Privacy Policy

ELBE LB attaches great importance to the protection of privacy and personal data.

In accordance with the European Regulation 2016/679 of April 26, 2016, and the amended French Data Protection Law of January 6, 1978, ELBE LB makes strong commitments to the persons concerned.

All information collected on the Site and/or in the context of contractual relations is recorded by ELBE LB, the data controller.

This Policy applies to all data collected and processed in the context of commercial, contractual, one-off, or ongoing relations, whether with customers, partners, users, installers, assistants or beneficiaries.

1. Data collected

We collect personal data transparently and explicitly.

To this end, ELBE LB collects:

data necessary for contractualization (surname, first name, e-mail address, bank details, etc.) expressly requested on the Site or within the framework of commercial relations,

connection data, regardless of the medium through which ELBE LB services are used,

data from telephone recordings of calls made to the telephone numbers indicated on the Site,

data necessary for the execution and follow-up of contracts, regardless of the nature of the contracting party

2. Purposes of data processing

Each data collection is carried out specifically for explicit purposes that are clearly indicated on the page of the Site where the data is collected. In this respect, please note that :

As regards contractualization with ELBE LB, the purposes of data collection and processing are (i) contractualization, follow-up and execution of the contracts entered into, (ii) all pre-litigation and litigation contractual management (including the constitution and use of evidence in the event of a possible dispute concerning the commercial transaction) and (iii) the improvement of products or services. The legal basis for this processing is the performance of a contract (article 6.1.b of the European Regulation);

As regards the number and expiry date of your bank details, the purpose of collection and processing is, in addition to that referred to in the previous indent, the possibility of paying more quickly for subsequent purchases if you have expressly agreed to this. The legal basis for this processing is consent (article 6.1.a of the European regulation).

As regards the collection of information relating to browsing on a device, the purposes of collection and processing are (i) the improvement of products or services, and (ii) the provision of personalized recommendations. The legal basis for this processing is the performance of a contract (article 6.1.b of the European regulation);

As regards the recording of telephone calls, the purposes of collection and processing are (i) employee training and assessment, and (ii) product or service improvement. The legal basis for this processing is the performance of a contract (article 6.1.b of the European regulation);

Regarding any optional request to a data subject, on the website or by virtue of a law, the purpose is the one referred to on the support (for example, commercial canvassing) and is, unless an exception is expressly referred to, subject to consent, which may be withdrawn at any time. The legal basis for this processing is consent (article 6.1.a of the European regulation).

ELBE LB reserves the right to create additional and/or complementary means of collection. In this respect and in accordance with the regulations, ELBE LB will specify the purposes specific to the processing concerned on the data collection page.

ELBE LB does not make any fully automated decisions based on your personal data.

3. Data processing recipients

There are several types of data recipients:

ELBE LB teams, in particular,

subcontractors for the execution of the processing concerned,

ELBE LB partners (only for matchmaking requests). With regard more specifically to the collection of opinions and the evaluation of products and services, ELBE LB uses the services of the external company [...] to collect your opinions. In order to carry out this processing, ELBE LB shares with [...] your surname, first name, email address and reference number. If you would like to know more about how [...] processes your data, you can read [...]'s privacy policy here.

Transmissions of personal data to recipients (whatever their legal nature, subcontractor, data controller or simple recipient) are carried out in a secure manner and in application of an agreement between ELBE LB and each recipient. ELBE LB undertakes to ensure that each recipient is aware of the guiding principles of personal data protection and is subject to them in application of the law and/or a specific contract.

4. Data storage

ELBE LB takes care store your personal data within the European Union with hosting companies that are subject to European regulations on the protection of personal data. Your personal data is thus stored by ELBE LB in complete safety and in compliance with regulations.

However, as far as the call center and related operations and processing are concerned, ELBE LB has taken all guarantees in terms of compliance with regulations protecting privacy and personal data by signing the European Commission's standard contractual clauses with this subcontractor.

The retention periods applied by ELBE LB comply with the regulations applicable on the date hereof, namely :

for contract/subscription data: 3 years from contract termination;

for banking data :

for the constitution and use of evidence in the event of a dispute concerning the commercial transaction: a maximum of 13 months from the date of debit;

for re-use of contact details for subsequent purchases: up to the card's expiry date;

for data relating to the creation of the account, a period of 3 years from the termination of the account. In this respect, it is recalled that ELBE LB considers that, notwithstanding any formal termination, this period runs from a period of inactivity of 12 consecutive months on the account;

for telephone recordings, a period of 6 months from the recording;

for the supply of personalized content and advertising, 12 months from the supply of said content;

for other purposes, the period strictly necessary for the pursuit of the purpose.

ELBE LB reserves the right to create additional and/or complementary means of collection. In this respect, ELBE LB will specify, in accordance with regulations, the retention periods specific to the processing concerned on the data collection page.

5. Your rights

You have the following rights:

right of access to your personal data;

the right to rectify your personal data if it is inaccurate or incomplete;

the right to restrict the processing of your personal data in accordance with Article 18 of the European Data Protection Regulation;

right to erase your personal data if :

they are no longer necessary for the purposes for which they were collected or otherwise processed; or

you withdraw your consent for processing subject to consent (e.g. commercial prospecting); or

you validly object to the processing; or

they have been processed unlawfully; or

as required by law.

the right to object on legitimate grounds,

the right to portability of your data,

the right to define directives concerning the fate of your personal data after your death and,

for processing based on consent, to withdraw your consent at any time.

To exercise one or more of these rights, please provide proof of identity and contact the person in charge of data protection at EVALUTOO [email].

6. Contact

If you have a complaint, you can contact the CNIL (www.cnil.fr ).

You can register on the “opposition au démarchage téléphonique” list at www.bloctel.gouv.fr/