
Therefore, we invite you to regularly consult our Policy, accessible from all the pages of our website, in order to be informed of the latest applicable online version. We also
encourage you to check the date on this Policy to see when it was last updated.

 

Contents

 

  1. Why does SARL TAMARINA need to collect your data?
  2. What data does LA SARL TAMARINA collect?
  3. What is the legal basis for processing your data?
  4. How long will your data be kept?
  5. What are your rights and how can you exercise them?
    1. Your rights over your data
    2. Exercising your rights
  6. With whom does SARL TAMARINA share your data?
  7. Is your data transferred outside the EU?
  8. How does SARL TAMARINA secure the processing of your data?
  9. Required fields
  10. Cookies policy
  11. Social Networks
  12. Privacy by Design/by Default
  13. Accountability

 

  1. Why does TAMARINA SARL need to collect your data?

 

The data that SARL TAMARINA collects is necessary to enable it to fulfil the following purposes:

 

With regard to the data of website users:

  • responding to requests received via our ‘contact’ section
  • managing cookies

For customer and prospect data:

  • contract management (booking, invoices, payments) ;
  • customer account management ;
  • loyalty / satisfaction management;
  • management and follow-up of prospect requests;
  • monitoring complaints ;
  • compiling business and financial statistics;
  • accounts management ;
  • managing unpaid bills does not lead to the exclusion of the person from any future transactions;
  • managing possible pre-litigation and litigation;
  • managing requests to exercise rights granted to users under the regulations applicable to the processing of personal data.

For data from partner suppliers:

  • managing accounts payable: carrying out administrative operations related to contracts, orders, receipts, invoices, payments and accounting;
  • issuing payment orders ;
  • the provision of supplier selections for the needs of SARL TAMARINA;
  • archiving documentation related to supplier monitoring;
  • drawing up financial statistics (turnover per supplier, etc.);
  • manging possible pre-litigation and litigation;
  • managing requests to exercise the rights granted to users under the regulations applicable to the processing of personal data.

In general, SARL TAMARINA does not process any of your data for purposes incompatible with those for which they were collected, except with your prior consent.

 

  1. What data does SARL TAMARINA collect?

 

SARL TAMARINA collects different types of personal data about you:

  • Personal data that you provide directly to us:
    • When you fill in a contact form,
    • When you send a booking request ;
    • When issuing an invoice,
    • When you contact the SARL TAMARINA to ask a question or to file a complaint,
    • In general, when you communicate with SARL TAMARINA in any other way.

The communication of your personal data is voluntary. However, certain information, identified by an asterisk, is essential for SARL TAMARINA to process your request. Without this information, SARL TAMARINA will not be able to process your request.

 

  • Personal data created by SARL TAMARINA

 

On the basis of the personal data that it holds, SARL TAMARINA may create or infer data concerning you. If necessary, this data is necessary for:

  • Billing and accounts management
  • Generating commercial and financial statistics
  • Management and follow-up of complaints
  • The personal data we collect automatically

 

We automatically collect certain information about you when you access the website of SARL TAMARINA, in particular, information about your browsing activity. SARL TAMARINA uses cookies and other tracking technologies to collect information about you when you interact with the SARL TAMARINA website.

To learn more about cookies and how to disable them, please see our Cookies Policy.

 

 

  1. What is the legal basis for processing your data?

 

SARL TAMARINA collects your personal data for the purposes described in article 1 of this Policy. In every case, SARL TAMARINA collects your data only when its collection and processing have a legal basis.

 

Carrying out contractual relations with SARL TAMARINA
Your data is necessary for carrying out the contract to which you have subscribed or wish to subscribe. On this contractual legal basis, any refusal to communicate your personal data will prevent the conclusion and execution of said contract:

  • Concerning customers and prospects: data required to make a reservation or invoice;
  • Concerning suppliers: administrative operations related to contracts, orders, receipts and invoices, as well as creating payment orders required by the contract between SARL TAMARINA and the supplier concerned.

Respecting legal obligations to which SARL TAMARINA is subjected

 

Some of your data is processed by SARL TAMARINA to meet our legal obligations, in particular:

  • Accounting and tax obligations for the management of accounts receivable and payable;
  • For the processing of requests to exercise rights granted to users under the applicable regulations on the protection of personal data

Your consent

 
Subject to having obtained your prior consent, SARL TAMARINA may process your data to deploy cookies, under conditions described in our Cookies Policy.

At any time, you can go back on your choice and withdraw your consent, according to the modalities described in article 5.2 of this Policy, without however calling into question the legality of the processing based on the consent and implemented before said withdrawal.

 

The legitimate interests of SARL TAMARINA

SARL TAMARINA may process your personal data for the purpose of pursuing its legitimate interests, in particular:

  • Concerning customers and prospects:
    • Complaints management
    • Managing any pre-litigation or litigation
    • Managing unpaid bills which will not result in the exclusion of the person from any future transactions
    • Compiling of business and financial statistics
  • In the area of supplier file management :
    • Supplier selection ;
    • Archiving documentation related to supplier monitoring;
    • Compiling financial statistics ;
    • Managing possible pre-litigation and litigation

 

  1. How long will your data be kept?

 

Your data will be kept by SARL TAMARINA for the time necessary to achieve the purposes mentioned in article 1 of the present document, which may be extended by legal prescription periods.

 

Concerning visitors to the Site

For more information on the retention periods of data collected through cookies installed on our site, please see our Cookies Policy.

 

Concerning customer and prospect data

  • Regarding the management of requests from prospects,
    SARL TAMARINA will keep the data collected for the time necessary to process the request and for a maximum of three (3) years from their collection or from the last contact of the prospect with SARL TAMARINA (for example, a click on a hypertext link contained in an e-mail or the date of the last telephone exchange)
  • Regarding contract management,
    Data concerning you which is necessary to the execution of a contract are kept during the duration of the contractual relationship. They can also be kept by SARL TAMARINA for the management of commercial activities for a period of three (3) years as from its collection or your last contact. After the end of the contract, SARL TAMARINA may archive some of your data to answer accounting or fiscal obligations or for evidential purposes, in case of litigation or claims, within the limit of the applicable prescription period.
  • Regarding complaint management,
    Data is only collected in cases where the complaint needs to be followed up and is only kept for the time necessary to resolve the complaint.
  • Regarding to any pre-litigation or litigation
    Processed data is deleted as soon as the dispute is settled out of court or, failing that, as soon as the corresponding legal action is time-barred. Data processed to manage a possible dispute is deleted when appeals are no longer possible against the decision made to enforce it. However, the decisions pronounced may be kept by SARL TAMARINA as a definitive archive due to its historical interest.
  • In situations where users exercise their rights under the applicable regulations on the protection of personal data

Data relating to identity documents may be kept for a period of one (1) year.

 

Concerning the data of suppliers and partners
Personal data collected within the framework of contract management and supplier relations is kept for the duration of the contractual relationship, which may be extended by legally imposed conservation periods and/or the applicable legal prescription periods.
For more information about the duration of the conservation of your data, please contact the DPO of SARL TAMARINA (see article 5.2 of this Policy).

 

 

 

  1. What are your rights and how can you exercise them?

5.1. Rights to your data

Right to access your data
From SARL TAMARINA you may obtain the confirmation that your data has or has not been processed and, if this is the case, get access to all data and information held by SARL TAMARINA.

Right to correct your data
You can easily and quickly ensure that SARL TAMARINA correct any data concerning you which is inaccurate or erroneous. You can also ask that your data be completed, if necessary.

Right to delete your data
Unless there are legal exceptions, you can ask SARL TAMARINA to delete your data as soon as possible, if you consider that the processing carried out by SARL TAMARINA on your data is no longer necessary with regard to the purposes for which they were collected.

Right to transfer your data
You may recover part of your data in an open and machine-readable format or to ask SARL TAMARINA to transmit it to another organization. This right only applies to data that you have actively and consciously provided to SARL TAMARINA (for example, data that you have entered in an online form) or data that is generated when using a service or device in the context of the conclusion or management of your contract, and that is processed in an automated manner, based on consent or the execution of a contract.

Right to object
You may object to your data being used by an organisation for a specific purpose. In this case, you must put forward reasons relating to your particular situation, except in the case of commercial prospecting, to which you may object without giving any reason. If your data is processed for commercial prospecting purposes, you may object at any time (see article 5.2 of this Policy), just as you may object at any time to the deploying of cookies (see article 10 of this Policy).

Right to limit the processing of your data
You may ask SARL TAMARINA to keep your data without being able to use it, in one of the following cases:

  • you dispute the accuracy of the data used by SARL TAMARINA,
  • you object to your data being processed,
  • in case of illegal use but you object to its deletion,
  • you need it to establish, exercise or defend legal claims.

Right to withdraw your consent to the processing of your data
In situations where processing of your personal data is based on your consent (e.g. sending our electronic commercial offers), you may withdraw your consent at any time (see article 5.2 of this Policy).
Similarly, to withdraw your consent to cookies, you may do so in the manner set out in our Cookies Policy.

The right to give post-mortem instructions
You may outline instructions for the retention, deletion and disclosure of your data after your death. These instructions set out how you wish rights to your data to be exercised after your death. You can send us these directives by sending a letter to the DPO of SARL TAMARINA (see article 5.2) mentioning ‘Post-mortem instructions’ in the subject. You can, at any time, modify or revoke these instructions.

Right to lodge a complaint with the CNIL
If you consider that your rights are not respected or that the protection of your data is not ensured in accordance with the GDPR, you may, at any time, lodge a complaint with a competent supervisory authority (in France, the CNIL), directly on the CNIL website: https://www.cnil.fr/ or by post at: CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.

5.2. Exercising your rights

To exercise one of your rights, send your request to:
dpo@janar.fr or by mail to: SARL TAMARINA – For the attention of the DPO – 6 IMPASSE DES GOELANDS – 97434 SAINT-PAUL

All requests must specify, in the subject line, the reason for the request (exercising rights of access, deletion, etc.) and the company concerned by the request. The request must also be accompanied by proof of identity and specify the address to which the reply should be sent.

SARL TAMARINA will send you an answer within a maximum of one (1) month, as from the date of reception of your request. This period can however be extended by two (2) months depending on its complexity and the number of requests.

If you consider, after having contacted SARL TAMARINA, that your rights with regard to data processing and liberties have not been respected, you can address a complaint to the CNIL.

 

 

 

  1. With whom does SARL TAMARINA share your data?

Your personal data is mainly intended for the duly authorised internal services of SARL TAMARINA.
However, and insofar as it is necessary for the achievement of all or part of the purposes referred to in article 1 of this Privacy Policy, your data may be transmitted or made accessible to service providers and authorised third parties acting as service providers, co-treatment managers or separate treatment managers.

With regard to the data we collect on the website, your data may be accessed by:

  • Authorized personnel of SARL TAMARINA in charge of reply management
  • Authorized personnel of subcontractors as soon as the contract signed between subcontractors and SARL TAMARINA mentions the obligations incumbent on said subcontractors by virtue of article 28 of the GDPR, in particular those authorized for website maintenance

In the domain of customer and prospect management, the following may have access to your data or be recipients of your data:

  • Internal services of SARL TAMARINA as well as the management of SARL TAMARINA
  • Authorised personnel of LA FINANCIÈRE JANAR in charge of accounts management of the Group, as well as personnel and third parties in charge of audits (chartered accountants, auditors, services in charge of the internal audit procedures)
  • Authorised personnel of subcontractors as long as the contract signed between subcontractors and SARL TAMARINA mentions the obligations incumbent on said subcontractors by virtue of article 28 of the GDPR, in particular those authorised for the maintenance of servers and computer stations and accounting software.
  • Judicial and legal officers within the framework of their debt collection mission, as well as service providers in charge of collection, where applicable

In the domain of supplier data management, supplier data can be transmitted:

  • To internal staff in charge of accounts management (accounting department and management of SARL TAMARINA);
  • To public bodies acting as authorized third parties for the sole purpose of fulfilling the legal obligations of SARL TAMARINA;
  • Judicial and legal officers within the framework of their debt collection mission, as well as service providers in charge of collection, where applicable;
  • To authorised personnel of subcontractors, provided that the contract signed between the subcontractors and SARL TAMARINA mentions the obligations incumbent on said subcontractors by virtue of article 28 of the GDPR.

 

  1. Is your data transferred outside the EU?

Your data is hosted on secure servers located in France. If your data is transferred outside the EU, in particular through our subcontractors, we will take particular care to ensure that they process your data in strict compliance with the regulations in force concerning the protection of personal data. In the event that the latter are located in a country that is not subject to an adequate decision by the European Commission, recognising a level of protection equivalent to that provided by the European Union, a standard contract will be drawn up in order to comply with the model established by the European Commission.

 

 

 

  1. How does SARL TAMARINA secure the processing of your data?

 

TAMARINA SARL implements all the technical, physical and organizational measures necessary to ensure the security and confidentiality of your data during the collection, processing and transfer of your data.

The infrastructure of SARL TAMARINA is protected against malicious software (virus, spyware, etc.). Physical and remote access to the servers hosting the data is regularly checked. Pen tests are carried out, as well as regular backups with restoration tests. The security of your own computer, from which you connect to our website, is your own responsibility.

In the event that SARL TAMARINA calls upon service providers to process part of your data, it undertakes to check that they present sufficient guarantees to ensure the protection of the personal data entrusted to them and to have them sign confidentiality clauses in accordance with article 28 of the GDPR.

In the event of a personal data breach, i.e. a security incident, whether malicious or not and whether intentional or unintentional, which results in the integrity, confidentiality or availability of your personal data being compromised, we undertake the following obligations:

 

Any data breach will

bring on obligations

 NO RISK SLIGHT RISK HIGH RISK
An internal document,

listed under ‘Breach register’

 X X X
Notification of the CNIL within a maximum period of 72h – X X
We will inform you

as soon as possible

 – – X

 

 

 

The ‘Breach register’ contains the following elements:

  • the nature of the breach;
  • the categories and approximate number of people concerned;
  • the categories and approximate number of files involved;
  • the likely consequences of the breach;
  • the measures taken to remedy the breach and, where appropriate, to limit the negative consequences of the breach;
  • where applicable, the justification for not notifying the CNIL or informing the people concerned.

However, and in accordance with the regulation in force, SARL TAMARINA is not bound to inform you of a breach in the following cases:

  • Your personal data is protected by measures that make it unintelligible to anyone who is not authorised to access it;
  • measures have been taken to ensure that the risk is no longer likely to materialise;
  • this communication requires disproportionate efforts for the SARL TAMARINA, not having any element allowing to contact you in order to inform you.

 

  1. Required fields

The fields marked with an asterisk in our forms are mandatory. The consequences of failing to reply are only that your request will not be taken into account. The obligation to provide the requested data is contractual, as it is necessary for the execution of the contract to which you are a party or for pre-contractual measures carried out at your request, in particular in the event of a request for information or a quote concerning our products and services.

 

  1. Cookies policy

To learn more about how we process data collected through cookies on our site, please see our Cookie Policy available here and at the bottom of each page of the site.

 

  1. Social networks

SARL TAMARINA is present on Facebook, Instagram and Linkedin.

 

  1. Privacy by Design/by Default

SARL TAMARINA commits itself to including the protection of personal data from the conception of any project, service or any other tool related to the handling of personal data, in particular the minimization of personal data, the limitation of the purposes of the collection of data, the respect of integrity and confidentiality of the data, as well as the limitation of the duration of conservation.

 

  1. Accountability

In order to respect the principle of accountability, SARL TAMARINA:

  • has adopted internal procedures to ensure compliance with regulations (an IT charter, a personal data protection charter);
  • keeps a documentary record of any processing carried out under its responsibility or that of the processor (archiving the processing register, confidentiality agreements with employees and service providers, company security policy, procedures for managing requests for access, rectification, opposition, etc.);
  • carries out impact assessments (PIAs) for processing operations presenting particular risks with regard to rights and freedoms. The objective is to provide comprehensive documentation enabling us to demonstrate compliance with the rules on data protection at any time.