Data Protection Policy
This information notice (hereinafter the “Policy”) describes how the establishment of BOLLORE SE known as Innovative Thin Films (a division of the Bolloré Group whose business activity consists in the manufacture of plastic films), located at Odet, 29500 Ergué-Gabéric, France (hereinafter “ITF” or “we”), collects and uses the Personal Data entrusted to it in its capacity as Controller.
The Policy applies to you if you are:
- a user of this website or any other website operated by ITF; and/or
- a representative (employee, director, agent, etc.) of an existing or prospective corporate customer; and/or
- a representative (employee, director, agent, etc.) of a service provider or supplier; and/or
- a journalist, a representative of a public administration or authority, or any other third party interacting with ITF,
(hereinafter collectively referred to as “you”).
This Policy does not apply to the collection and use of Personal Data relating to ITF’s employees or non-employed staff members, nor to applicants for positions within ITF, who are provided with separate information notices (in the case of applicants, on our Careers website, available at: https://jobs.bollorefilms.com/en/legal).
Who are the recipients of your Personal Data?
The Personal Data we collect are intended to be used by authorised ITF personnel on a need-to-know basis, depending on the reason for which you have entered into a relationship with ITF. However, your Personal Data may also be made available to our technical service providers (“Processors” within the meaning of applicable Data Protection Laws), strictly to the extent necessary for, and within the scope of, the services entrusted to them (including, in particular, IT service providers).
Certain Personal Data may also be disclosed to third parties that may use such Personal Data for their own purposes, where necessary in view of the reason for which you have entered into a relationship with ITF:
- institutional or commercial partners in connection with the management of ITF’s activities;
- public bodies and public authorities legally authorised to receive certain Personal Data;
- professional representatives and advisers for the purposes of managing a dispute or other matter (lawyers, bailiffs, etc.);
- statutory auditors, chartered accountants and other auditors;
- if all or part of the assets of Bolloré SE are acquired by a third party, your Personal Data may be made available to any person involved in the preparation and completion of the transaction and may be included among the assets transferred.
Where such recipients are located in non-European countries that are not covered by an adequacy decision of the European Commission, transfers of Personal Data (limited to the Personal Data strictly necessary) are subject to appropriate safeguards through the execution of Standard Contractual Clauses with the recipient. A copy of such clauses may be obtained by contacting: dpo@bollore-technologies.fr.
How do we use your Personal Data?
We may collect your Personal Data on various occasions in the course of our activities, depending on the reason for which you have entered into a relationship with ITF, as described in the table below.
| Purpose | Legal basis/bases | Retention period |
| – Monitoring and management of ITF’s activities – Management of our relationship under the agreement entered into between you, or the person you represent, and ITF (performance and monitoring of our services, management of our relationships with suppliers and service providers, invoicing, management of outstanding payments and debt recovery, etc.) | Performance of a contract entered into between you and ITF Our legitimate interest in performing a contract to which a third party (for example, your employer) is a party, or in taking pre-contractual steps at the request of a third party (for example, a request for information or a request for a quotation made on behalf of your employer) | 2 years after the end of our relationship |
| – Continuous improvement of our products and services | Our legitimate interests (conducting our business activities, improving our services and ensuring our security), unless you object, which you may do at any time and by any means. | 10 years after our last contact |
– Provision of our products and services – Improving our understanding of our customers – Customer relationship management and customer retention (including, in particular, gaining a better understanding of the individuals with whom we interact and sending communications regarding our news and updates) – Responding to calls for tenders issued by prospective customers – Preparation of statistics – Creation and management of lists of relevant contacts – Management of the IT security of our premises and website | Our legitimate interests (conducting our business activities, improving our services and ensuring our security), unless you object, which you may do at any time and by any means. | 3 years after your last contact with us |
| Management of litigation involving ITF | Our legitimate interest in establishing, exercising and defending legal claims. | For the duration of the proceedings (until all avenues of appeal have been exhausted). |
| Compliance with legal, accounting and tax data retention obligations | Compliance with our legal obligations | For the corresponding statutory retention period |
| Management of requests to exercise your rights in relation to your Personal Data | Compliance with our legal obligations | 6 months after our last correspondence |
Once the retention periods specified in the table above have expired, your Personal Data will, where necessary, be archived for a period not exceeding the applicable statutory limitation periods, applicable archiving requirements or, in the event of litigation, the duration of the relevant proceedings. Once these periods have expired, the Personal Data will be deleted.
What Personal Data do we collect?
In addition to the Personal Data we collect directly from you, we may, depending on the circumstances, collect certain Personal Data relating to you indirectly (for example, where your Personal Data are provided to us by one of your colleagues). In such cases, we may collect the following categories of Personal Data:
- Personal Data relating to your identity and contact details, your employer and job title, as well as your communication preferences;
- Commercial information;
- Technical data, including information collected when you visit our website, such as your IP address and connection data. Our website also uses cookies that are strictly necessary for its proper operation and use (a language preference cookie and an audience measurement cookie exempt from the consent requirement in accordance with the CNIL’s guidance). These cookies do not require your consent and you cannot object to their use, except by changing your browser settings. Please note, however, that changing such settings may prevent the website from functioning properly.
Where certain Personal Data are necessary for us to perform a contract to which the person you represent is a party, or to comply with a regulatory obligation, we will inform you accordingly at the time of collection.
What are your rights in relation to your Personal Data and how can you exercise them?
You have the following rights in relation to our use of your Personal Data:
- obtain confirmation as to whether or not Personal Data concerning you are being processed and, where they are, access such Personal Data and information concerning the Processing;
- obtain the rectification of inaccurate Personal Data;
- in certain circumstances, obtain the erasure of certain Personal Data concerning you;
- in certain circumstances, obtain the restriction of the Processing carried out by us;
- object to the Processing of your Personal Data on grounds relating to your particular situation or, irrespective of your particular situation, object to the use of your Personal Data for direct marketing purposes;
- where consent is the legal basis for the Processing of your Personal Data, withdraw your consent at any time with effect for the future;
- receive the Personal Data you have provided to us and/or request that we transmit such Personal Data to another Controller, where the Processing is based on your consent or on a contract and is carried out by automated means;
- if you reside in France, give instructions regarding the handling of your Personal Data after your death.
To exercise your rights, simply send your request to dpo@bollore-technologies.fr. We invite you to provide any supporting documentation necessary to verify your identity and the grounds on which your request should be granted.
If, after contacting us at dpo@bollore-technologies.fr, you encounter any unresolved issue regarding the use of your Personal Data, you may lodge a complaint with the CNIL (the French Supervisory Authority).