- The Policy covers all Personal Data (“Personal Data”) in any form, including but not limited to electronic data, disks and paper documents and all types of processing, whether manual or automated, that is in Revevol’s possession or under Revevol’s control, in all geographical areas where Revevol operates. This will include information held about Revevol members, partners, employees, contractors, consultants, clients, consumers, suppliers, business contacts and any third parties.
- Revevol shall mean the relevant Revevol entity processing the Personal Data and the various Revevol affiliates which are part of the Revevol Group.
- Third Party shall mean a third party or business Partner who receives from Revevol or who is granted access to or is otherwise entrusted with Personal Data on behalf of Revevol, for example suppliers, contractors, sub-contractors and other service providers.
- Data Subject shall mean an identified or identifiable natural person whose Personal Data is being processed by Revevol.
- Informed Consent shall mean any freely given specific and informed indication of the Data Subject’s agreement to the processing of his/her Personal Data, when required.
- Personal Data shall mean any information enabling to identify a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. Data is considered Personal Data when it enables anyone to link said data to a natural person, even if the person or entity holding that information cannot make that link.
- Sensitive Data (or Special Category of Data) shall include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
- Personal Data relating to criminal convictions and offences are a subset of Personal Data, which due to their nature have been classified by law or by an applicable policy as deserving additional privacy and security protections.
- Process / Processing shall mean any operation or set of operations that is performed upon Personal Data, whether or not by automated means, including but not limited to, collection, recording, organization, storage, access, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, making available, alignment, combination, blocking, deleting, erasure, or destruction, either by Revevol’s software application(s), when applicable (Application Data) or through other means, such as Revevol’s websites (“Process” shall be interpreted accordingly).
How do we ensure the lawfulness, fairness and transparency of your Personal Data ?
Personal Data is processed on the basis of legal grounds with the informed knowledge of the Data Subjects.
How do we process Personal Data for specific and legitimate purpose and verify that Personal Data is minimized and accurate?
- Personal Data will only be collected and processed specified, explicit and legitimate purposes (which could be multiple), complying with the Personal Data minimization principle and ensuring the accuracy of the Personal Data processed.
- Personal Data will not be further processed in a manner that is incompatible with those purposes.
- We carefully evaluate and define the purposes of any Personal Data Processing before launching a project (e.g. management of HR data, management of recruitment data, payroll purpose, accounting and financial management, allocation of IT tools and any other digital solutions or collaborative platforms, IT support management, health and safety management, information security management, client relationship management, bids, sales and marketing management, supply management, internal and external communication and events management, compliance with anti-money laundering and anti-bribery obligations or any other legal requirements, data analytics operations, implementation of compliance processes).
- We will ensure that the Personal Data we collect are relevant, adequate and not excessive in relation to the purpose of the Processing and its eventual use (e.g. insights, marketing, promotions). This means that only necessary and relevant information for the purpose sought can be collected and processed.
- When collecting Sensitive Data or Personal Data relating to criminal convictions and offences, proportionality is fundamental. We do not collect Sensitive Data or Personal Data relating to criminal convictions and offences, unless required by applicable law or when allowed by applicable law with the Data Subject’s prior express consent.
- Every reasonable step will be taken to ensure that Personal Data are maintained in an appropriately accurate and up-to-date form at every step of Personal Data Processing (i.e. collect, transfer, storage and retrieval).
- We encourage the Data Subjects to help us maintaining your Personal Data up to date by exercising your rights, notably of access and rectification.
What Security and confidentiality measures are implemented?
Since employees, contractors, customers, suppliers, consumers and business partners put their trust in Revevol when they provide us with their Personal Data, Revevol ensures the security and confidentiality of the Personal Data it processes.
- We protect any Personal Data collected, used, retained and disclosed to support our business activities by following the relevant usage, technical and organizational policies, standards and processes.
- Industry standard technical and organizational measures are implemented to prevent against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access, or any other unlawful or unauthorized forms of Processing.
- Where processing is to be carried out on behalf of Revevol, it will select service providers providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of applicable data protection laws and ensure the protection of the rights of the data subject.
- Revevol endeavors to take reasonable measures based on Privacy by design and Privacy by default as appropriate to implement necessary safeguards when processing Personal Data. Revevol will thus implement technical and organizational measures, at the earliest stages of the design of the Processing operations, in such a way that safeguards privacy and data protection principles right from the start (‘Privacy by design’). By default, Revevol should ensure that Personal Data is processed with privacy protection (for example only the data necessary should be processed, short storage period, limited accessibility) so that by default Personal Data is not made accessible to an indefinite number of persons (‘Privacy by default’).
- When Personal Data Processing is likely to result in a high risk to the rights and freedoms of Data Subjects, we will carry out a privacy impact assessment or “Personal Data impact assessment” prior to its implementation.
- Further information on the IT security measures are described in Revevol Information Security Policy.
For how long do we keep your Personal Data?
Any person or entity handling Personal Data for Revevol will keep it only for as long as it is necessary for the purpose for which it has been collected and processed (and other compatible purposes) which may include:
- To meet or support Revevol business activity; or
- To comply with a legal or regulatory requirement and comply with applicable statute of limitation requirements;
- To defend against legal or contractual actions (in which case, the Personal Data may be retained until the end of the corresponding statute of limitation or in accordance with any applicable litigation hold policies).
Personal Data is retained and destroyed in a manner consistent with applicable law and in accordance with Revevol Data Retention Policy.
What are your rights as Data Subject?
We are receptive to queries or requests made by Data Subjects in connection with their Personal Data and, where required by law, we provide Data Subjects with the ability to access, correct, restrict and erase their Personal Data as set forth by applicable law. We also allow them to oppose the processing of their personal data, and to exercise their right to portability.
When and how do we disclose your Personal Data to third parties?
Personal Data is only disclosed outside Revevol where there is an overarching legal justification to do this.
- Disclosure is made on a strictly limited ‘need to know’ basis where there is clear justification for transferring Personal Data - either because the Data Subject has consented to the transfer or because disclosure is required to perform a contract to which the Data Subject is a party, or for a legitimate purpose that does not infringe the Data Subject’s fundamental rights, including the right to privacy (e.g. sharing in the context of a merger and acquisition operation). In each case the Data Subject will be aware that the disclosure is likely to take place. Assurances will also be sought from the recipients that they will only use the Personal Data for legitimate / authorized purposes and keep it secure.
- If a particular disclosure is required to meet a legal obligation (for example to a government agency or police force / security service) or in connection with legal proceedings, generally the Personal Data may be provided as long as the disclosure is limited to that which is legally required and, if permitted by law, the Data Subject has been made aware of the situation (i.e. the Data Subject was told of the possibility of such an event in an Informed Consent or is notified at the time of the request for disclosure).
How are international transfers of Personal Data from EU protected?
Personal Data originating from those Revevol entities operating within the EU will not be transferred outside the EEA to a third country which does not ensure an adequate level of protection unless appropriate safeguards are implemented in accordance with applicable laws.
- International Personal Data transfer is a very sensitive topic and is taken seriously before transferring any Personal Data from its EEA country of origin to another non-EEA country, whether such transfer is done for technical purposes (e.g. storage, hosting, technical support, maintenance) or the main purposes (e.g. centralization of client’s database management).
- We never carry out international transfers of Personal Data from an EEA country to another non-EEA country without ensuring that appropriate transfer mechanisms as required by applicable data protection laws are in place, to ensure adequate protection of the data when transferred (e.g. adequacy decision, signature of EU Commission Model Clauses as appropriate).
How do we handle complaints?
- Data Subjects are informed that they can complain about privacy issues by writing an email to Revevol Privacy Contact at the address above mentioned and that they may file a complaint with a supervisory authority. In particular, this shall be expressly specified in the privacy notices communicated to and/or accessible by Data Subjects.