PERSONAL DATA PROTECTION POLICY
It is essential for us to guarantee the confidentiality and responsible processing of your personal data. Our commitments in this regard are detailed below:
PROCESSING OF PERSONAL DATA
As part of its business, Ascoma collects the following categories of data:
Identity, telephone and postal contact details, email address;
Data relating to browsing on the website (time stamp, 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 trackers);
Data relating to the management of user contacts (time stamp and subject of the request, follow-up, action taken, statistics);
Data relating to the management of publications (subject, presentation of offers, follow-up, statistics);
Data relating to the management of technical services (time stamp and subject of requests, follow-up, action taken, statistics);
Website audience statistics and usage of online services offered by Ascoma.
The data originates from:
Staff responsible for publishing content and the technical administration of the website;
Internet users accessing the Ascoma website;
Staff of technical service providers involved in the processing.
Not all data is mandatory. Data collected for purposes other than audience measurement is mandatory to fulfill the requests of the data subjects.
The data controller is the company that defines the purpose and method of using personal data, namely for the Ascoma website:
Ascoma
SAM with a capital of €5,000,000.00,
24, Boulevard Princesse Charlotte, 98000 Monaco,
Monaco Trade and Companies Register No. 01S 03913
The data subjects are:
Internet users accessing the Ascoma website;
Ascoma staff responsible for the website’s technical administration and content publication;
Authorized employees who respond to individual requests from internet users and anyone contacting Ascoma via online forms (applications, information, and other inquiries);
Staff of relevant service providers.
PURPOSE OF PERSONAL DATA PROCESSING
The collection and processing of personal data is for the purpose of managing the website administered by Ascoma. This processing enables:
The posting of contact forms;
The posting of contact forms for job applications submitted by Ascoma;
Technical administration directly related to service providers (domain name registrar, third-party application maintenance);
Website security management;
Content preparation and publication;
Archiving of published content;
The compilation of website audience and usage statistics for Ascoma.
The data collected by Ascoma is always used for the purposes outlined herein.
The legal bases for processing are:
The consent of the data subject for the newsletter;
Processing is necessary for the performance of contractual or pre-contractual measures related to managing data subject requests;
Processing is necessary for the purposes of the legitimate interests pursued by the data controller.
DATA RETENTION PERIOD
Data collected through contact forms for experts is retained for the duration of the request processing;
Log data (connection logs, etc.) is retained for one year from the date of collection;
Data necessary for generating website audience and online service usage statistics is retained for a maximum of six months unless the data subject objects.
Data collected for the purpose of managing the business relationship is retained for the duration of the business relationship, subject to any contrary legal provisions.
Data collected in response to an information request is retained for the duration of the request processing, as well as for the period necessary for evidentiary purposes and litigation management.
In all other cases, data is stored in the back office and on the website servers for two years from the date of collection.
RECIPIENT OF PERSONAL DATA
Data Controller:
Ascoma does not sell the personal information entrusted to it by its customers to third parties. However, in order to provide all appropriate services, this information may also be shared with technical service providers.
Ascoma certifies that this data may not be used for purposes other than those outlined herein and ensures that this processing is carried out in compliance with Monegasque regulations (Law No. 1.165 of 23/12/1993 on the protection of personal data, as amended) and more specifically with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
CONFIDENTIALITY
This information is strictly confidential and processed in accordance with Law No. 1.165 of 23/12/1993 on the protection of personal data (for Monaco) and in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
RIGHTS OF THE DATA SUBJECT
In accordance with the aforementioned provisions, the data subject has the right to access, rectify, restrict processing of, and object to the processing of their data, as well as the right to rectification and also:
Right to data portability: Since May 25, 2018, the data subject may, under certain circumstances, obtain the personal data they have provided to Ascoma (in a structured, commonly used, and machine-readable format) in order to reuse it elsewhere.
Right to erasure: The data subject may request the deletion of their personal data in certain cases, for example, if they wish to withdraw their consent. If the personal data has been shared with third parties, Ascoma will inform them of the deletion to the extent possible. Upon written request from the data subject and within the limits of applicable regulations, we may provide information on the data processors to whom we have disclosed the data so that the data subject can contact them directly.
Right not to be subject to a decision based solely on automated processing (“profiling”): The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless such profiling is necessary for entering into, or performing, a contract with Ascoma. Ascoma does not carry out this processing.
The data subject may exercise these rights. You can also exercise any requests or inquiries relating to these rights by telephone or email to the Data Protection Officer at the following number and address: dp*@****ma.com / +377 92 00 08 68, specifying “Data Subject Rights” in the subject line and attaching a copy of proof of identity.
If you believe that the responses you have received are unsatisfactory, you have the right to lodge a complaint with the supervisory authority, the CCIN – Commission for the Control of Personal Information.
COOKIES
Our Cookie Management Policy can be found at the following link: cookie management
WITHDRAWAL OF CONSENT
When consent constitutes the legal basis for the processing of personal data, the data subject can always withdraw it, particularly in the case of marketing communications (such as newsletters), by using the unsubscribe link in our marketing communications.
Withdrawal of consent will not affect the lawfulness of processing carried out after such withdrawal.