In our Group we are committed to protect and respect your privacy and we do so in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th, 2016.
This notice applies to the use of your personal data in our Business Relationship Management. It explains who we are and how you can contact us. It also explains when and why we process personal information, what your individual rights are with respect to the personal data we process about you, how we use your personal data, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Notice applies to our sales, marketing and customer contract fulfilment activities.
Who are we?
We are COMEP, with registered offices at Zae Du Pont Neuf 16130 Salles D'angles, France, and are part of Sidel Group. If you have any questions or remarks, our Data Privacy Manager can be contacted by email: privacy@Sidel.com.
Collection and use of personal Information
We may process your personal information for legitimate business purposes to perform direct sales, direct marketing and customer service. We can process personal information:
- When you or your organization use our products/services, or we receive information from a legitimate source, including an existing contact, that these could be of interest to you;
- When you interact with us in person, through correspondence, by phone, by social media, or through our websites;
- When we collect personal information from other legitimate sources, such as third-party data aggregators, marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is processed we typically make an assessment, ensuring that there is an established mutual interest between you and COMEP.
We may collect:
- Contact information like your name, phone number, title and (business) email address, in addition to your company’s name and contact information or language preferences;
- Feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails.
We do not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.
We process personal information for the following purposes:
- Sending you marketing communication, which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent;
- Sending you information about the products and services that you have purchased from us;
- To perform direct sales and marketing activities in cases where legitimate and mutual interest is established;
- Providing you content and venue details on a webinar or event you signed up for;
- To reply to a ‘Contact me’ or other web forms you have completed on one of our websites;
- To follow-up on incoming requests (customer support, emails, chats, or phone calls);
- If applicable, to provide access to our Customer Support portal and/or Sidel Services Online (SSO) portal;
- To perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar activities. The contract may be with COMEP directly or COMEP associated companies, or with a partner of COMEP;
- Contacting you to conduct surveys about your opinion on our products and services;
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below.
We may disclose your personal information for legitimate purposes in the following circumstances to:
- Tetra Laval Group entities, other Sidel entities, joint ventures, subcontractors, vendors or suppliers who perform services on our behalf, or to customers, for the aforementioned purposes;
- A newly formed or acquiring organization if COMEP is involved in a merger, sale or a transfer of some, or all, of its business;
- Distributors, agents, sub-contractors and other associated organizations with the purpose of them providing services to us, or you, on our behalf;
- Any recipient, if required by law, or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
When information is disclosed we ensure that appropriate contractual processing agreements are in place to safeguard the privacy of your data.
Your personal information may be transferred outside of the country where your data was collected, including to countries that do not provide the same level of protection for your personal information. COMEP is committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we will assure that adequate protection exists either through appropriate contractual arrangements or as required by law. You may obtain a copy of the adequate protection for data transfers by requesting it to: firstname.lastname@example.org
Your data is processed through Microsoft Dynamics 365 a centralized Customer Relationship Management system (CRM), information security (ISO 27001) certified. To make sure only the designated Sidel employees can have access to your data, a Single-Sign-On (SSO) protocol is set up and governed by the Sidel IT Security team.
Our legal basis for processing your personal data:
We process your personal data to help us maintain and develop our business relationship. The legal basis therefore is either based on:
We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between COMEP and the individual person has been identified. A copy of such legitimate interest assessment can be provided upon your request sent to email@example.com. This legal basis is primarily related to our sales and marketing activities. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes. This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
You have the following rights with respect to your personal data:
- The right to request that COMEP corrects your personal data if inaccurate or out of date;
- The right to request that your personal data is deleted when it is no longer necessary for COMEP to retain such data;
- The right to withdraw any consent to personal data processing at any time. For example, unsubscribe to receive e-marketing communications:
- If you want to unsubscribe, please use the link to manage your subscriptions included in our communication. Please note that in this case you may still receive system messages and administrative communications from Sidel Group, such as order confirmations or system messages.
- The right to request that COMEP provides you with (a copy of) your personal data.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
- The right not to be subject to automated decision making.
Any query about your Privacy Rights should be sent to privacy@Sidel.com.
Changes to this Privacy Notice
COMEP reserves the right to amend this Privacy Notice at any time. The applicable version will always be found on our websites. We encourage you to check this Privacy Notice occasionally to ensure that you are in agreement with any changes. If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.
Handling Privacy Concerns
If you have any questions about this notice, or if you believe that your personal information is not handled in accordance with the applicable law or this notice, please contact either:
- Your COMEP sales or marketing representative, or;
- Sidel Group’s Data Privacy Manager through privacy@Sidel.com.
You can also lodge a complaint with the national Data Protection Authority which is competent for your place of residence.
Thank you for your trust and business with COMEP.
Data Privacy Manager | Sidel Group | e-Mail: privacy@Sidel.com