This Privacy and Cookies Policy describes our policies and procedures on the collection, use and disclosure of your Personal Data when you use the Service and tells you about your privacy rights
We use your Personal Data to provide and improve the Service. By using the Service, you understand that your Personal Data are collected and used for specific purposes of processing in accordance with this Privacy Policy.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
(a) "Business" for the purpose of the CCPA, means the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
(b) "CCPA" means the California Consumer Privacy Act, which is a Californian law relating to data confidentiality.
(c) "Company" (referred to herein as either the "Company", "We", "Us" or "Our"), means BeFC, a simplified joint-stock company registered in the Grenoble Trade and Companies Register under number 883 544 009 and having its registered office at 570 rue de la Chimie - 38610 Gières (France). .
(d) "GDPR" means the EU General Data Protection Regulation 2016/679, which is a regulation in EU law on data protection and privacy.
(e) "Consumer" , for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
(f) "Data Controller" , for the purposes of the GDPR, means the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
(g) "Device" means any electronic device that can access the Service such as a computer, a cell phone or a digital tablet.
(h) "Personal Data" means any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
(i) "Sale" , for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
(j) "Service" means the Company’s services accessed via the Website.
(k) "Usage Data" means data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
(l) "Website" means the domains www.befc.co.uk/ www.befc.us/ www.befc.fr/ www.befc.global/ befc.kr/ www.befc.jp
(m) "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
(a) Personal Data provided by You
On the data collection forms available on the Website, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. This Personal Data may include, but is not limited to:
(b) Usage Data that We collet and use
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
(c) Use of Your Personal Data
The Company may use Personal Data for the following purposes:
a. To provide and maintain Our Service, including to ensure fluid browsing on the Website, to guarantee the operation of the Service and to store user interface preferences (including with respect to the use of cookies).
b. To send You the Company’s newsletter, where You have subscribed to receive such newsletter.
c. To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
d. To manage Your requests: To attend and manage Your requests to Us.
e. To manage Your job applications: We may use Your Personal Data to process the job applications You have submitted to Us and conduct any job interviews necessary to assess Your suitability for the job and Your professional skills.
f. For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
g. For audience measurement and analytics purposes: We may use Your Personal Data to measure the audience of the Service, which includes data analysis, identifying usage trends, and to evaluate and improve our Service, products, services and your experience on the Service.
h. To interact with social media via the Website: We may use Your Personal Data to allow interactions with social media or other external platforms directly from the pages of the Website, via the social media buttons included in the Website.
i. To manage any dispute relating to the use of the Service, including any pre-litigation and litigation.
(d) Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Your Personal Data will then be archived to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
More particularly, we retain Your Personal Data for the following retention periods:
| Purpose of processing | Retention period |
|---|---|
| Provide and maintain the Service | 1 year as from the data collection |
| Send You the Company’s newsletter | 3 years as from the last contact the person |
| Provide You with news, special offers and general information | 3 years as from the last contact the person |
| Manage Your requests | 5 years as from the closure of the request |
| Manage Your job applications | "2 years as from the last contact with the candidate |
| When the person is recruited, the information collected as part of the application process are then included in the HR files." | |
| Business transfers | 3 years as from the last contact with the person |
| Audience measurement and analytics purposes | 25 months as from the data collection |
| Interact with social media via the Website | 1 year as from the data collection |
| Manage any dispute relating to the use of the Service | "Pre-litigation: retention until expiry of the limitation period applicable to the action |
| Litigation: retention until a final decision is obtained and enforced" |
(e) Transfer of Your Personal Data
Your Personal Data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that Your Personal Data may be transferred to — and maintained on — servers located outside of Your country, in other jurisdiction where the data protection laws may differ than those from Your jurisdiction.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
(f) Disclosure of Your Personal Data
(i)Service providers
As part of the different purposes of processing, the Company is likely to use certain service providers, including more particularly IT service providers, that will only process Your Personal Data on behalf and according to the instructions of the Company.
(ii)Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
(iii)Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
(iv)Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
(g) Security of Your Personal Data
We are committed to protecting Your Personal Data. To this end, we take all necessary physical, technical and organisational measures to prevent any unauthorised or unlawful processing, as well as any accidental loss, destruction or deterioration of Your Personal Data.
Cookies are small text files that are placed on Your terminal (telephone, computer, tablet, etc.) by the Company and its partners when You use the Website, in order to provide a better service to you, to help keep your account safe, and to generally improve our Website and Service. By extension, and within the meaning of this cookie policy, the term "cookie" more generally covers all tracking technologies used on the Website and which collect information relating to Your browsing and Your interactions on the Website.
In some cases, the cookies used on the Website may collect Personal Data about You.
Where Personal Data is collected by the Company acting as Data Controller, it will be processed in accordance with the provisions of this Privacy Policy.
Where third party cookies enable Our partners to collect and process Personal Data about You, We invite You to consult their privacy policy to find out the conditions under which Your Personal Data will be processed.
(a) Categories of cookies
Several categories of cookies are likely to be placed on your terminal equipment: essential cookies strictly necessary for the operation of the Website, audience measurement and analytical cookies intended to measure the performance of the Website and social media cookies which allow You to interact with Your social networks.
Strictly Necessary and Functional Cookies.
Strictly Necessary and Functional cookies are essential to providing and maintaining the Website and the Service and cannot be turned off. They provide necessary security settings, help You use the Website’ features and the Service as expected and allow Us to remember choices You make about the kind of experience You want on the Website to provide You with a more personalized experience (including remembering Your cookie consent preferences).
Performance and Analytics Cookies.
Performance and Analytics cookies are subject to Your consent and help Us to learn how users access and use the Website to help improve their performance and design – for example, the number of users on the Website, how long they stay on the Website for, what parts of the Website they visit and the types of browsers or devices used to access the Website.
If You do not consent to the deposit of these cookies, We will not be able to take into account Your browsing for the purposes of Our performance statistics and audience measurement and to improve the Service accordingly.
We use the following partners to monitor and analyze the use of the Service:
(i)Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service.
As part of the use of some of the Google Analytics cookies, your data is transferred to the United States. This transfer is framed by the execution with Google of Standard Contractual Clauses of the European Commission.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please view the Google Privacy & Terms.
a.Hotjar
Hotjar is a critical tool that We use to understand the behavior of Our users on the Website and identify any pain points where they might be getting stuck.
For more information on the privacy practices of Hotjar, please view Hotjar’s privacy policy.
Social Media Cookies.
Social Media cookies are subject to Your consent and used on the Website to make the Website more user-friendly and interactive, by enabling You to interact with social media (Facebook, Instagram, LinkedIn, YouTube). These cookies may process data relating to the content shared via social networks and the fact that You have an account on a social media. These functions are based on third-party applications integrated into the Website. The social media providing such an application button is likely to identify You and track Your browsing on the Website thanks to this button, even if You did not use this button when visiting the Website.
If You do not consent to the deposit of these cookies, the social media will not be able to identify You and track Your browsing on the Website.
We use the following partners to provide social media cookies:
(b) Management of the cookies
(i)Management of the cookies on the Website
When you access the Website, a cookies banner is displayed, allowing You to accept or refuse all cookies, or to express Your choice by category of cookies subject to Your prior consent (essential and functional cookies are activated by default). As long as You have not given Your consent, these cookies are deactivated by default and are not installed on Your terminal.
You can change Your cookie preferences at any time by clicking on the Cookie management tab accessible from any page of the Website.
(ii)Management of the cookies on Your browser
You may configure Your browser to systematically reject the deposit of cookies.
For the management of cookies and Your preferences, the configuration of each browser is different. Please consult the conditions of Your browser to determine how to modify Your preferences to the deposit of cookies:
(iii)Retention period of Your cookies’ preferences
Your choices concerning the acceptance or refusal of cookies on the Website are kept for six (6) months, at the end of which You will be asked again to express Your consent or refusal to the deposit of cookies.
(a)Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
More particularly, Your Personal Data is processed in accordance with the following legal bases for each purpose of processing:
| Purpose of processing | Legal basis |
|---|---|
| Provide and maintain the Service | Legitimate interest of the Company to provide the Service |
| Send You the Company’s newsletter | Consent |
| Provide You with news, special offers and general information | Legitimate interest of the Company to send communications on similar products or services provided by the Company |
| Manage Your requests | Legitimate interest of the Company to send communications on similar products or services provided by the Company |
| Manage Your job applications | Execution of precontractual measures |
| Business transfers | Legitimate interest of the Company to restructure its activity |
| Audience measurement and analytics purposes | Consent |
| Interact with social media via the Website | Consent |
| Manage any dispute relating to the use of the Service | Legitimate interest of the Company to ensure its defense in the event of a dispute |
(b)Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights
You have the right under this Privacy Policy, and by law if You are within the EU, to:
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us by mail: Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
(a)Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
(i)Category A: Identifiers.
Examples: Name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Collected: Yes.
(ii)Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, email address, telephone number, employment, bank account number, credit card number, debit card number, or any other financial information (We use third party payment providers). Some personal information included in this category may overlap with other categories.
Collected: Yes.
(iii)Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
(iv)Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
(v)Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
(vi)Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
(vii)Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
(viii)Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
(ix)Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: Yes.
(x)Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
(xi)Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
(b)Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
(c)Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CPRA/CCPA), which may include the following examples:
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
(d)Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CPRA/CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
(e)Sale of Personal Information
As defined in the CPRA/CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CPRA/CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
(f)Your Rights under the CPRA/CCPA
The CPRA/CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
-The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
-The right to request. Under CPRA/CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
-The categories of personal information categories sold
-The categories of personal information categories disclosed
-Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-Debug products to identify and repair errors that impair existing intended functionality.
-Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. -Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
-Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
-Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
-Comply with a legal obligation.
-Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
-Denying goods or services to You
-Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
-Providing a different level or quality of goods or services to You
-Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
We cannot respond to Your request or provide You with the required information if we cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
(a)Links to third-party websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
(b)Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
(c)Contact Information
If you have any questions about this Privacy and Cookies Policy, You can contact us by email: privacy@befc.fr