I. GENERAL INFORMATION
3. Users can contact the Administrator in the following way:
A. by letter to the following address: 66, avenue des Champs-Elysées, Paris– 75008
B. via e-mail: firstname.lastname@example.org;
4. Personal data is any information relating to an identified or identifiable natural person. The scope of this type of data includes, among others, name, surname, address, telephone number and e-mail address. Information that cannot be traced back to an identified or identifiable person (such as statistical data) is not considered personal data.
II. APPLICABLE LAW ON PERSONAL DATA PROTECTION AND CONFIDENTIALITY OBLIGATION
1. NOVA POST FR SAS is subject to the provisions of Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC as well as other relevant national data protection legislation.
2. NOVA POST FR SAS provides postal services, which is why it is obliged to observe the confidentiality of correspondence and ensure the security of shipments, in accordance with the provisions of the Postal and Electronic Communications Code as amended and supplemented.
III. INFORMATION PROTECTION
1. NOVA POST FR SAS by applying appropriate technical and organizational measures, makes every physical and technical effort to protect personal data against loss, damage, disclosure to not authorized personal, alteration or improper use.
2. All notifications regarding the protection of personal data are registered and explained in detail and analyzed in accordance with applicable law.
IV. RIGHTS OF DATA SUBJECTS
1. The data subject has the right to:
A. receive the information and have an access to data concerning him/her (the right of access by the data subject under art. 15 GDPR);
B. rectify his/her personal data that are incorrect and update his/her data (the right to rectify data, Article 16 GDPR);
C. request the deletion of his/her personal data (the right to delete data under art. 17 GDPR);
D. requests to cease processing (the right to limit processing under art. 18 GDPR);
E. request the transfer of data to another administrator (the right to transfer data under art. 20 GDPR);
F. objecting to the processing of his/her personal data (the right to object under art. 21 GDPR).
V. WITHDRAWAL OF CONSENT TO THE PROCESSING OF PERSONAL DATA AND MECHANISM OF WITHDRAWAL OF CONSENT
1. In the case the basis for data processing is the consent of the data subject, we inform you that this person has the right to withdraw consent at any time. The declaration of withdrawal of consent is made by providing the Administrator by e-mail or postal delivery, in accordance with the data provided, a statement in this regard.
2. Receiving of such a declaration does not affect the lawfulness of the prior processing of personal data.
3. Withdrawal of consent to the processing of personal data is ineffective to the extent necessary for the proper provision of services or provisions of an ongoing contract, including complaint proceedings. In this case, the withdrawal of the above-mentioned consent becomes effective upon resignation from services, termination of the contract or complaint process.
4. Despite the effective withdrawal of consent to the processing of data, the Administrator is entitled to process them to the extent necessary for:
A. pursuing claims related to the concluded contract;
B. fulfillment of the legal obligation incumbent on the Administrator;
C. performance of a task realized in the public interest or in the exercise of public authority vested in the administrator;
D. purposes resulting from legitimate interests realized by the Administrator or by a third party, except where these interests are overridden by the interests or fundamental rights and freedoms of the data subject.
VI. IMPLEMENTATION OF RIGHTS ARISING FROM GDPR
In connection with the submitted declaration of withdrawal of consent to data processing, for the purpose of identifying the person submitting the declaration and in order to protect against unauthorized access to data, NOVA POST FR SAS is entitled to obtain additional confirmation of the identity of the person submitting such a declaration.
VII. PERSONAL DATA CATEGORIES. PURPOSES OF THEIR PROCESSING AND LEGAL BASIS
1. In order to provide the Services and fulfill the Agreement with its Clients (Senders, Addressees) [Pursuant to art. 6 p. 1b) GDPR] NOVA POST FR SAS processes as the Administrator the necessary data, such as:
A. Client's data (registration data, data of contact persons on the customer's side, name, surname, position, telephone number, signature, e-mail address, job position);
B. Sender's data (sending address and necessary contact details, signature, payment information and other data needed to perform the service ordered by the sender);
C. data of the Addressee (name and surname, signature, address, zip code, city, country, and optionally other data necessary for the realization provided to the data Administrator by the sender of the shipment or indicated by himself the Addressee, such as e-mail address, telephone number).
2. Providing personal data is voluntary, but it is necessary for the performance of the Services provided by NOVA POST FR SAS. If the Sender provides additional personal data of the Addressee, in connection with the selection of one of the Additional Services, the Sender is responsible for the correct collection of this data, in particular for having the Addressee's consent for their transfer to NOVA POST FR SAS.
3. In some cases, the data is also processed:
A. on the basis of consent [Pursuant to Article 6 p. 1 a) and art. 7 GDPR] - in particular for marketing purposes or in relation to data provided voluntarily by the Addressee in connection with the delivery of the parcel.
B. and the legitimate interests of the Administrator [Pursuant to ART. 6 p. 1 f) GDPR] – in particular, such as: solvency control, compliance programs or sanctions, satisfaction surveys with the services provided (as well as to analyze the results of surveys completed as part of this survey and the possibility of return contact with the person providing the answer).
4. NOVA POST FR SAS as a registered postal operator also processes personal data for the purpose of fulfilling its legal obligations [According to Art. 6 p. 1c) GDPR] deriving, in particular, from the Postal and Electronic Communications Code, Law 2004-669 of 9 July 2004 on electronic communications and audiovisual communication services and the European Electronic Communications Code and ANC Regulation № 2014-03 on general accounting plan, amended by Resolution № 2015-06 of November 23, 2015, which transposes the new directive of the European Parliament and the Accounting Council No. 2013/34/EU of June 26, 2013, Regulation № 2020-01 on consolidated reporting (for example: proper settlement of the provided service, consideration of complaints).
5. Using website may involve the processing of personal data for the following purposes:
A. Placing an order and activities aimed at its implementation.
B. Shipments tracking [Pursuant to art. 6 p. 1b) GDPR] – the Parcel number is required to provide information about the status of the parcel.
C. Contact via the contact form [Pursuant to art. 6 p. 1f) GDPR] – data sent via the contact form, such as: name and surname, address, postal code, city, e-mail address are required to process and answer the inquiry; [Pursuant to art. 6 p. 1a) GDPR] consent to the processing of data such as: e-mail address, telephone number is required for contact in order to present a commercial offer.
D. Contact with a consultant via chat [Pursuant to art. 6 p. 1f) GDPR] – data sent during the conversation with the consultant, such as e-mail address, first and last name, address, postal code, city, are processed in order to verify the question asked and answer the question.
E. Parcel redirection [Pursuant to art. 6 p. 1b) GDPR] – via the NOVA POST FR SAS website, the Addressee has the option to change the delivery address if he or she cannot collect the parcel in person.
For this purpose, we collect the following personal data:
1.a. name and surname of the Addressee or company name;
1.b. street / house number;
1.c. zip code / place of residence;
1.d. e-mail address and description of the desired location.
7. Direct marketing and sales promotion. In order to inform about promotions and new offers of goods and services, the Administrator will process your data as provided during registration on the Website / application. The legal basis for data processing is the legitimate interest of the Administrator, which consists in the direct marketing of the Administrator's products and services (Article 6 part 1 letter f) GDPR)
A. Sending commercial and marketing information using electronic means of communication and push notifications. In order to inform about promotions and new products from the joint offer of goods and services of the Administrator and Partners using electronic means of communication (SMS, e-mail, push messages), the Administrator will process your data, for which you have voluntarily given consent to their use, as stated above. The legal basis for data processing is the consent obtained by the administrator (Article 6 Part 1 Letter a GDPR). You have the right to withdraw your consent at any time, the withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
6. Selection of candidates. During the recruitment process, the following categories of your data will be processed for the purposes and on the lawful basis.
- 1Basic data (name, date of birth), if possible;
- 2Contact information (address, phone number, email address, etc.), if available;
- 3Application details (resume, cover letter, certificates, references, interview notes and any data you provide us or wish to provide during the interview);
- 4Photo, video, if possible;
- 5Citizenship and work permit, if any;
- 6Health information for work, if available;
- 7Data that you have provided through public platforms used for professional purposes, in accordance with the applicable terms of the company responsible for managing the platform;
- 8Communication and means of communication (for example, confirmation of your application or information about a telephone/ video interview if possible).
In addition to these categories of data, in order to evaluate each job application, we need data that tells us how well suited you are to the position in question.
To manage our relationship with you, including
- 1to assess your suitability for work (purposes), the legal basis for processing is contract performance;
- 2for organizing and conducting (video) interviews (purpose), the legal basis of processing is the performance of the contract;
- 3to check your data for compliance with applicable sanctions lists and laws (purpose), the lawful basis for processing is a.) legal obligation and b.) legitimate interest.
We collect data directly from you when you provide your details on our careers website or through other communication channels. When you use another channel, for example through public platforms used for professional purposes, such as LinkedIn, we will process your data in accordance with the applicable terms of that platform. When we work with recruitment agencies, we receive your data indirectly. In this case, these institutions are responsible for ensuring the accuracy of the data and transferring it to us in accordance with applicable law.
7. Video cameras and video surveillance. We monitor and process your personal data when you visit our branches, both for your personal safety and for the safety of our employees, customers and property. Video surveillance is carried out without identification in compliance with strict security and confidentiality rules using modern technologies and equipment. Video surveillance records are stored in our systems for up to 30 calendar days.
8. Registration and recording of telephone conversations. Personal data and categories of data subjects in the register.
The following phone call identification data is registered:
- 1Call start and end time
- 2Subscriber number
- 3Called the service number
- 4Name and phone number of the official.
All calls to service numbers are recorded. Entries are made in a predetermined way. Recording starts when the call is answered and ends with the end signal.
The following chat and chatbot session details are recorded:
- 1Session time
- 2The name of the consultant and the client in the chat
Chat sessions store the content of the session between the customer and the advisor, while chatbot sessions store the content of the session between the automated chatbot and the customer.
The content of the chatbot responses is mainly collected from the website and other public sources available to anyone. At the beginning of the session, customers are provided with instructions for use.
The customer is not asked any personal questions and the customer cannot solve personal questions through the chatbot service. If a customer provides digital identification data, such as a phone number, to the chatbot service, the data is automatically deleted after one hour.
If we send an SMS request to a customer who contacted our service number by phone, the following data is recorded:
- 1Request time
- 2Customer phone number
- 3Written responses of the customer to the request
The following data is registered for the identification of customers who receive information about the actual beneficial owners:
- 1Person's name and identification code
VIII. SHARING OF DATA
1. NOVA POST FR SAS may provide personal data:
A. to subsidiaries of NOVA POST FR SAS and subcontractors (e. g. transport partners, operating parcel collection points or parcel lockers) within the European Union or outside it for the purpose of delivering parcels from the sender to the Addressee [Pursuant to art. 49 p. 1b) respectively c) GDPR];
B. entities that are subject to a contract for the provision of services for NOVA POST FR SAS or on behalf of NOVA POST FR SAS (Processors), in particular an IT service providers;
C. other persons or organizations based on applicable law;
D. banks and payment operators in order to perform the transaction (including payments made using the codes);
E. law enforcement officers and authorities to comply with national security requirements or as part of a legal process to protect property, or to pursue an investigation of a violation of NOVA POST FR SAS principles and policies, unauthorized access or use of NOVA POST FR SAS equipment, or any other illegal activity.
2. Only the Sender and the Addressee have the right to receive information about the shipment. NOVA POST FR SAS may provide such information to other entities only in situations specified in the relevant provisions of law, in particular in the Postal and Electronic Communications Code, Law 2004-669 of July 9, 2004 on electronic communications and audiovisual communication services and European Code of Electronic Communications as amended.
IX. STORAGE PERIOD AND DATA DELETION
1. NOVA POST FR SAS processes personal data only for the time necessary to achieve the purpose for which they were collected. The period of data storage is determined based on the following requirements:
A. operational requirements: the period in which the information is necessary to perform the provided Services.
B. legal requirements: the period in which NOVA POST FR SAS is required to store data for a specified period of time to comply with the law.
C. legitimate interests of NOVA POST FR SAS the period in which data is processed for the purpose of their implementation, in particular to establish and pursue possible claims in connection with the Services provided.
2. What information about you do we collect and how do we use it?
What data do we collect/process?Collection and delivery of parcelsSurname and first name of the sender and recipient of the package, address of the place of delivery, phone number, email address and other information provided to us by the sender, as well as the signature of the recipient of the package (provided at the time of receipt).
Data created by us: parcel number, delivery confirmation, GPS data of the place of receipt and delivery of the parcelExecution of contracts (offer)For individuals who accept the contract: surname, first name, patronymic, address, telephone number, e-mail address.
For representatives of legal entities on whose behalf the contract is concluded (for example, company employees): surname, first name, patronymic, position, telephone number, e-mail address, signature and the contract being concludedCustoms administrationSurname, first name, phone number, e-mail address, parcel number, sent messages, content and price of the productMaking payments and keeping accounting recordsData contained in accounting documents: surname, first name, patronymic, individual tax number, contact information, bank account number, payment details, services provided and other information in accordance with the rules of accountingDirect marketing (informing about our services and conducting surveys to evaluate the quality of our services)Name, surname, e-mail address, phone numberManaging our social media accountsFirst name, last name, account name, gender, contact information (if you provide it to us), country, photo, comments on our posts, distribution of our posts, reactions to our posts, reviews and ratings left, information about , when you started following or liking our social network account, messages sent to us with attachments, history of your messages with us (message content and when they were received/sent)Processing of inquiries, complaints and requests (internal administration)Name, surname, contact details and any other information or documents you provide to usRecording of conversations for the purpose of ensuring the quality of telephone services and information, protecting the rights and legitimate interests of employees and interested parties, protecting their rights and legitimate interests, collecting evidence, considering complaintsAudio data (phone call recording), customer service operator name, subscriber phone number, call date, start and end time are collectedEnsuring the security of parcels stored in post offices and Company assets (video surveillance)Video data (video recording), date and time of collectionAnalyzing user experience and quality to improve our servicesThe following data is collected and processed from visitors to our website: IP address, operating system, user ID and other information about the activity of the visitor on our website and other websites. This information is collected and stored as part of log entries or through cookies .
Legal basisCollection and delivery of parcelsIn the case of the sender:
(1) performance and conclusion of the contract (Article 6(1)(b) GDPR); and
(2) fulfillment of a legal obligation pursuant to Article 6(1)(c) GDPR
In the case of the consignee of the parcel
(1) fulfillment of a legal obligation pursuant to Article 6(1)(c) GDPR; and
(2) our legitimate interest in serving the parcel to the correct recipient (identification in accordance with Article 6(1)(f) GDPR)Execution of contracts (offer)Performance of the contract and its conclusion (Article 6(1)(b) GDPR)
Our legitimate interest in entering into and performing a contract with the other party to the contract through its representative (for the purpose of concluding, performing, communicating, identifying, signing documents, etc.) (Article 6(1)(f) GDPR )Customs administrationCompliance with a legal obligation pursuant to Article 6(1)(c) GDPRMaking payments and keeping accounting recordsFulfillment of the legal obligation to keep proper accounting records in accordance with Article 6(1)(c) of the GDPR and ANC Resolution No. 2014-03 on the general plan of accounting, amended by Resolution No. 2015-06 of November 23 of 2015, which transposes the new directive of the European Parliament and the Council on accounting No. 2013/34/EU dated June 26, 2013 Regulation No. 2020-01 on consolidated reportingDirect marketing (informing about our services and conducting surveys to evaluate the quality of our services)We inform you about our services:
(1) if you have used our services, we process your data on the basis of Article 81(2) of the Electronic Communications Act C of 2003;
(2) if you did not use our services (you were not our customer), we process your data based on your consent (Electronic Communications Act C of 2003 and Article 6 (1) (a) GDPR).
We conduct surveys based on our legitimate interest in improving the quality of our services in accordance with Article 6(1)(f) GDPRManaging our social media accountsYour consent (Article 6(1)(a) GDPR.)Processing of inquiries, complaints and requests (internal administration)Our legitimate interest in the proper and prompt handling of complaints, inquiries and requests received pursuant to Article 6(1)(f) GDPRRecording of conversations for the purpose of ensuring the quality of telephone services and information, protecting the rights and legitimate interests of employees and interested parties, protecting their rights and legitimate interests, collecting evidence, considering complaintsYour actual consent (when you decide to continue the conversation) (Article 6(1)(a) GDPR).Ensuring the security of parcels stored in post offices and Company assets (video surveillance)Our legitimate interest in ensuring the security of parcels stored in post offices and the security of the Company's assets (Article 6(1)(f) GDPR)Analyzing user experience and quality to improve our servicesThe data obtained through cookies are collected based on your consent (Article 6(1)(a) GDPR). The data received is processed on the basis of our legitimate interest in improving the functioning of our website (Article 6(1)(f) GDPR)
Storage periodCollection and delivery of parcelsDuring 3 (three) months, and after the expiration of this period, they are anonymized and stored for 3 (three) years in the archiveExecution of contracts (offer)During 3 (three) months, and after the expiration of this period, they are anonymized and stored for 3 (three) years in the archiveCustoms administrationSix months in the active database, and after the end of this period, they are anonymized and stored for 3 (three) years in the archiveMaking payments and keeping accounting recordsTen (10) years, except when there is a need to retain data for a longer period, for example to defend legal claimsDirect marketing (informing about our services and conducting surveys to evaluate the quality of our services)data is processed while the contract is valid.
If we have your consent for direct marketing, we will process your data for five years from the date of receipt of your consent.
The data used for conducting surveys will be processed within three months from the date of service provisionManaging our social media accountsThree yearsProcessing of inquiries, complaints and requests (internal administration)The data is stored for three years after the issue has been resolved. Personal data may be retained for a longer period of time if necessary for the Company to defend itself against claims, demands or lawsuits brought against it.Recording of conversations for the purpose of ensuring the quality of telephone services and information, protecting the rights and legitimate interests of employees and interested parties, protecting their rights and legitimate interests, collecting evidence, considering complaintsNo more than six months, except when there is a need to store data for a longer period, for example, to defend legal claims.Ensuring the security of parcels stored in post offices and Company assets (video surveillance)No more than 30 calendar days, except when there is reason to believe that:
(1) the video record is a record of an administrative offense, a criminal offense or any other violation of legislation or a violation of labor discipline and/or professional ethics;
(2) video data is necessary for pretrial or judicial proceedings; or
(3) the request for access to video data is received before the end of the data storage period.
In such cases, the image data must be kept as long as necessary for these purposes and destroyed as soon as they are no longer neededAnalyzing user experience and quality to improve our servicesRow
3. Archived data is available only to authorized employees. After the expiry of the period authorizing data storage, they are permanently deleted.
X. TRANSMISSION OF PERSONAL DATA TO COUNTRIES WHICH ARE NOT MEMBERS OF THE EUROPEAN ECONOMIC AREA
1. To all companies that are directly and/or indirectly owned or controlled by the same ultimate beneficial owners as NOVA POST FR SAS as well as subcontractors (for example, transport partners, operating parcel reception points or parcel storage chambers) within Ukraine and the European Union or beyond them for the purpose of delivering parcels from the sender to the addressee [According to Art. 49 part 1b) respectively c) GDPR];
2. NOVA POST FR SAS does not transfer personal data to international organizations.
3. NOVA POST FR SAS does not transfer personal data to third countries if it is impossible or would be inconsistent with generally applicable law.
4. The level of protection of Personal Data outside the European Economic Area ("EEA") is not the same as the level provided by European law. Therefore, NOVA POST FR SAS transfers personal data outside the EEA only when it is necessary, while ensuring an adequate level of data protection, mainly through:
A. cooperation with entities processing personal data in countries for which an appropriate decision of the European Commission has been issued regarding the assurance of an adequate level of protection of Personal Data;
B. use of standard contractual clauses issued by the European Commission, provided that an adequate level of personal data protection is ensured;
5. In the event of a justified intention to transfer personal data outside the EEA, other than the one indicated above, NOVA POST FR SAS will inform about this fact at the appropriate stage of data processing, in accordance with applicable law.
XI. INFORMATION ON DATA COLLECTED THROUGH THE WEBSITE
1. Event log and cookies. Each time a user accesses website, the data is saved in a log file. The scope of temporarily stored data includes:
A. the IP number of the computer from which the query was received;
B. domain name;
C. date and time of access;
D. http response code;
E. visited pages;
F. name and version of the operating system;
G. browser name and version;
H. screen resolution.
1. Cookies are Internet data, in particular text files, which are stored on the end device (computer, mobile phone, tablet) of the User. First of all, they contain the name of the website of their origin, their unique number and the time of storage on the end device. Cookies are used to provide the Administrator with statistical information about the visits of Users, the activity of Users and the way of using the Service. They allow you to customize content and services according to the User's preferences.
A. The cookie mechanism is not used to obtain any information about Users, except for information about their behavior on the pages of the Service.
B. The administrator stores cookies on Users' computers in order to:
1.a. proper adaptation of the Service to the needs of Users and optimization of the use of websites;
1.b. remembering the User's preferences and individual settings, recognizing the User's device and properly displaying the website according to his needs (full version, mobile version of the website);
1.c. creation of statistics of website visits, which help to understand how Users use websites, which allows to improve their structure and content;
1.d. support of the User's session (after login), so that the User does not need to re-enter the login and password on each sub-page of the Website;
1.e. saving the shopping cart data in the online store so as not to lose them after visiting the Service again.
3. The website uses two main types of cookies: session cookies and persistent cookies. Session cookies are temporary files that are stored on the website user's end device until the user logs out, leaves the website or closes the software (web browser). Persistent cookies are stored on the Website User's end device for the time specified in the cookie settings or until they are deleted by the Website User.
4. The service uses two main types of cookies:
- 1"Necessary" cookies to enable the use of services available on the Website, such as authentication cookies used for services that require authentication on the Website, cookies used to ensure security, such as are used to detect authentication fraud on the Website;
- 2"Functional and analytical" cookies that allow "remembering" settings selected by the User and personalize the User interface, for example, regarding the User's selected language or region, font size, appearance of the website and allow collecting information about how to use the Website pages, etc.;
- 3"Advertising" cookies that allow Website Users to provide advertising content that is more relevant to their interests.
a. Google Ads - files used by Google to configure advertising in its services, for example in the search engine or to display advertising on the Internet, more information: https://policies.google.com/technologies/partner-sites
b. Facebook pixels – files used to match advertising on Facebook services to the individual preferences of the recipient, more information: https://www.facebook.com/privacy/policies/cookies/
c. Google Analytics - files used to analyze how users use the website, create statistics and reports, more information: https://policies.google.com/technologies/partner-sites
XIII. BLOCKING THE ACTION OF COOKIES
1. In many cases, web browsers allow cookies to be stored on the User's end device by default. Website Users can change cookie settings at any time, e. g. in such a way as to block the automatic handling of cookies or inform about their every posting on the Website User's device. Detailed information on the possibilities and methods of handling cookies is available in the browser settings or on the following websites:
A. in the Internet Explorer browser;
B. in the Mozilla Firefox browser;
C. in the Chrome browser;
D. in the Safari browser;
E. in the Opera browser;
1. If you have a complaint about the manner in which NOVA POST FR SAS have handled your data please submit it in writing, providing as much detail as possible, using the contact details at Section I of this policy above. NOVA POST FR SAS will work with you to resolve any issues without delay.
2. If you believe that your rights under the General Data Protection Regulation have been violated, you have the right to file a complaint with the supervisory authority of NOVA POST FR SAS. In France, the relevant authority is the National Commission for Information and Liberties (CNIL) - information and contact details can be found on its website (https://www.cnil.fr/en/contact-cnil).
XV. CHANGES TO THIS POLICY