June 10th, 2022
Zelros SAS, registered at the RCS Nanterre under the number 815123765, located at 73 rue du Château, 92100 Boulogne Billancourt (hereafter “Zelros” – and “our”, “we” or “us” means Zelros where relevant), as a controller, is responsible for the processing of your personal data in relation to our activities.
- an employee or agent of a prospective client of Zelros;
- an employee or an agent of a client of Zelros;
- an employee or an agent of a vendor or supplier of Zelros;
- a job candidate applying online for a position with Zelros;
- a user of our website.
2. WHY AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL DATA?
In this section we explain why we process your personal data and the legal basis for doing so.
2.1 Your personal data is processed to perform a contract to which you are a party or pre-contractual measures taken at your request
Your personal data is processed when it is necessary to enter into or perform a contract to:
- respond to your requests and assist you;
- process your application if you are applying for a position with Zelros.
2.2 Your personal data is processed to comply with our various legal and/or regulatory obligations
Your personal data is processed, where necessary, to enable us to comply with the laws and/or regulations to which we are subject, including for the following purposes:
- prevent and detect money laundering and financing of terrorism and comply with regulations relating to sanctions and embargoes (to identify you and/or your employer, verify your identity, screen your details against sanctions lists);
- record transactions for accounting purposes;
- exchange and report different operations, transactions or orders or reply to an official request from duly authorized local or foreign financial, tax, administrative, criminal or judicial authorities, arbitrators or mediators, law enforcement, state agencies or public bodies.
2.3 Your personal data is processed to fulfil our legitimate interest or that of a third party
Where we base a processing activity on legitimate interest, we balance that interest against your interests or fundamental rights and freedoms to ensure that there is a fair balance between them.
2.3.1 In the course of our business, we use your personal data to:
- manage the risks to which we are exposed:
- we carry out the collection of debts;
- we manage legal claims and defend our position in the event of litigation.
- enhance cyber security, manage our platforms and websites, and ensure business continuity.
- carry out financial operations such as debt portfolio sales, securitizations, financing or refinancing of Zelros.
- manage the customer relationship with your employer, when your employer is a customer of Zelros.
2.3.2 We use your personal data to send you marketing communications
We want to be able to offer you access to the full range of products and services that best meet your needs and/or those of your employer.
If you are a customer and unless you object, we may send you offers and/or marketing materials by electronic communication means for our products and services that are similar to those you have already subscribed to.
2.4 Your personal data are processed if you have given your consent
For some processing of personal data, we will give you specific information and ask for your consent. Of course, you can withdraw your consent at any time.
In particular, we ask for your consent for:
- any marketing communications by electronic communication means for products and services not similar to those you have subscribed to or for products and services from our trusted partners;
- use of your navigation data (cookies) for commercial purposes or to enhance the knowledge of your profile.
You may be asked for further consent to process your personal data where necessary.
3. WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY?
- vendors and processors which perform services on our behalf (e.g., IT services, logistics, printing services, telecommunication, debt collection, advisory and distribution and marketing).
- local or foreign financial, tax, administrative, criminal or judicial authorities, arbitrators or mediators, public authorities or institutions, to which we are required to disclose pursuant to:
- their request;
- our defense, action or proceeding;
- complying with a regulation or a recommendation issued from a competent authority applying to us;
- certain regulated professions such as lawyers, notaries, or auditors when needed under specific circumstances (litigation, audit, etc.) or to an actual or proposed purchaser of the companies or businesses of Zelros.
4.INTERNATIONAL TRANSFERS OF PERSONAL DATA
In case of international transfers originating from: (i) the European Economic Area (“EEA”) to a non-EEA country, the transfer of your personal data may take place where the European Commission has recognized a non-EEA country; or (ii) the United Kingdom (“UK”) to a third country, the transfer of your personal data may take place where the UK Government has recognized the third country, as providing an adequate level of data protection. In such cases your personal data may be transferred on this basis.
For transfers to: (i) non-EEA countries where the level of protection has not been recognized as adequate by the European Commission; or (ii) third countries where the level of protection has not been recognized as adequate by the UK Government; we will either rely on a derogation applicable to the specific situation (e.g., if the transfer is necessary to perform our contract with you, such as when making an international payment) or implement an appropriate safeguard to ensure the protection of your personal data, such as Standard contractual clauses approved by the European Commission or the UK Government (as applicable).
To obtain a copy of these safeguards or details on where they are available, you can contact us as indicated in section 10 below.
5. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will retain your personal data for the longer of: (i) the period required by applicable law; or (ii) such other period necessary for us to meet our operational obligations, such as: proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.
More specifically, we retain personal data for the following durations:
|Processing purpose||Retention period|
|Manage the contractual relationship with your employer when your employer is a customer of Zelros, including to provide the products and services subscribed to under the applicable contract||Duration of the relevant contract and five years thereafter|
|Respond to your requests/assist you||Processing of your request|
|Process your application for employment||Processing of your application, unless you give us your consent to further retain your personal data|
|Collection of debts and management of legal claims/defense||Duration of the relevant proceedings and the statute of limitation applicable to the underlying claim|
|Ensuring the cybersecurity of our IT systems||Six months as from the collection of the data relating to your connections to our IT systems|
|Marketing purposes||Three years as from your last interaction with us, for marketing communications relating to products and services similar to those previously provided to you by Zelros; for the duration of your consent in relation to marketing communications for other products or services|
|Analytics and profiling purposes (based on cookies)||For the duration of your consent to such processing activities|
6. HOW CAN YOU EXERCISE YOUR RIGHTS IN RELATION TO OUR PROCESSING OF YOUR PERSONAL DATA?
You have rights which allow you to exercise real control over your personal data and how we process it.
- You can request access to your personal data
We will provide you with a copy of your personal data promptly upon request, together with information relating to its processing.
Your right of access to your personal data may, in some cases, be limited by applicable law and/or regulation.
- You can ask for the correction of your personal data
Where you consider that your personal data is inaccurate or incomplete, you can request that we modify or complete such personal data. In some cases you may be required to provide supporting documentation.
- You can request the deletion of your personal data
If you wish, you may request the deletion of your personal data, to the extent permitted by law.
- You can object to the processing of your personal data based on legitimate interests
If you do not agree with a processing activity based on a legitimate interest, you can object to it, on grounds relating to your particular situation, by informing us precisely of the processing activity involved and the reasons for your objection. We will cease processing your personal data unless there are compelling legitimate grounds for doing so or it is necessary for the establishment, exercise or defense of legal claims.
- You can object to the processing of your personal data for direct marketing purposes
You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling, insofar as it is linked to such direct marketing.
- You can suspend the use of your personal data
If you query the accuracy of the personal data, we use we will review and/or verify the accuracy of the personal data. If you object to the personal data, we process we will review the basis of the processing. You may request that we suspend the use of your personal data while we review your query or objection.
- You have rights against an automated decision
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or otherwise significantly affects you. However, we may automate such a decision if it is necessary for the entering into or performance of a contract between us, authorized by law or regulation or if you have given your explicit consent.
In any event, you have the right to challenge the decision, express your views and/or request the intervention of a competent person to review the decision.
- You can withdraw your consent
If you have given your consent to the processing of your personal data, you can withdraw this consent at any time.
- You can request the portability of part of your personal data
Provided your data is processed on the basis of the performance of a contract or based on your consent, you may request a copy of the personal data that you have provided to us in a structured, commonly used and machine-readable format. Where technically feasible, you may request that we transmit this copy to a third party.
- How to file a complaint with the CNIL
In addition to the rights mentioned above, you may lodge a complaint with the competent supervisory authority, the CNIL (Commission Nationale de l’Informatique et de Libertés).
8. HOW TO CONTACT US