Personal Data Protection Policy

In the course of its business, FINEGAN (“we” or “us”) collects and processes information, some of which is referred to as Personal Information. FINEGAN is committed to respecting the privacy of individuals, and uses data responsibly and confidentially, for a specific purpose and in accordance with applicable data protection regulations, including the European General Data Protection Regulation.

The present policy, describing the processing of Personal Data on the website www.finegan.lu is applicable to all users of the same website and can be updated at any time by FINEGAN. The date of the most recent update will appear on this page. 

This Policy applies to “you” for one or more of the following reasons:

– You are a “Customer”: we have or have had a direct relationship with you as a customer, an individual. You have, in this case, signed one or more contracts with us 

– You are a “Prospect”: your Personal Data is processed even though you do not have a contractual relationship with us

1. Nature of the data collected

The different categories of Personal Data collected within the framework of the services offered on our website are notably the following:

  • The identification data transmitted by the user of the website and in response to a request for service: first name, last name, email, possibly telephone number if you wish to be contacted by another means
  • Data collected automatically: During your visits, once you have given your consent, we may collect “web analytics” type information relating to your browsing, the duration of your visit, your location, your browser type and version. For more information, see our Cookie Usage Policy.
  • Data relating to your professional career: curriculum vitae, training, professional experience, skills assessment.

You are not obliged to answer all the questions asked.

The mandatory nature of the information is indicated by the presence of an asterisk. Failure to provide this information will make it impossible for FINEGAN to process your request.

Personal Data is only collected with the user’s mandatory consent. This consent is validly collected (buttons and/or check boxes), free, clear and unequivocal.

2. Purposes and legal bases

Personal Data is collected for the following purposes described below. For each of the purposes, we have also specified the reason that makes the processing of Personal Data necessary:

PURPOSES OF THE PROCESSING

REASONS MAKING THE PROCESSING NECESSARY

To answer your questions sent by

e-mail, via contact form

FINEGAN has a legitimate interest in answering the questions raised in order to better serve its customers and prospects 

To manage and administer your solicitations/

registrations

To manage and administer your solicitations/registrations To enforce the Terms of Use of the website that govern your interactions with the services offered on the website 

To better understand users’ preferences and
to offer them tailored Products or Services

FINEGAN has a legitimate interest in knowing its prospects/customers better

To send information about our offers, news and events, surveys and polls (newsletters, invitations and other publications)

Your explicit consent resulting from your positive registration to receive such information or to subscribe to such Services. FINEGAN has a legitimate interest in publicizing its Products or Services and those of its companies withing the Group 

To ensure the security of the website

FINEGAN has a legitimate interest in securing its website

To conduct statistical analysis of traffic
to the website 

FINEGAN has a legitimate interest in improving the performance of its website

FINEGAN may be subject to legal and regulatory obligations to disclose data and may also have a legitimate interest in using it to defend itself in the event of legal action

FINEGAN may be subject to legal and regulatory obligations to disclose data and may also have a legitimate interest in using it to defend itself in the event of legal action

Depending on the purpose of the processing, Your Personal Data may be processed by authorized FINEGAN personnel (marketing, sales, customer relations, administrative, HR and functional support departments of FINEGAN). Your Personal Data may also be processed by third party service providers within the European Union acting on behalf of FINEGAN, including the service provider in charge of the Website. 

There will be no transfer of Personal Data outside the European Union. 

3. Duration of data retention

We will only retain your Personal Data for as long as is necessary for the fulfillment of the purposes described above or to meet our legal obligations.

The retention periods applicable to Personal Data collected on the website are as follows:

  • as long as your User account remains active;
  • as long as we remain in contact with you through our promotional activities and three (3) years after the last interaction, unless you object when you receive one of our marketing messages;
  • the period of time required by applicable law.

4. Exercise of rights 

You may, at any time, under the conditions and within the limits provided for by law, exercise these rights concerning your Personal Data:

  • Access and obtain a copy of your Personal Data as well as information on how the Personal Data is processed and its legal basis;
  • Rectify your Personal Data when it is erroneous and the right to complete it if it is incomplete;
  • Delete your Personal Data when it is no longer necessary to achieve the purposes for which it was collected or processed;
  • Limit the processing of your Personal Data when:
    • Their accuracy is disputed;
    • The processing is unlawful but you object to the deletion of your Personal Data;
    • We no longer need your Personal Data but they are still necessary for the establishment, exercise or defense of legal claims;
  • Request the portability of your Personal Data into a machine-readable format if our processing is based on your consent or the performance of a contract with us;
  • Give general or specific instructions on how your Personal Data should be processed and used after your death ;
  • Withdraw your consent to the processing of your Personal Data if such processing is based on your consent, for example in connection with Newsletters. Such withdrawal will not affect the lawfulness of the processing based on consent carried out prior to the withdrawal of consent;
  • To object to any processing for the purpose of prospecting.


In addition to the above rights, you have the right to object to any processing of your Personal Data based on FINEGAN’s legitimate interest, unless FINEGAN has compelling legitimate grounds that may prevail.

You also have the right to lodge a complaint with your local data protection supervisory authority, the Commission Nationale de l’Informatique et des Libertés (CNIL) 3 Place de Fontenoy 75007 Paris, France. 

If you have any questions about this Policy or if you wish to exercise any of your rights or contact our Data Protection Officer (DPO), please contact us at the following e-mail address 

dpo@finegan.fr

or by mail A/R to this address

FINEGAN Group, Group Data Protection Officer
10 avenue de la Grande Armée
75017 PARIS