Privacy Policy

This Privacy Policy describes our practices in connection with information that Orphalan ("we" or "us") or our service providers collect through the website or application operated and controlled by us from which you are accessing this Privacy Policy. By providing personal information to us, you acknowledge that you have read and understand this Privacy Policy.

Orphalan, a société anonyme governed by French laws, with a registered office at 226 Boulevard Voltaire, 75011 Paris, France, is the data controller responsible for the processing of personal data collected through this website.

1. The Types of Information We Process

We may process information about you including, but not limited to:

• General information, such as name, postal and/or email address, phone number, date of birth, job title and other information.
• Digital information generated from your use of our websites and mobile applications, such as IP address, geo-localization, device ID and data transmitted via cookies. For more information please see our Cookie Policy.

2. Why We Process Your Information

3. Use by Minors

The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the website. If your child has submitted personal information and you would like to request its removal, please contact us as explained below under Contact.

4. Disclosure of Your Information to Third Parties

4.1 We may share your personal information within the Orphalan group of companies for the purposes described above.

4.2 We may also share your personal information outside of the Orphalan group for the following purposes:

• With our business partners, who are contractually obliged to comply with appropriate data protection obligations.
• With third-party agents and contractors for the purposes of providing services to us (e.g. accountants, professional advisors, IT, communication and marketing providers). These third parties will only use your personal information as described in this Privacy Policy.
• To the extent required by law, for example to comply with any legal obligation or to establish, exercise or defend legal rights.
• If we sell our business or assets, the personal information may be disclosed to the prospective buyer for due diligence purposes.
• If we are acquired by a third party, the personal information held by us about you will be disclosed to the third-party buyer.

5. International Transfers of Personal Data

5.1 Where we transfer your personal information to a country outside the EEA, we ensure it is protected and transferred in a manner consistent with legal requirements. This may be done through an adequacy decision by the European Commission, or standard contractual clauses.

5.2 You can obtain more details of the protection given to your personal information when transferred outside Europe by contacting us as described in section 8.2 below.

6. How We Safeguard Your Information

6.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Physical access to areas where personal information is gathered, processed or stored is limited to authorised employees.

6.2 As a condition of employment, Orphalan employees are required to follow all applicable laws and regulations, including data protection law. Unauthorised use or disclosure of confidential client information is prohibited and may result in disciplinary measures.

7. How Long We Keep Your Personal Data

How long we retain your personal information depends on:

• The purpose for which we are using it - we will retain data for as long as necessary for that purpose.
• Legal obligations - laws or regulations may set a minimum period for which we must keep your data.

Personal data collected via the website may be retained for a period of five years from the date of collection.

8. Your Rights

8.1 You may have the following rights, exercisable free of charge in most cases:

• The right to access the personal information we hold about you
• The right to withdraw consent to processing at any time
• The right to data portability where technically feasible
• The right to request rectification of inaccurate or incomplete information
• The right to request erasure in certain circumstances
• The right to request restriction of processing in certain circumstances
• The right to lodge a complaint with the relevant data protection regulator