In accordance with Act No. 78-17 of January 6, 1978 as amended relating to data processing, files and freedoms as amended (hereinafter the “Data Processing and Freedoms” Act) and European Regulation No. 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the “RGPD”), Optimal Ways guarantees respect for the privacy of Users of the Site in its capacity as Data Controller.

The Data Controller is the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing.
During your visit to the Site, other companies may collect personal data about you.
These companies may publish cookies and tracers detailed in section 4 of this document.

Personal Data (hereinafter “Data”) means any information relating to an identified or identifiable natural person; an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity; as this term is defined by the regulations in force.

1. Purposes of data collection

Legal basis for processing

Under the applicable regulations, Optimal Ways is authorized to use the personal data of its users only if it has a valid legal basis.
Optimal Ways must ensure that its processing is based on one or more of the following legal grounds:

– consent;
– contract;
– legal obligation;
– safeguarding vital interests;
– public interest;
– legitimate interests.

A legitimate interest on the part of the Manager must not conflict with the rights and freedoms of users.

The processing of such Data may also be based on the User’s consent, in particular in order to be able to respond to his/her requests.
The User is informed that his or her information will be used by Optimal Ways’ strictly authorized departments and subcontractors for the purpose of managing requests for information.

In this case, the User may withdraw his consent at any time.
Such withdrawal will not call into question the lawfulness of the processing carried out prior to the withdrawal.

Purpose of the data processing carried out by the Manager

Optimal Ways collects and records personal data from Users in order to administer and manage the Site.
During consultation of the Site or access to Optimal Ways’ online services, the User may be asked to voluntarily provide certain personal data, in particular by means of collection forms.

All Data is processed for specific, clear, explicit and legitimate purposes, in accordance with applicable regulations.

• Purpose #1: to put contact forms online.
  Legal basis: legitimate interest of Optimal Ways in responding to user requests.
• Purpose #2: application management.
  Legal basis: Optimal Ways’ legitimate interest in ensuring business continuity within its services.

2. Processed data

For the above purposes, Optimal Ways may process the following categories of data:

• Data relating to your identity: this includes your surname, first name, job title, e-mail address, postal address and telephone number.
• Data relating to browsing on the Site (time stamps, users’ IP addresses, technical data relating to the equipment and browser used by users, cookies) and on digital platforms via share buttons and media (cookies and other tracers);
• Data relating to the management of user contacts (time-stamp and purpose of request, follow-up, action taken, statistics);
• Statistics on website audience and use of online services offered by the Manager.

3. Data sources

The Manager collects data directly from Site Users via the contact forms available online.

In some cases, the Manager may also collect Data from third-party partners in order to update the information available to it.
These are the following partners:

• HubSpot

4. Recipients of Data

Your Data is processed by Optimal Ways’ internal teams authorized to carry out the above-mentioned processing operations.
In addition, only authorized service providers and their staff are authorized to access your Data, in view of the specific services entrusted to them, which they must carry out exclusively on behalf of Optimal Ways, in strict compliance with security and confidentiality obligations.

With your consent, when required, your Data may be transmitted to partners, in particular so that they can send you information and news about the services and products they offer.

When required by applicable regulations, Optimal Ways may transmit your Data to bodies and authorities legally authorized to access them (in particular judicial and administrative authorities).

5. Data security

Optimal Ways takes all necessary precautions to preserve the security and confidentiality of your Data, in particular to prevent it from being distorted, damaged, disclosed or accessed by unauthorized third parties.
The technical and organizational measures taken by Optimal Ways to protect Data guarantee a level of security appropriate to the risk.

6. The User’s rights to his/her Data

Users of the Site are informed that they have the right to access, rectify, delete, limit, port (where applicable) and object on legitimate grounds to Data concerning them.

In addition, each email sent by Optimal Ways tells you how to stop receiving it.

Users of the Site also have the right to define directives concerning the fate of their Data after their death.
The User therefore has the right to agree – with Optimal Ways’ DPO – directives concerning the retention, deletion and communication of his or her Data after his or her death.

In the absence of instructions or a statement to the contrary in such instructions, the User’s heirs may – after his or her death and by producing a death certificate – exercise said rights over his or her Data.
The heirs may have the deceased’s user accounts closed, object to the continuation of the processing of Data concerning him/her, or have the Data updated.

The User and/or heirs may exercise these rights by contacting the Optimal Ways DPO department via the following contact address: dpo@optimalways.com.

The User also has the right to lodge a complaint with the CNIL.

Users of the Site are required to comply with the provisions of the Data Protection Act and the RGPD, in particular by refraining from any collection or misuse of the Data to which they access.

7. Data retention period

The Data Controller will keep your Data for no longer than is necessary for the purposes set out in this policy.
Beyond this period, your Data may be archived in order to comply with the legal obligations to which the Manager is subject, or, failing this, deleted.

Data used to establish proof of a right or contract, or retained to meet a legal obligation on the part of the Responsible Entity, are archived in accordance with the provisions in force.

• Data relating to exchanges with prospective customers is stored for a period of three years from the date of collection or last contact.
• Website logs are kept for twelve months.
• Recruitment data is kept for two years from the last contact in the case of an unsuccessful application, or for the entire period of employment.
• The data required to produce statistics on the audience and use of online services is kept for twenty-four months, in a format that does not allow individuals to be identified by their IP address, and includes an identifier (relating to the cookie) kept for a maximum of thirteen months, unless the person concerned objects.

8. International Data Transfers

You are informed that Data concerning you may be transmitted or stored for the purposes defined in this policy to companies located in countries outside the European Union (Google LLC, Hubspot, etc.) and which do not offer an adequate level of protection with regard to Data protection.

Prior to any transfer outside the European Union, and in accordance with the regulations in force, Optimal Ways implements all the procedures required to obtain the guarantees necessary to ensure the security of such transfers.

We use standard contractual clauses approved by the European Commission and rely on European Commission country-specific adequacy determinations, where applicable, for transfers of Data from the European Economic Area to the United States and other countries.

9. Modification of the privacy policy

Any modification by Optimal Ways of the present policy will be the object of an update on the Site.

You are invited to consult this policy regularly in order to take note of any updates or modifications.

If any clause of this policy is declared invalid or contrary to regulations, it will be deemed unwritten but will not invalidate the other clauses of the policy.

10. Cookie management

The Optimal Ways website https://www.optimalways.com/fr/ installs “cookies”, i.e. small files, on your hard drive in order to facilitate your access to the services offered.

At any time, you can update your cookie management and modify your choices regarding acceptance or refusal by clicking below.

These cookies fall into several categories and can be of several types.

1. What is a “cookie”?

The term “cookie” encompasses a number of technologies used to track browsing patterns or analyze user behavior.
These technologies are numerous and constantly evolving.
They include cookies, tags, pixels and Javascript code.

A cookie is a small text file saved by the browser on your computer, tablet or smartphone, which enables us to store user data to facilitate browsing and provide certain functions.

2. Types of cookies

The main types of cookies:
– Internal cookies (“first party”), placed by Optimal Ways for the purposes of navigation and site operation;
– Third-party cookies (“third party”), placed by third-party partner companies in order to measure the Site’s audience and compile statistics relating thereto.
They are intended to improve the interactivity of the site.
These cookies are managed directly by the companies that publish them, who must also comply with the regulations in force.

Google Analytics is used on this site (privacypolicy).