Legal notice, privacy policy and cookies

The www.wenold.com website, hereinafter referred to as the Site, is the property of WeNold, SAS, a simplified joint stock company, registered in the Nanterre Trade and Companies Register under number XXX XXX XXX, with registered offices at 9, rue du 8 Mai 1945 - 92700 Colombes.

The Site's publication director is Mr Pierre-Yves Fabre, in his capacity as Chairman and Founder of WeNold.

The Site is hosted by Simplébo, a simplified joint stock company, whose head office is located at : 

Head office: GRAPSTOR

43, boulevard Voltaire - 75011 Paris

Telephone: 01.84.17.49.76

RESPONSIBILITY

WeNold undertakes to use its best efforts to ensure that users can access the Site at all times. WeNold takes the utmost care to ensure the quality and reliability of the information contained on the Site.

WeNold cannot guarantee the accuracy, completeness or topicality of the information published on its Site, nor can it guarantee that it will always function properly or be completely secure. The information contained in the Site is provided for information purposes only, without any explicit or implicit guarantee of validity, completeness or timeliness, for the sole general information of users.

It cannot be held responsible in the event of the site being unavailable for any reason whatsoever. Nor can it be held responsible for errors, lack of availability of information and/or the presence of viruses on its site.

WeNold shall not be liable for any damage, temporary or permanent, to the visitor's computer system or for any loss or damage (including, but not limited to, loss of data or profits) suffered as a result of :

• Access to or navigation on the Site,
• The use of information contained in the Site,
• Copying, viewing or any other use of the Site that would give rise to litigation or collection proceedings.

Nor shall WeNold be liable for any indirect damage resulting from fraudulent intrusion by a third party leading to modification of the information published on the Site, or for any financial or commercial loss, loss of programs or data in the user's information system or otherwise, even if WeNold has been made aware of the possibility of such damage occurring. The user acknowledges having read this legal notice and undertakes to comply with it. The use of this information is the sole responsibility of the user.

INTELLECTUAL PROPERTY

The general structure of the Site, as well as each of the elements that make it up independently, in particular texts, data and graphic elements, whether animated or not, constitute works that are protected as such by intellectual property laws, in particular by copyright, designs and models and trademark law, and by international treaties.

The general structure of the Site, as well as each of the elements of which it is composed independently, in particular the texts, data and graphic elements of the Site, may not under any circumstances be modified, reproduced, displayed, presented, distributed or used for public or commercial purposes. Any person downloading or collecting information from the Site has only a private, personal and non-transferable right of use. The information collected may only be reproduced once, either on paper or digitally. Any use of the information collected must mention the source.

Protected works reproduced on the Site that do not belong to WeNold have been the subject of express prior authorization to reproduce on the part of the holder of the rights.

Any total or partial representation of the Site or any of its components without the express authorization of WeNold is prohibited and constitutes an infringement punishable by articles L.335-2 et seq. of the French Intellectual Property Code.

The databases appearing on the Site are protected by articles L.341-1 et seq. of the French Intellectual Property Code, and any extraction or reuse, qualitatively or quantitatively substantial, of the contents of the databases is punishable.

The trademarks and logos appearing on the Site are registered trademarks of WeNold or third parties. Any reproduction, imitation or use, in whole or in part, of these distinctive signs without express authorization and in violation of the prohibitions set forth in Articles L.713-2 et seq. of the French Intellectual Property Code shall engage the responsibility of the author.

Other distinctive signs, in particular corporate names, trade names, brand names, domain names reproduced on the Site are the property of the WeNold company or third parties and any reproduction without express authorization is likely to constitute usurpation engaging the responsibility of its author on the basis of article 1240 of the Civil Code modified by order n°2016-131 of February 10, 2016.

WeNold assumes no obligation to monitor any information the user may submit to the WeNold website.

In this regard, the User warrants that any information or material (the term "material" refers to any projects, files or other attachments sent) or comments other than personal data, which the User may transmit to WeNold through the WeNold website, does not infringe any third party intellectual property right or other applicable law.

Any such information, material or comments will be treated as non-confidential and non-proprietary. By submitting any information, material or comments, the user grants WeNold all necessary rights, unlimited and irrevocable, to use, perform, display, modify and transmit such information, material or comments, including any suggestions, concepts or know-how.

WeNold reserves the right to use such information, elements or comments in any way it chooses.

LINKS

Hypertext links to other sites, mainly to WeNold partners' sites, have been expressly authorized in advance. As links are provided for the personal convenience of Internet users, WeNold has no control over these sites and accepts no responsibility for them. The pages remain the sole responsibility of their owners.

The reproduction of a page of the Site in a frame not belonging to WeNold or the insertion of a page belonging to WeNold in the page of a site not belonging to WeNold is prohibited. WeNold reserves the right to remove links from its site to third-party sites.

Site users may not establish a link to this Site without the prior written consent of WeNold.

MODIFICATION

WeNold reserves the right to modify the content of this legal notice at any time and without prior notice.

APPLICABLE LAW

This Site is governed by the laws of France.

The user acknowledges having read this legal notice and undertakes to comply with it.

1. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy sets out our approach to the processing of your personal data that we lawfully collect from you or that third parties lawfully provide to us, and the purposes of such processing.

It also describes your rights with regard to our processing of your personal data, in particular under the General Data Protection Regulation (Regulation (EU) 2016/679).

This Privacy Policy also informs you about how we delete, update or transfer your personal data and/or how we give you access to such data.

This Privacy Policy is intended to enable you to make informed decisions about using the Site and our Services and/or to understand how we will treat your personal data in connection with our Services or if you apply for a job with us. We therefore invite you to take a few moments to read them.

Please note that this Privacy Policy applies solely to the use of personal data that we have collected from you.

2. WHO WE ARE WHAT DO WE DO?

WeNold is a consulting and services company registered with the Nanterre trade register under SIREN number XXX XXX XXX, with its head office at 9, rue du 8 Mai 1945 - 92700 Colombes.

WeNold provides human resources consulting and services, as well as other complementary consulting and services to its customers, in accordance with the applicable laws in the countries where it operates.

WeNold specializes in business and management consulting, with a focus on career transition support for experienced managers and executives (45+):
>Balances: Personal - Professional - Retirement - Patrimonial - Provident - Health.
>Transmission of their human capital to their successors and existing teams: corporate DNA and memory, key know-how and renowned experience.
>Build, enhance and implement the life project that suits them best.

3. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the application of your rights under this Privacy Policy, please contact us by sending an e-mail to the following address: pyfabre@wenold.fr or by post to the following address: SAS WeNold 9, rue du 8 Mai 1945 - 92700 Colombes, or by telephone on: 01 84 20 41 05.

4. WHAT PERSONAL DATA DO WE COLLECT?

We may collect personal data from you in the course of our business, including when you use our Site, when you contact us or request information from us, when you choose our services or as a result of the relationship you may have with one or more of our team members and customers.

The main purpose of processing your personal data is to :

• Check your identity,
• Provide our Services and Advice,
• Manage recruitment,
• Improve, develop and market new Services,
• Respond to your requests on the Site or in connection with our Services,
• Solve queries,
• Comply with any applicable law, court order or other legal process, and the requirements of regulatory authorities,
• Execute the contracts that bind us to you,
• Preserve our rights, property or safety or those of third parties, including those of our other customers and users of the Site or our Services,
• And meet any other obligation required by law.

In order to achieve these objectives, we may process the following personal data:

If you are a visitor to the Site :

- Your last name, first name, title and function,

- Your contact details, including the company that employs you, your e-mail address and, if applicable, your social network details,

- Demographic data, such as your business address, preferences and interests,

- Any other information relevant to the provision of Services (professional experience, training, etc.).

If you are an individual customer benefiting from our Services or an individual prospect:

- Your last name, first name, title and function,

- Your contact details, including the company that employs you and your e-mail address,

- Payment data,

- The information you provide to us in connection with the provision of the Services we perform for you and which depends on the nature of the instructions you have given to WeNold,

- Relevant information required by "Know Your Customer" or anti-money laundering regulations, and as part of procedures for taking on new customers,

- This may involve proof of the source of funds, at the start of the relationship and sometimes regularly throughout our relationship with customers, and may be requested and/or obtained from third parties,

- Verification sources may include the documentation we request from prospects and/or through the use of online sources,

- Information you give us to participate in meetings or events, including your dietary choices that may reveal information about your health or religious beliefs,

- Any other information relevant to the provision of Services.

The WeNold company primarily serves companies that pass on their instructions (i.e. legal entities) and are therefore not in principle data subjects within the meaning of the European Union's General Data Protection Regulation.

However, in the course of transmitting these instructions, personal data may be transmitted to us (e.g. personal data relating in particular to executives or members of staff of our existing or potential customer companies, personal data of a stakeholder or a supplier or buyer, including data relating to their advisors or staff or persons with similar functions, as the case may be).

If you are an individual whose personal data we process in connection with our provision of Services (including individual customers or business customers), we may process various types of personal data depending on the Services provided, as described above.

This may include personal data relating, in particular, to one of the executives or members of staff of our existing or potential client companies, a stakeholder or a supplier or buyer, including personal data relating to their councils, other councils or their staff or similar functions, as the case may be.

For example, in the case of recruitment consultancy assignments, we may receive and process information about your professional experience, recommendations and references, their contact details, and the dates of your various jobs.

We may also process personal data relating to third parties on the basis of instructions from our own customers or other natural or legal persons connected with the matter to which our provision of Services to our customer relates.

This is a non-exhaustive list which reflects the varied nature of the personal data processed as part of WeNold's human resources consulting and services.

For existing and potential customers, we also collect information that enables us to market our products and services that may be of interest to you. To this end, we collect the following data:

• Your last name, first name, title and function,
• Other information of a professional nature, such as your job title and the company you work for,
• Areas or subjects that interest you,
• Additional information that may be collected, such as events you attend, and possibly your dietary choices if you choose to communicate them to us, on the understanding that they may give us indications about your health or your religious convictions, although this is not the purpose.

5. HOW DO WE USE YOUR PERSONAL DATA?

We may use your personal data for the following purposes:

Our Consulting and Services

We collect and store the personal data that you voluntarily provide to us during your use of the Site and/or the Services in order to enable us to perform the Services.

Please note that our General Terms and Conditions also apply to all Consulting and Services provided by us.

What is our legal basis?

We need to process your data in order to fulfil our obligations under any contract we may have entered into with you. We may also use your personal data to fulfil our legitimate interest in providing you with the best possible customer service.

Customer service

Our Site and online services use several user interfaces to enable you to request information from us about our Services, including electronic forms and a telephone service.

In each case, we may ask for your contact details, as well as other personal data relevant to your Service request.

This information will be used to respond to your requests.

What is our legal basis?

We use your personal data as part of our legitimate interest in providing you with the best possible customer service.

Business management and legal compliance

We use your personal data for the purposes of our business and to comply with the law:

• Compliance with our legal obligations (including to any regulatory authority or competent regulatory body in relation to the provision of human resources and IT services, know-your-customer or anti-money laundering obligations, conflict of interest obligations or similar obligations, but not limited to maintaining compulsory insurance),

Assert our rights in court,

• Protect the rights of third parties,
• And as part of a commercial transaction.

What is our legal basis?

Our use of your personal data as part of a commercial transaction, to enforce our legal rights, or to protect the rights of third parties is based on our legitimate interest or that of a third party. For all other purposes described in this section, we are obliged to use your personal data in order to comply with the legal obligations applicable to us.

We will not process any particular category of data except where permitted by applicable law or with your explicit consent.

Communications

We carry out the following marketing activities using your personal data:

• By post
• By e-mail

We use the data we observe about you from interactions with our Site, e-mail communications sent to you and/or as part of the Services (see Customer Information and Analysis below for further information on the data collected and how it is collected) to send you communications.

What is our legal basis?

The use of your personal data for prospecting purposes is based on our legitimate interest in developing our relationship with you.

We will only send you communications if you have given us your consent to do so, or unless you object, where permitted by law.

Customer information and analysis

We analyze your contact information in conjunction with other personal data that we observe about you from your interactions with our Site, communications that we send to you by e-mail and/or as part of our Services.

Where you have given us your consent (where such consent is required by law), we use cookies, tracking files and other technologies to collect personal data on the computer and software you use to access the Site or on your cell phone. The following may be collected:

• An IP address to track Site traffic,
• A session identifier to track usage statistics on our Site,
• Information about your personal or professional interests, demographic statistics, experiences with our products and contact preferences.

Our web pages contain "cookies", "web beacons" or "pixel tags" ("Beacons"). Beacons allow us to track the receipt of e-mail addressed to you, to count users who have visited a web page or opened an e-mail and to collect other types of aggregated information. As soon as you click on an e-mail containing a Beacon, your details can be cross-referenced with the source e-mail and the corresponding Beacon.

In some of our e-mails, we use a "clickable URL" linked to certain websites administered by us or on our behalf.

The use of this information enables us to estimate the effectiveness of our content and the way visitors use our Site and Services. In this way, we know which pages of our Site most attract our visitors, which parts of our Site are of most interest, and what type of offers our registered users like to consult.

We use this information for prospecting and customer follow-up purposes.

What is our legal basis?

Where your data is not anonymous, we use your personal data to fulfil our legitimate interest in providing you and our other customers with the best products and services.

If we wish to use your personal data for purposes other than those listed above or if we change the purposes listed above, we will inform you using your contact details where available.

6. WHAT IS OUR LEGAL BASIS?

In general, we need to use your personal data:

• Or to perform obligations arising from any contract between us,
• Or to meet our or a third party's legitimate interest in providing the best possible Services,
• Or to comply with our legal obligations.

7. WITH WHOM WE SHARE YOUR PERSONAL DATA

WeNold is a human resources consulting and services company and any information we collect or that you provide to us may be shared with and processed by any of the entities for the purposes stated above only after obtaining your express consent.

We may also share your personal data with the following categories of third parties where necessary:

• Our professional advisors, such as lawyers and accountants,
• Public or regulatory authorities,
• Insurance companies offering professional liability coverage,
• Regulatory bodies/tax authorities/company registries,
• Third parties to whom we outsource certain services, including, in particular, document processing and translation services, confidential document destruction services, computer system providers or software publishers, IT support service providers, information and document storage service providers,
• Third parties we call upon to provide services on behalf of our customers, such as coaches, graphologists, technical experts, appraisers, etc,
• Third-party service providers to assist us with customer data analysis, e.g. Google Analytics
• Third-party postal or private messaging service providers who help us deliver our postal prospecting campaigns to you, or provide you with documents relating to a file.

Please note that this is not an exhaustive list and that other circumstances may lead us to share your personal data with other parties in order to provide the Services as efficiently as possible.

8. OUR USE OF COOKIES AND SIMILAR TECHNIQUES

Please be aware that our Site uses certain Beacons, tracking files and other technologies. We invite you to visit our sites and services in private browsing if you wish to disable them.

Please consult our Cookies Policy to find out more about the cookies we use and how to manage and delete them.

9. THIRD-PARTY CONTRACTORS AND OTHER DATA CONTROLLERS

As indicated above, we may use third-party processors to provide the Services, who may process your personal data on our behalf and in accordance with our instructions.

These include, for example, document processing and translation services, confidential document destruction services, IT system providers or software publishers, IT support providers, document and information storage providers. We carry out the necessary checks and verifications and put in place contractual documentation with any subcontractor we use, in order to guarantee the appropriate processing of personal data by the latter, in compliance with our legal and regulatory obligations.

In addition, we may appoint external data processors where necessary to provide Services (for example, accountants, lawyers or other third-party experts). Where we do so, we will comply with our legal and regulatory obligations regarding personal data, in particular, by putting in place appropriate safeguards.

10. COUNTRIES TO WHICH WE TRANSFER YOUR DATA

In order to provide you with the Services, we may need to transfer your personal data to countries other than those where you provided the data.

If you are located within the European Economic Area (EEA), please be aware that, where necessary to carry out the Services, we may transfer personal data to countries outside the EEA (for example in connection with recruitment outside the EEA).

In such cases, we ensure that appropriate safeguards are in place to provide you with an adequate level of protection for your personal data in accordance with European Commission directives.

11. RETENTION PERIOD OF YOUR PERSONAL DATA

In respect of visitors to the Site and our online services, we will retain personal data for at least three years from the date of our last interaction with you and in accordance with our obligations under the EU General Data Protection Regulation or any equivalent law applicable elsewhere in the world or for longer periods if we are required to do so in accordance with our regulatory obligations or professional indemnity obligations.

In relation to the provision of Services to a customer, we will retain personal data for the duration of the contractual relationship and for at least six years from the date of our last interaction with the customer and in accordance with our obligations under the EU General Data Protection Regulation or equivalent law applicable elsewhere in the world or for longer periods if we are required to do so in accordance with our regulatory obligations or professional indemnity obligations. We may then destroy these files without notice and without incurring any liability.

We may delete personal data that is only used in the short term, for example for specific prospecting campaigns.

12. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to ensuring the security of the personal data provided to us and have implemented information systems security policies and appropriate technical rules and measures to protect the personal data under our control against unauthorized access, modification, use, disclosure, unlawful destruction or accidental loss.

All our partners, employees, consultants, workers and data processors (i.e. the persons who process your personal data on our behalf, for the aforementioned purposes), who have access to personal data and are involved in the processing thereof, are required to respect the confidentiality of said data.

13. ACCESS TO YOUR DATA AND OTHER RIGHTS YOU MAY HAVE

You have the following rights with regard to the personal data we hold about you:

Your right of access

At your request, we will inform you whether we are processing your personal data and, if necessary, provide you with a copy of this data (together with certain other information). We may charge a reasonable fee for any additional copies you request.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.

Your right to erasure

You may ask us to delete or withdraw your personal data in certain cases, for example when we no longer need it or in the event of withdrawal of your consent (as the case may be). If you have the right to have your data deleted and we have made it public, we will take reasonable steps, taking into account available technology, to inform third parties who process the data whose deletion you have requested.

Your right to restrict processing

You may ask us to "block" or restrict the processing of your personal data in certain cases, for example if you dispute the accuracy of your personal data or if you notify us of your objection.

Your right to data portability

You have the right, in certain cases provided for by the applicable regulations, to obtain the personal data you have given us (in a structured, commonly used, machine-readable format) and to re-use it elsewhere or to ask us to transfer it to a third party of your choice.

Your right to object

You can object to the processing of your personal data, and we will stop it:

• If such processing is based on our legitimate interest or that of a third party to process your personal data, unless the processing meets our overriding legitimate interests,
• Or if your personal data is processed for prospecting purposes.

Your rights in the context of automated decision-making and profiling

You have the right not to be subject to a decision that is based on exclusively automated processing, including profiling, producing legal effects or effects that significantly affect you, unless the profiling is necessary for the conclusion or performance of a contract between you and us or for compliance with our legal obligations.

Your right to withdraw your consent

If we process your personal data on the basis of your consent, you have the right to withdraw this consent at any time, without this affecting the lawfulness of the processing based on consent carried out prior to the withdrawal.

Your right to a digital will

You can provide general or specific instructions concerning the fate of your personal data after your death.

Your right to lodge a complaint with a supervisory authority

If you have a concern about any aspect of our privacy practices, including how we have handled your personal data, you can contact the relevant supervisory authority. (CNIL - www.cnil.fr)

Please note that some of these rights may be restricted where we have a compelling interest or legal obligation to continue processing the data, or where the data cannot be disclosed due to our professional obligations.

14. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

The Site contains links to other sites whose information collection practices may differ from ours. Visitors are advised to consult the privacy policies of these other sites. WeNold has no control over the information communicated to or collected by these third parties.

15. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal data, we will update this Privacy Policy periodically to reflect any changes in the way we use your personal data.

We may also make modifications to comply with changes in current legislation and regulations. Wherever possible, we will notify you of any significant changes. However, we encourage you to review this Privacy Policy regularly to learn how we use your personal information.