Personal Data Protection Policy

The purpose of the Personal Data Protection Policy is to inform you that your personal data is processed when you browse the Site published by Eco TLC. We hereby inform you of the nature of the personal information that is collected, how we use it, with whom we share it, how we strive to protect it, how you can access and/or correct your information and lastly, how you can contact us if you have any questions.  

The purpose of this document is to also communicate all information made mandatory by Article 32 of the French Data Protection Act and by Article 13 of EU Regulation EU 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals in regards to the processing of personal information and the free circulation of this information (“RGPD”). 

Lastly, attention is drawn to the fact that we may need to modify this document in particular to ensure that it meets new regulations or to adapt it to our practices.  

 

Article 1 – Processing Manager

Information collected via the different Personal Data collection forms on the Site are processed by Eco TLC in its capacity as Processing Manager.

 

Article 2 – Personal Data Collection by Eco TLC

Personal Data designates any and all information related to an identified or identifiable individual, i.e. a person who can be directly or indirectly identified.

Eco TLC collects and processes the Users’ personal data via forms created for this purpose on the Site.

The personal data collected by Eco TLC is as follows: first name, surname, email address and job title and function. 

By browsing on the Site, Eco TLC is also likely to collect login data (IP address, logins, login name, terminal identifiers, login identifiers, information, on date and time, etc.) and internet data (Cookies, trackers, browsing data, audience measurements, etc.)

It is compulsory to complete non-optional fields. If these have not been completed requests cannot be processed by Eco TLC.  

 

Article 3 – Purpose(s) of Personal Data processing and legal bases

Eco TLC is an eco-organisation approved by the State and whose main mission of general interest is to provide information and assist stakeholders in the CHF industry on the most environment-friendly production methods. It’s mission is to encourage the collection and recovery of clothing, household linen and footwear waste.  

As an eco-organisation approved by the public authorities, Eco TLC is obliged to report back to public authorities on the performance of initiatives undertaken, in particular in terms of information provided and awareness-raising measures.  

To measure the effectiveness of its initiatives and the communication of its Site’s contents, Eco TLC is obliged to gather User Personal Data and analyse the browsing behaviour and choices. Given its mission of general public interest, Eco TLC thereby has a legitimate interest in collecting personal data for these purposes. 
 

Personal Data may be used by Eco TLC to: 

  • Create Personal Accounts for Users and allow users to have access to the Site’s contents. The legal basis for processing this information is legitimate interest.

  • Send newsletters by email with the legal basis of this processing being legitimate interest and the right to refuse.

  • Send surveys/requests by email with the legal basis of this processing being legitimate interest and the right to refuse.

  • Analyse browsing and choices by the User on the Site in order to perform profiling for content customisation purposes: the legal basis of this processing being consent.

  • Compile statistics: the legal basis being legitimate interest.

  • Process all User questions/claims the legal basis being legitimate interest. 

  • Manage an individual’s right to exercise his/her rights (access to information, correction, deletion and portability of information): Personal Data processing is mandatory by law

  • Justify in the event of a dispute, that legal and regulatory obligations have been met: Personal Data processing is made obligatory by law.

 

Article 4 – Communications sent by Eco TLC

4.1 Communication categories sent by the User 

Users are likely to receive the following types of communications:  

  • Emails 

Following registration on the Site you will receive a confirmation email. The receipt of this information is not linked to the choices that you expressed in relation to newsletters.

  • Eco TLC Newsletters 

Following your registration on the Site, if you did not refuse receiving these, you may receive Eco TLC newsletters by email. In particular, these communications enable you to be kept updated with the latest news from Eco TLC and the latest, environmentally-friendly production new methods. You can refuse to receive emails and newsletters at any time. 

  • Surveys/requests for opinions 

We may also contact you via email for your opinion using questionnaires. You may also refuse these surveys or requests for opinions directly in the email that is sent or by informing us.

 

4.2 How to exercise your choices?  

At any time you can refuse that your personal data be used as described hereafter:  

  • When you register on the Site using a tick box; 

  • By directly contacting Eco TLC by email, telephone or by post;

  • By clicking on the link that appears in each email sent to unsubscribe yourself from the newsletter/notifications.

  

Article 5 - The recipients or categories of recipients receiving Personal Data

Your Personal Data is intended for Eco TLC.

It may also be communicated to subcontractors with whom Eco TLC works in order to carry out services for the above-mentioned purposes. Eco TLC ensures that its subcontractors comply to data protection requirements. 

Eco TLC may also provide your personal data when it is required to:

  • comply with law (or a subpoena or court order);

  • comply with legitimate requests from public or governments authorities; 

  • prevent a misdemeanor or carry out an inquiry, for example in the event of fraud or identity theft;

  • protect Eco TLC’s rights, property or security from Users or third parties.

 

Article 6 – Transferring data to a country outside the EU

It is understood by data transfer, all communication, copying or movement of Personal Data intended for processing in a third party country or any data to which a third party outside of France may have access.  

In the event that your data is transferred to Eco TLC partners located outside of the European Union, Eco TLC guarantees: 

  • Having collected all the required authorisations from the competent authorities to perform said transfer.

  • Having managed this transfer by standard European Commission contractual clauses or internal company rules (Binding Corporate Rules) or ad hoc contractual clauses that the CNIL (French National Data Protection Commission) has previously recognised as guaranteeing an adequate level of protection of privacy and the fundamental rights of individuals. 

In the event of transfer to the United States, Eco TLC undertakes to verify if the receiving entity of said data has complied with the “Privacy Shield”, a self-certification mechanism for companies established in the United States. This mechanism has been recognised by the European Commission as offering an adequate level of protection for personal data transferred by a European entity to one established in the United States.

 

Article 7 - The rights of individuals

You have the right to access, rectify, delete your personal data and to its portability.

You can also request that the processing of your data is limited or refuse that it be processed.  

You have the right to communicate your instructions to Eco TLC concerning your personal data in the event of your death.

You can exercise your rights with Eco TLC: 

Eco TLC reserves the right to request the settlement of “reasonable costs” related to any administrative costs borne for supplying information if your request is clearly unfounded or unreasonable. Eco TLC shall endeavour to meet your request within the deadlines required by the GDPR.

To protect your privacy and ensure your security, Eco TLC will also undertake suitable measures to check your identify before granting you access to your personal information or to correct, modify or delete it. All requests shall be accompanied by a copy of your personal ID.

In the event that your rights have not been observed, you may file a claim with the CNIL (French Data Protection Commission).  

 

Article 8 – Data Security and Confidentiality 

You Data security:

We implement organisational and technical security measures to guarantee the confidentiality and integrity of personal data. In this regards, the purpose of administrative, organisational, technical and physical precautions is to protect your personal data from loss, theft, non-authorised access, non-authorised transmission and all modifications or deletion. In all cases, Eco TLC shall implement security measures that are suitable for the type of data collected.

Data that is collected is confidentially saved and is protected to a very high level of security. The servers on which this data is saved comply with security standards currently in force. They are protected against digital and physical attacks.

All of the Site’s pages on which you are required to communicate Personal Data are made secure in https. However, despite all efforts made, Eco TLC cannot guarantee that this protection is infallible due to unavoidable risks that occur during the transmission of personal data.

Security of data transmitted to our external service providers:

We always select service providers with the greatest of care and attach the greatest importance in the way that your data is made secure. Therefore, these service providers act on Eco TLC’s orders only and at no time use your data other than for carrying out the services that we have entrusted to them. A contract is systematically signed between Eco TLC and its selected service providers in which we request that the appropriate technical, physical, logical and organisational measures are implemented in order to ensure the confidentiality and the security of processed Personal Data and thereby prevent it from being deformed, damaged or that non-authorised third parties access it. 

 

Article 9 – Period that Personal Data is kept 

Eco TLC only keeps Personal Data for the time required for the operations for which it was been collected and complies with the regulations in force and the following policy on the period that data is kept:

 

Personal Data Categories

 

Period that data is kept

 

 

Identification Data required to process
       the different services offered by the Site        
(e.g. Creation of a personal account)

 

The time required to accomplish
the objective pursued during
data collection

Identification data for the purpose
of sending Newsletters
 

 

Up to such a time when consent is
     withdrawn and 3 years maximum as from       
the date of the last activity

 

Data concerning information
requests or claims

 

3 years from the date that it was collected
or the last contact or the end of the
commercial relationship

  

Data proving a right or a contract

 

5 years as from the collection of the data
or the last contact or the end
of the commercial relationship

 

 

Some data may be kept for an additional period in order to manage claims and/or disputes as well as meet legal or regulatory requirements or to respond to any requests made by authorised authorities. Data shall be deleted when Eco TLC receives information on the death of the person.

 

Article 10 – Cookies 

When browsing the Site, information on your browsing behaviour may be recorded in files known as “Cookies” installed on your computer, depending on the choices that you made concerning Cookies, and that you can modify at any in time.

Cookies allow the Site visited to thereby manage, save and recover information about your browsing behaviour as well as obtaining technical communications on the Site’s browsability.  

For all additional information, please refer to our Cookie Policy