2. CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING
Where you use the Website, HY24 Partners processes your Personal Data for various purposes, each of them being duly legitimated by a valid legal basis, as described in the table below.
|Purposes||Personal Data collected||Legal basis|
|Managing and following up any questions and/or requests you may submit.||Identification data (i.e., your first name and your email address); data related to your professional life (i.e., the identity of your employer and your job position); and the content of the message(s) you send to HY24 Partners as part of your question/request.||To take steps at your request prior to entering into a contract or, depending on the content of your message, in our legitimate interest which consists in duly managing HY24 Partners’ relationships with you, providing efficient support and improving our services and offers.|
|Managing your subscription to the newsletter.||First name, last name, email address.||Your consent.|
|Managing any potential or alleged disputes with you or third parties.||Identification data; data related to your professional life; content of your message(s).||In our legitimate interests to ensure the defence of our interests in court.|
In any event, and disregarding the processing purpose at stake, please note HY24 Partners will comply with a strict data minimisation principle and will thus only collect and process Personal Data which is necessary for the above purposes.
Please note that, under certain circumstances, providing your Personal Data is mandatory, as otherwise HY24 Partners will not be able to provide you with the services you request (e.g., your email is mandatory for HY24 Partners to reply to your question or request).
3. DATA RECIPIENTS
To perform statistics on the number of visitors of the Website, HY24 Partners relies on the services of Google LLC, which accesses and processes your Personal Data resulting from the deposit of cookies.
To the extent this is necessary, HY24 Partners also communicates your Personal Data to its group companies, i.e., Ardian SAS and Five T Hydrogen AG.
In addition, HY24 Partners may also communicate your Personal Data to auditors or other advisers auditing, assisting with or advising HY24 Partners on any aspect of its business, including notably its external legal advisors.
In any event, HY24 Partners communicates your Personal Data to the above recipients on a strict need-to-know basis and only as necessary for fulfilling duly identified processing purposes.
4. TRANSFERS OUTSIDE THE EUROPEAN UNION
HY24 Partners transfers Personal Data to Switzerland. This country has been recognized by the European Commission as a country which ensures an adequate level of protection.
When transfers outside the European Union are required for the processing of your Personal Data, HY24 Partners prefers transfer to countries that ensure an adequate level of protection in accordance with the requirements of the European Commission.
However, your Personal Data may also be transferred to HY24 Partners’ entities located in the US and Singapore that are not recognised as providing an adequate level of protection by the European Commission. These transfers are subject to appropriate safeguards to ensure the security of Personal Data and to allow you to exercise your rights and have effective remedies. Thus, in the absence of an adequacy decision, the transfers are framed by the European Commission’s standard contractual data protection clauses. You can obtain a copy of such standard contractual clauses by addressing a request to the address provided in Section 8 (Contact details) below.
Before contracting these clauses with the recipient of the transferred Personal Data, HY24 Partners carries out an assessment of the specific regulations applicable to the transfers in question in the recipient countries. If the effect of these clauses is limited or totally ruled out by the legislation of the third country applicable to the transfers, HY24 Partners undertakes to put in place additional technical, organizational measures and/or legal nature to ensure the required level of data protection.
DATA RETENTION PERIODS
HY24 Partners only retains your Personal Data for a retention period not exceeding what is necessary for the purpose of the processing at stake.
As a result, the data retention period implemented by HY24 Partners depends upon the processing purposes as detailed above in paragraph 3.
First, with respect to the management of your questions and/or requests, HY24 Partners will not retain your Personal Data for more than three (3) years following the later date of the collect of the Personal Data or the last contact on your initiative.
Second, where HY24 Partners processes your Personal Data for managing your subscription to its newsletter, your Personal Data will be retained by HY24 Partners until you unsubscribe from the newsletter or, alternatively, three (3) years following the later date of the collect of the Personal Data or the last contact on your initiative.
Third, where HY24 Partners processes your Personal Data for managing any potential or alleged disputes with you or third parties, your Personal Data will be retained by HY24 Partners during the applicable legal prescription period.
Lastly, the Personal Data processed by HY24 Partners or on its behalf for performing audience measurement operations will not be retained for more than twelve (12) months. The cookies deposited to ensure that the Website functions properly will be retained for six (6) months. For more information about cookies used on the Website, please refer to the Cookies Policy.
Where the applicable retention period expires, HY24 Partners either deletes your Personal Data or irrevocably anonymises them so that you can no longer be identified.
Where HY24 Partners considers it does not need to retain your Personal Data in its active database, it will archive it and will ensure that access thereto is restricted to a limited number of persons having an actual need to access your Personal Data.
5. YOUR RIGHTS AND OBLIGATIONS AS DATA SUBJECT
As a data subject of the processing, we carry out, you benefit from various rights regarding the processing of your Personal Data. These are as follows:
- right to request from HY24 Partners access to your Personal Data: this right enables you to receive a copy of the Personal Data that HY24 Partners holds about you and to check that HY24 Partners is lawfully processing it.
- right to request from HY24 Partners the rectification of your Personal Data: this right enables you to have any incomplete or inaccurate information that HY24 Partners holds about you corrected.
- right to request from HY24 Partners the erasure of your Personal Data: this right enables you to ask HY24 Partners to delete or remove Personal Data where there is no good reason for continuing to process it. You also have the right to ask HY24 Partners to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- right to request from HY24 Partners restriction of the processing of your Personal Data: this right enables you to ask HY24 Partners to suspend the processing of Personal Data about you, for example if you want HY24 Partners to establish its accuracy or the reason for processing it.
- right to object to the processing of your Personal Data: you may use this right where HY24 Partners relies on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, or where your Personal Data is processed for direct marketing purposes.
- right to portability of your Personal Data: this right enables you to ask for a transfer of your personal data, in a reusable format, to you or to a third party elected by you.
- right to specify guidelines regarding the use of your Personal Data after your death: this right enables you to inform HY24 Partners of the fate you want your Personal Data to have after your death, whether by specifying rules on the retention of such personal Data, its deletion, its transmission to a third party, or by appointing a third party to grant him/her access to your Personal Data after your death.
- right to withdraw the consent you gave, at any time and without affecting the lawfulness of processing based on your consent before withdrawal thereof: you may use this right to withdraw the consent you gave to HY24 Partners to send you its newsletter if you do not wish to receive it anymore; and
- right to lodge a complaint with the French Data Protection Authority, the CNIL: you may use this right if you have a complaint about the way in which HY24 Partners is managing and processing your Personal Data.
Nevertheless, it is important to note that some of the abovementioned rights can only be exercised under the conditions and within the limits provided for by the applicable legal framework (i.e., the General Data Protection Regulation No. 2016/679 dated April 27, 2016 (GDPR) and, in France, the French law No. 78-17 of January 6, 1978, as amended). In this respect, if your particular case does not meet the legal requirements to do so, we may inform you that we cannot let you exercise the concerned right, and we will explain you the reasons justifying our refusal.
Please note that HY24 Partners remains at your disposal should you decide to exercise your right(s) and/or to answer any of the questions you may have on your rights and their limitations, by contacting it to the address specified on Section 8 (Contact details) below.
HY24 Partners is committed to utmost care when it comes to protecting your Personal Data and complying with the applicable data protection legal framework.
This is the reason why HY24 Partners requires your assistance to this end. Thus, you commit to inform HY24 Partners in case the Personal Data you shared with HY24 Partners would become obsolete or inaccurate.
6. CONTACT DETAILS
Should you have any questions or requests regarding the processing of your Personal Data by HY24 Partners, including the exercise of your rights specified in Section 7 (Your rights and obligations as data subject) above, please feel free to contact Hy24 by using the following contact details: firstname.lastname@example.org or Hy24 69 rue de Richelieu 75002 Paris.
When contacting Hy24, please: (i) quote your name and address; (ii) expressly specify your request, question, or complaint; and (iii) where applicable, provide brief details of the Personal Data concerned. This will help Hy24 process your request more efficiently.