This privacy notice is provided in the following format.

1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
11. QUERIES, REQUESTS OR CONCERNS

1. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide when you sign up to our newsletter or request a service.

This website is not intended for children, and we do not knowingly collect data relating to children unless required to provide a service you have requested.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Renestance is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). Our contact details are contact@renestance.com and +33 411 932 599.

Renestance is the controller and responsible for this website.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data: includes your first name, last name and email address, if you have signed up for our newsletter.

Contact Data: which includes your phone number and address, collected either directly or by a third party processor (Paypal, Stripe, Eventbrite, etc.) if you have made an electronic payment.

Personal Data: that may include your profession, citizenship, arrival date in France; copies of passports, birth certificates, marriage/divorce certificates and other official documents; copies of insurance policies, leases, house deeds, car registration, driving records; the names, birth dates and citizenship of members of your immediate family. This data is only gathered when required to deliver the specific service that requires it, such as applying for a residency permit, registering a vehicle or some other administrative task necessitating this type of documentation.

Financial Data: which may include your bank account details (RIB, IBAN, etc.) or copies tax returns and financial statements. As with Personal Data above, this data is only collected and used when required to deliver a specific service you have booked. Your bank card details would only be gathered if you provide them expressly for us to make a specific payment to a specific third party on your behalf. The data will not be stored longer than necessary to make the requested payment. If you make an online payment to Renestance, you will give your data to the third party (Paypal, Stripe, etc.), but this financial data will not be given to us, only your contact details and confirmation of the amount that you paid.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including:

Directly: You may give us your identity, contact, personal and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• sign up for our newsletter
• make an inquiry via our website
• make a booking over the phone

Indirectly: Your contact details will be provided by the third party payment gateway (PayPal, Stripe, Eventbrite) if you make a purchase via our website.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party (as in the case of booking a service) or to take steps at your request before entering into such a contract.

Legitimate Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience, such as in sending you a newsletter when you have signed up for it. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Dennelle Taylor Nizoux at Renestance.

Comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data when it relates to a service that you have booked, or in which you have expressed an interest. We do not do use third parties to send marketing information. You have the right to withdraw consent for us to contact you by emailing contact@renestance.com.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Promotional offers from us

You will receive newsletters from us only if you have requested them. If you have purchased a product or service or have requested information from us, we may periodically send promotional emails about new products, special offers or other information, which we think you may find interesting using the email address you have provided.

Third-party marketing

We do not share your personal data with any company for marketing purposes (and would not do so in the future without your express consent).

Opting out

You can ask us to stop sending you newsletters at any time by following the opt-out links on the emailed newsletter sent to you or by contacting contact@renestance.com.

Where you opt out of receiving these newsletters, this will not apply to personal data provided to us as a result of a service transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please visit our website.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties Service Providers (acting as processors) in the EEA or outside it who provide: e-shot mailing services (Mailchimp), financial transaction services (Paypal, Stripe), client relationship databases (Zoho), or file storage (Google Drive). All of these organisations have certified their compliance to the EU-US Privacy Shield framework.

External Third Parties who are professional partners of Renestance, providing services directly or indirectly to you. These include translators, accountants, lawyers, language institutes, banks, mortgage lenders, real estate agents, etc. These third parties may also include administrative offices of the French government.

External contractors working for Renestance to deliver your contracted service.

External contractors working for Renestance and managing the newsletter subscription lists or website.

Professional advisers acting as processors including accountants, lawyers, bankers, auditors and insurers based in the EEA who provide services to Renestance and may encounter your data in our client database.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our external third parties, such as the ones listed above in the first point of paragraph 5, are based outside the European Economic Area (EEA) so their processing of your personal data will mean that there will be a transfer of data outside the EEA. However, we have ensured that such third parties are:

• GDPR compliant
• that they take security of your private data seriously.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where data is collected from you over the phone or by email we limit access to your personal data to those employees and contractors who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will hold your name and address details if you have contracted a service with us, so that you can do so again in the future.

Renestance will only store personal data and financial data (points 2 and 3 of section 2) on a temporary basis, until the service you contracted that required it has been completed. In some circumstances, you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances, we may render your personal data anonymous (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable, i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact dennelle@renestance.com.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

From 25 May 2018 there will be changes in data protection laws and we will then be able to respond to some of your requests (for example, a request for the transfer of your personal data). We are still working towards getting our systems ready for some of these changes.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection officer, Dennelle Taylor Nizoux at dennelle@renestance.com.

If this does not resolve your issue to your satisfaction, you have the right to lodge a complaint.