Personal data policy
Who are we?
The following information is provided to you so that you can become aware of the personal data protection commitments of LMP SAS, a simplified joint stock company located at 1, Cité Paradis 75010, Paris, which acts as data controller for the processing of personal data referred to in the this document.
Personal data that we process
As part of the processing of personal data, LMP SAS collects and processes the following data:
Civility
Name
First name
Mobile phone number
Email address
The purposes and legal bases of our data processing
3.1 The purposes of our treatments
The treatments that we implement are carried out to ensure the following purposes:
management of customers, prospects and door-to-door ambassadors (i.e. service providers to whom LMP SAS subcontracts the collection of personal data); management of current offers; commercial prospecting.
3.2 The legal bases for our treatments
We only carry out data processing if at least one of the following conditions is met:
your consent to the processing operations has been obtained;
the existence of our legitimate interest which justifies that we implement the processing of the personal data concerned;
the execution of a contract between us and you requires us to process the personal data concerned.
3.3 Legitimate interests pursued
The legitimate interests that are pursued by LMP SAS may in particular consist in the management of its activity, the monitoring of its contracts and the provision of its services.
The recipients of your data
The personal data that we collect, as well as those collected later, are intended for us in our capacity as data controller.
We ensure that only authorized persons can have access to this data. Our service providers may be recipients of this data to provide the services we entrust to them. Some personal data may be sent to third parties or to legally authorized authorities in order to meet our legal, regulatory or contractual obligations.
Transfers of your data
We transfer your personal data to partners located in the United States.
Each of these transfers is governed by legal instruments in accordance with the applicable legal framework. Indeed, the United States benefits from an adequacy decision, which means that it offers your personal data a degree of protection equivalent to that which is current on the territory of the European Union.
The periods for which we keep your data
The storage periods that we apply to your personal data are proportionate to the purposes for which they were collected. As a result, we organize our data retention policy as follows:
the duration of our contractual relationship on an active basis;
3 years after your last contact for commercial prospecting operations;
5 years after the end of the contractual relationship between us on an interim basis;
10 years for your accounting and tax data.
The rights that are recognized to you
7.1 How to exercise your rights
You can exercise your rights electronically at the following address: privacy@explain.fr or by postal mail at the following address: 1, Cité Paradis 75010 Paris, providing proof of your identity by any means.
To do this, you must clearly indicate your name (s) and first name (s), the address to which you want the answer to be sent to you.
In principle, you can exercise all of your rights free of charge. However, in terms of the right of access, you may be asked to pay a reasonable fee based on administrative costs for any copy of the data that you request.
With regard to the right to information, LMP SAS will not be obliged to act on it when you already have the information you are requesting to communicate.
LMP SAS will inform you if it cannot respond to your requests.
LMP SAS wishes to inform you that failure to provide or modify your data may have consequences in the processing of certain requests in the context of the execution of contractual relationships and that your request to exercise your rights will be retained for follow-up purposes.
All the rights you have are entitled to are detailed below.
7.2 Your right to information
You acknowledge that this privacy policy informs you of the purposes, the legal framework, the interests, the recipients or categories of recipients with whom your personal data is shared, and the possibility of a data transfer to a third country or to an international organization.
In addition to this information and in order to ensure fair and transparent processing of your data, you declare that you have received additional information concerning:
the storage period of your personal data;
the existence of the rights that are recognized for your benefit and the procedures for exercising them.
If we decide to process data for purposes other than those indicated, all information relating to these new purposes will be communicated to you.
7.3 Your right to access and rectify your data
You have the right to access and have your personal data rectified, which you can exercise at LMP SAS at the following address: privacy@explain.fr or by postal mail at the following address: 1, Citét Paradis 75010 Paris.
As such, you have the confirmation that your personal data is or is not being processed and when they are, and have access to your data as well as to information concerning:
the purposes of the treatment;
the categories of personal data concerned;
the recipients or categories of recipients as well as the international organizations to which the personal data has been or will be communicated, in particular recipients who are established in third countries;
where possible, the envisaged duration of storage of personal data or, when this is not possible, the criteria used to determine this duration;
the existence of the right to request the controller to rectify or delete your personal data, the right to request a limitation of the processing of your personal data, the right to oppose this processing;
the right to file a complaint with a supervisory authority;
information relating to the source of the data when they are not collected directly from the persons concerned.
You can ask us that your personal data be, depending on the case, rectified, completed if they are inaccurate, incomplete, equivocal, out of date.
7.4 Your right to have your data deleted
You can ask us to erase your personal data when one of the following reasons applies:
personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
you withdraw the consent previously given;
you object to the processing of your personal data when there is no legal reason for such processing;
the processing of personal data does not comply with the provisions of the applicable laws and regulations;
your personal data has been collected as part of the offer of information society services to children under the age of 16.
However, the exercise of this right will not be possible when the storage of your personal data is necessary under legislation or regulations and in particular for example for the establishment, exercise or defense of rights in court.
7.5 Your right to restrict data processing
You may request the limitation of the processing of your personal data in the cases provided for by legislation and regulations.
7.6 Your right to object to data processing
You have the right to object to the processing of personal data concerning you when the processing is based on the legitimate interest of the data controller.
7.7 Your right to the portability of your data
Since May 25, 2018, you have the right to the portability of your personal data.
The data on which this right can be exercised are:
only your personal data, which excludes anonymous personal data or data that does not concern you;
the declarative personal data as well as the personal operating data mentioned above;
personal data that does not infringe the rights and freedoms of third parties, such as those protected by business secrecy.
This right is limited to treatments based on consent or on a contract as well as to personal data that you have personally generated.
This right does not include derived data or inferred data, which are personal data created by LMP SAS.
7.8 Your right to withdraw your consent
When the data processing that we implement is based on your consent, you can withdraw it at any time. We then stop processing your personal data without calling into question the previous operations for which you had consented.
7.9 Your right to appeal
You have the right to file a complaint with the CNIL on French territory, without prejudice to any other administrative or judicial remedy.
7.10 Your right to define post-mortem guidelines
You have the option of defining guidelines for the storage, deletion and communication of your personal data after your death to a trusted third party, certified and responsible for enforcing the will of the deceased, in accordance with the requirements of the applicable legal framework.
