Legal notice

4.1 Purpose

Groupe Special Lines will not divulge to third parties any personal data that you may communicate to it by means of electronic mail. It will only be used for the purpose of responding to you in the most efficient way possible. In accordance with the “Law n°2004-801 of 6 August 2004, Law on the protection of individuals with regard to the processing of personal data and amending Law n°78-17 of 6 January 1978 on information technology, files and freedoms”, you have the right to access, modify, rectify and delete personal data concerning you.

This Policy is established by Groupe Special Lines SAS located at 6-8 rue Jean Jaurès in 92800 Puteaux, registered under the number 820 232 163; (hereinafter referred to as “the data controller”)
The purpose of this Policy is to inform visitors to the website hosted at the following address: https://www.groupespeciallines.fr/ (hereinafter referred to as the “Website”) of the manner in which data is collected and processed by the data controller.

This Policy is part of the controller’s desire to act transparently, in compliance with its national provisions, such as Law No. 2018-493 of 20 June 2018, promulgated on 21 June 2018, amending the Data Protection Act in order to bring national law into line with the European legal framework, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “General Data Protection Regulation”).

The data controller pays particular attention to the protection of the privacy of its users and therefore undertakes to take reasonable precautions to protect the personal data collected against loss, theft, disclosure or unauthorised use.

Personal data” is defined as all personal data relating to the user, i.e. any information that directly or indirectly identifies the user as a natural person.

If the user wishes to react to any of the practices described below, he/she may contact the controller at the postal address or email address specified in the “contact data” section of this Policy.

4.2 What data do we collect?

The Site is not intended to receive confidential information from you. As a result, and with the exception of the personal data referred to above (Paragraph – 4.1 Purpose), any information, in whatever form – document, data, graphic, question, suggestion, concept, remark or other – that you communicate to Us on the Site will in no way be considered confidential. Consequently, its simple transmission by you gives us the right to use, reproduce, distribute, modify or transmit it for the purpose of processing your request.

The data controller collects and processes the following personal data according to the methods and principles described below

its domain (automatically detected by the controller’s server), including the dynamic IP address ;
his/her e-mail address if the user has previously revealed it, for example by sending messages or questions on the website, communicating with the controller by e-mail, participating in discussion forums, accessing the restricted part of the website with identification, etc. ;
all information concerning the pages that the user has consulted on the website;
any information that the user has given voluntarily, for example in the context of information surveys and/or registrations on the website, or by accessing the restricted part of the website with identification.
It is possible that the data controller may also collect non-personal data. These data are qualified as non-personal data because they do not directly or indirectly identify a specific person. It may therefore be used for any purpose, for example to improve the website, the products and services offered or the advertising of the controller.
In the event that non-personal data are combined with personal data in such a way that identification of the data subjects is possible, such data shall be treated as personal data until such time as it is impossible to link them to a specific person.

4.3 Collection methods

The controller collects personal data in the following ways:

4.4 Personal data is collected and processed solely for the purposes mentioned below:

• to ensure the management and control of the execution of the services offered;
• sending and follow-up of orders and invoices;
• sending promotional information on the products and services of the controller;
• sending promotional material;
• to answer the user’s questions;
• to carry out statistics;
• to improve the quality of the website and of the products and/or services offered by the data controller;
• to send information on new products and/or services of the data controller;
• with a view to commercial prospecting;
  to enable better identification of the user’s interests.

The data controller may need to carry out processing operations that are not yet provided for in this Policy. In this case, it will contact the user before re-using his/her personal data, in order to inform him/her of the changes and give him/her the possibility, if necessary, to refuse this re-use.

4.5 Legitimate interests

Some of the processing operations carried out by the data controller are based on the legal basis of its legitimate interests. These legitimate interests are proportionate to the respect of the user’s rights and freedoms. If the user wishes to be informed of the details of the purposes founded on the legal basis of legitimate interests, he/she is recommended to contact the controller (see point on “contact data”).

4.6 Retention period

As a general rule, the controller shall only keep personal data for as long as is reasonably necessary for the purposes for which they are to be used and in accordance with legal and regulatory requirements.

A customer’s personal data is kept for a maximum of 10 years after the end of the contractual relationship between the customer and the controller.

At the end of the retention period, the controller shall make every effort to ensure that the personal data has been made unavailable and inaccessible.

4.7 Application of rights

For all the rights listed below, the data controller reserves the right to verify the identity of the user for the application of the rights listed below.

This request for additional information shall be made within one month of the user submitting the request.

4.8 Access to data and copying

The user may obtain free of charge written communication or a copy of the personal data concerning him/her that have been collected.
The controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the user.
Where the user makes such a request electronically, the information shall be provided in a commonly used electronic form, unless the user requests otherwise.
Unless otherwise provided for in the General Data Protection Regulation, the user will be provided with a copy of his or her data no later than one month after receipt of the request.

4.9 Right of rectification

The user may obtain, free of charge, as soon as possible and at the latest within one month, the rectification of personal data that are inaccurate, incomplete or irrelevant, as well as the completion of such data if they are found to be incomplete.
Unless otherwise provided for by the General Data Protection Regulation, the request for application of the right to rectification shall be processed within one month of its submission.

4.10 Right to object to processing

The user may at any time, for reasons relating to his/her particular situation, object free of charge to the processing of his/her personal data, when
the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail (in particular where the data subject is a child).
The data controller may refuse to implement the user’s right to object if it establishes compelling legitimate grounds for the processing which override the interests or rights and freedoms of the user, or for the establishment, exercise or defence of legal claims. In the event of a dispute, the user may lodge a complaint in accordance with the “Complaints and claims” section of this Policy.
The user may also, at any time, object, without justification and free of charge, to the processing of personal data concerning him/her when his/her data is collected for the purpose of commercial prospecting (including profiling).
Where personal data are processed for scientific or historical research or statistical purposes in accordance with the General Data Protection Regulation, the user has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out in the public interest.
Save for the exceptions provided for in the General Data Protection Regulation, the controller is obliged to respond to the user’s request as soon as possible and at the latest within one month and to give reasons for its response if it intends not to comply with such a request.

4.11 Right to limit processing

The user may obtain the limitation of the processing of his/her personal data in the following cases
when the user disputes the accuracy of a data item and only for as long as it takes for the controller to check it;
when the processing is unlawful and the user prefers the limitation of processing to erasure;
when, although no longer necessary for the purposes of the processing, the user needs it for the establishment, exercise or defence of legal claims;
for the time necessary to examine the merits of a request for opposition made by the user, in other words for the time necessary for the controller to check the balance of interests between the legitimate interests of the controller and those of the user.
The controller will inform the user when the processing restriction is lifted.

4.12 Right to erasure of data (right to be forgotten)

The user may obtain the deletion of personal data concerning him/her, when one of the following reasons applies

the data are no longer necessary for the purposes of the processing;
the user has withdrawn his consent to the processing of his data and there is no other legal basis for the processing
the user objects to the processing and there is no compelling legitimate reason for the processing and/or the user exercises his specific right to object in relation to direct marketing (including profiling);
the personal data have been processed unlawfully;
the personal data must be erased in order to comply with a legal obligation (under Union or Member State law) to which the controller is subject;
the personal data have been collected in the context of the provision of information society services to children.
However, erasure of data is not applicable in the following cases

when the processing is necessary for the exercise of the right to freedom of expression and information ;
where processing is necessary for compliance with a legal obligation to process laid down by Union law or by the law of the Member State to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
where the processing is necessary for reasons of public interest in the field of public health;
where processing is necessary for archival purposes in the public interest, for scientific or historical research purposes or for statistical purposes and provided that the right to erasure is likely to render impossible or seriously compromise the achievement of the purposes of the processing in question;
where the processing is necessary for the establishment, exercise or defence of legal claims.
Unless otherwise provided for by the General Data Protection Regulation, the controller is obliged to respond to the user’s request as soon as possible and at the latest within one month and to give reasons for not responding to such a request.

4.13 Right to “data portability

The user may, at any time, request to receive free of charge his/her personal data in a structured, commonly used and machine-readable format, in particular with a view to transmitting them to another data controller, where:

the data processing is carried out by automated means; and
the processing is based on the user’s consent or on a contract concluded between the latter and the data controller.
Under the same conditions and in the same way, the user has the right to obtain from the data controller that personal data concerning him/her be transmitted directly to another data controller, insofar as this is technically possible.

The right to data portability does not apply to processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4.14 Recipients of data and disclosure to third parties

The recipients of the data collected and processed are, in addition to the data controller itself, its employees or other subcontractors, its carefully selected commercial partners, located in France or in the European Union, and who collaborate with the data controller in the context of the marketing of products or the provision of services.

In the event that data is disclosed to third parties for direct marketing or commercial prospecting purposes, the user will be informed in advance so that he/she can choose to accept the transfer of his/her data to third parties.

Where such transfer is based on the user’s consent, the user may withdraw his or her consent for this specific purpose at any time.

The data controller complies with the legal and regulatory provisions in force and will ensure in all cases that its partners, employees, subcontractors or other third parties with access to this personal data comply with this Policy.

The data controller discloses the user’s personal data in the event that a law, legal proceedings or an order from a public authority makes such disclosure necessary.

No transfer of personal data outside the European Union is made by the controller.

4.15 Security

The controller shall implement appropriate technical and organisational measures to ensure a level of security of the processing and of the data collected appropriate to the risks presented by the processing and the nature of the data to be protected. It shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks to the rights and freedoms of users.

The controller always uses encryption technologies that are recognised as industry standards within the IT sector when transferring or receiving data on the website.

The data controller has put in place appropriate security measures to protect and prevent the loss, misuse or alteration of information received on the website.

In the event that the personal data under the control of the controller should be compromised, the controller will act promptly to identify the cause of the breach and take appropriate remedial action.

The data controller shall inform the user of this incident if required by law.

4.16 Complaints and complaints

• If the user wishes to react to any of the practices described in this Policy, it is advisable to contact the controller directly.

  The user may also lodge a complaint with his/her national supervisory authority, the contact details of which can be found on the official website of the European Commission: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

  In addition, the user may lodge a complaint with the competent national courts:

  On the website of the CNIL:
  in certain specific cases, by means of the online complaint teleservice;
  In other cases not covered by the teleservice, through the “Need help” service.
  By post, by writing to : CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

4.17 Contact data

For any questions and/or complaints relating to this Policy, the user may contact the data controller:

• By e-mail: contactdpo@groupespeciallines.fr
• By post: 6-8 rue Jean Jaurès 92800 Puteaux.

4.18 Modification

The data controller reserves the right to modify the provisions of this Policy at any time. The modifications will be published directly on the website of the data controller.

4.19 Applicable law and jurisdiction

This Policy is governed by the national law of the place of the controller’s principal place of business.

Any dispute relating to the interpretation or execution of this Policy shall be subject to the jurisdiction of that national law.

This version of the Policy is dated 30/09/2022

5. Limitations and liability

Groupe Special Lines endeavours to ensure, to the best of its ability, the accuracy and updating of the information published on the Site, the content of which it reserves the right to correct at any time and without notice. However, Groupe Special Lines cannot guarantee the accuracy, precision, updating or exhaustiveness of the information made available on the Site.

Consequently, and with the exception of direct damage resulting from a gross or intentional fault of Groupe Special Lines, the latter declines all responsibility :
– for any imprecision, inaccuracy or omission concerning the information available on the Site ;
– for any damage resulting from fraudulent intrusion by a third party, leading to a modification of the information or elements made available on the Site
– and more generally for all damage, direct or indirect, whatever the cause, origin, nature or consequences, even if Groupe Special Lines has been advised of the possibility of such damage, caused by reason of (i) access by any person to the Site or the impossibility of accessing it, (ii) the use of the Site, including all deteriorations or viruses which could infect your computer equipment or any other property, and/or (iii) the credit given to any information coming directly or indirectly from the Site.

The elements of the Site or of any other site are provided “as is” without any guarantee of any kind, implicit or explicit. Groupe Special Lines does not offer any guarantee, implicit or explicit, relating, without limitation, to their market value or their suitability for a given purpose.

6. Availability of the website

You acknowledge that (i) it is technically impossible to provide the Website free of all defects and that GROUPE SPECIAL LINES cannot commit to this; (ii) defects may lead to the temporary unavailability of the Website; and that (iii) the functioning of the Website may be affected by events and/or elements that GROUPE SPECIAL LINES does not control, such as for example, means of transmission and communication between you and GROUPE SPECIAL LINES and between GROUPE SPECIAL LINES and other networks. GROUPE SPECIAL LINES and/or its suppliers may, at any time, modify or interrupt, temporarily or permanently, all or part of the Website to carry out maintenance operations and/or improvements and/or modifications to the Website. GROUPE SPECIAL LINES is not responsible for any modification, suspension or interruption of the Website.

7. Information on the products

The information contained and distributed on the Website may contain direct or indirect references to products, programmes and services of GROUPE SPECIAL LINES which are not announced or available in certain countries or certain regions or which may be offered under a different brand name and which may be subject to different regulations and conditions of use depending on the country. Such references do not imply that Groupe Special Lines intends to sell these products, programmes or services in your country. Please consult your local GROUPE SPECIAL LINES subsidiary or your GROUPE SPECIAL LINES business partner for information regarding the products, programs and services which may be available to you.

8. Jurisdictional Provisions

The Site and its content are governed by French Law, and any possible dispute relating to it will be subject to the jurisdiction of the French courts.

9. Additional legal information

9.1 Graphic design and development of the site: AxeNet web agency (site), 25 avenue de la Constellation 95800 Cergy

9.2 Groupe Special Lines is an insurance brokerage company – S.A.S. with capital of EUR 100,000 in which Groupama Rhône Alpes Auvergne holds more than 10% of the shares and voting rights│ 820 232 163 R.C.S. Paris Intermediary registered with the ORIAS under No. 16003981 (http://www.orias.fr) │ Under the supervision of the Autorité de Contrôle Prudentiel et de Résolution, 4 Pl. de Budapest, 75009 Paris

9.3 Director of Publication and Editor: Mr Paul-Henri Lecointre

9.4 Site hosting: The website is hosted by Axenet – www.axenet.fr