Privacy Policy

Last updated: 15 October 2024

https://www.elinej.com (‘Website’) is provided by ‘E.G. Jager’ (‘we’/’us’/’our’). We understand that your privacy is important and we are committed to protecting the privacy of everyone who uses our Website. We will only collect and use personal data in ways that are described in this Privacy Policy and in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Before obtaining information from you (including through use of cookies) we intend to alert you to this Privacy Policy, let you know how we intend to process the information (including through use of cookies) and that we will only process the information as permitted by law.

You may browse parts of this Website without providing any information about yourself and without accepting cookies, in which case it is unlikely we will possess or process any information relating to you.

Who we are

The Website is owned and operated by ‘E.G. Jager’ registered as “EI” in France under SIRET: 91762182300025. Registered address: 57 avenue du Maréchal Juin, 64200 Biarritz, France.

What does this policy cover?

This Privacy Policy applies only to your use of our Website. Our Website may contain links to other websites, but please note that we have no control over how your data is collected, stored, or used by other websites. Please refer to the privacy policies of those websites.

What is personal data?

Personal data is defined by the European Data Protection Regulation 2018 (“the Data Protection Legislation”) as ‘any information which are related to an identified or identifiable natural person’.

Personal data is, in simple, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What are your rights?

Under the Data Protection Legislation, you have the following rights:

The right to be informed: which is fulfilled by way of this Privacy Policy and our transparent explanation as to how we use your personal data, but you can always contact us to find out more or to ask any questions.

The right to access: you are entitled to access your personal data we hold about you.

The right to rectification: you are entitled to have personal data rectified if it is inaccurate or incomplete

The right to erasure/’right to be forgotten’: you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This right only applies in the following specific circumstances:

Where the personal data is no longer necessary in regards to the purpose for which it was originally collected
Where consent is relied upon as the lawful basis for holding your data and you withdraw your consent
Where you object to the processing and there is no overriding legitimate interest for continuing the processing
The personal data was unlawfully processed
Where you object to the processing for direct marketing purposes

The right to restrict: (i.e. prevent) the processing of your personal data. When processing is restricted, we can store the data but not use it. This right only applies in the following circumstances:

Where you contest the accuracy of the personal data – we should restrict the processing until we have verified the accuracy of that data
Where you object to the processing (where it was necessary for the performance of a public interest or purpose of legitimate interests), and we are considering whether our organisation’s legitimate grounds override your right
Where processing is unlawful and you request restriction

The right to object: you have the right to object to processing based on legitimate interests; and direct marketing. This right only applies in the following circumstances:

An objection to stop processing personal data for direct marketing purposes is absolute – there are no exemptions or grounds to refuse – we must stop processing in this context
You must have an objection on grounds relating to your particular situation
We must stop processing your personal data unless We can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

The right to withdraw consent: this means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

The right to data portability: this means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights outlined above, contact us using the details provided in the Who We Are section.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed if we have that data.

What information do we collect?

Depending upon your use of our Website, we may collect and process the following types of personal data:

Contact information: Name, email address, phone number, and company details when you contact us via forms or sign up for newsletters.
Usage data: IP address, browser type, geographical location, pages viewed, and time spent on our site, collected via cookies and similar technologies.
Communication data: Information you provide through email, contact forms, or other communication channels.

We do not collect sensitive personal data unless explicitly necessary and with your consent.

How do we use your personal data?

We use your personal data for the following purposes:

To provide our services: Respond to inquiries, provide consulting services, and manage client relationships.
To improve our Website and services: Analyze website usage patterns and improve functionality, user experience, and services.
For marketing purposes: With your consent, send newsletters, updates, or promotional material about our services or events.
To comply with legal obligations: Respond to legal requests or court orders, and protect our legal rights and interests.
For recruitment purposes: Process job applications and contact candidates.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email,telephone, text message or post, with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

What is the legal basis for processing your personal data?

We process your personal data based on one or more of the following legal grounds:

Performance of a contract: To provide the services you requested.
Legitimate interest: To maintain and improve our services and business operations.
Consent: For marketing communications or optional data processing activities, you can withdraw your consent at any time.
Legal obligation: To comply with our legal responsibilities and protect our interests.

How do we share your data?

We may share your personal data with:

Service providers and partners: Third-party companies that provide services on our behalf, such as website hosting, analytics, or marketing support.
Legal authorities: When required by law, we may disclose your data to authorities or regulators.
International transfers: Since our Website is accessible globally, personal data may be transferred outside the European Economic Area (EEA) to countries that may not offer the same level of data protection. In such cases, we will ensure that adequate safeguards, such as Standard Contractual Clauses (SCC), are in place to protect your data.

How long do we retain your data?

We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by law. The retention period may vary based on the nature of the data and the specific legal or contractual requirements.

How and where do we store or transfer your personal data?

We recognise that your information is valuable and we take all reasonable measures to protect it whilst it is in our care. We take appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
use computer safeguards such as firewalls and data encryption.

However, please note that no system is completely secure, and we cannot guarantee absolute security.

We will only store your personal data in France and European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that it will be fully protected under the EU GDPR and/or to equivalent standards by law.

Cookies and tracking technologies

We may use cookies and similar technologies to collect usage data and enhance your experience on our Website. Cookies help us track Website performance, personalize content, and analyze traffic.

You can control or delete cookies through your browser settings. For more information, please see our Cookie Policy.

Third-party links

Our Website may contain links to third-party websites, which are governed by their own privacy policies. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their privacy policies.

Children’s privacy

Our services are not intended for individuals under the age of 16, and we do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without verification of parental consent, we will take steps to delete that information.

Changes to this privacy policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any updates will be posted on this page, and we will notify you of significant changes via email or a prominent notice on our Website.

Contact us

If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us through the contact form.