Along with your business collaboration with RUNSTEAD SERVICES (for the purpose of this privacy notice, “RUNSTEAD”), we process information about you, as an external expert or a client (“personal data”), depending on the essence of our business relationship.
The term “client” encompasses clients, represented by a natural person (individual entrepreneurs) and the employees and representatives of legal entities with whom we enter into business relations. The processing of personal data takes place in order to establish and manage operations and obligations towards you as a business management consulting company.
The term “external expert” encompasses natural persons, which collaborate with us directly for the purpose of business development or project delivery, or employees and representatives of legal entities with whom we enter into such kind of business relations.
We protect your personal data and privacy by taking all relevant measures in accordance with applicable legislation, including the EU Regulation 2016/679 – known as General Data Protection Regulation (GDPR).
This privacy notice describes how RUNSTEAD uses your personal data, how we ensure its protection and which privacy rights are granted to you by law.
For the purpose of this notice, “we” and “our” will refer to RUNSTEAD and “you” and “your” will refer to clients and partners/external experts.
Data provided by clients or experts for delivery of projects
In certain situations, you may provide us with personal data (e.g. in form of databases) in order to deliver a service for you. Data categories and purposes can vary according to the information contained in these databases. Therefore, in these situations, RUNSTEAD will become a processor and will need specific instructions from you in order to process this personal data (e.g. in the form of a data processing agreement).
- Why we process your personal data?
RUNSTEAD generally processes your personal data in order to ensure our day-to-day business activity. This data is mostly provided by you when entering into a business relationship with us. Personal data will be generated and requested further along our contractual or informal cooperation, always in relation to a specific and well-defined purpose. Below please see the main purposes for which we will process your personal data:
If we collaborate with you as a client, we process your data in order to:
formalize our relationship in agreements; understand and document your needs and requests;
manage the service you requested from us, including by contacting you;receive payments for the service provided; create statistics related to the usage of our services;
contact you for direct marketing purposes and propose cooperation opportunities; ensure the security of our working premises;respond to potential project-related request after the end of our contractual relationship ;
If we collaborate with you as an external expert or a consortium representative, we process your data in order to: maintain a database of experts; apply to tenders or projects where your expertise is relevant and perform the project; communicate to you about opportunities for collaboration; respond to contractors’ inquiries concerning your expertise;stay in contact in order to ensure continuity of our common projects; ensure the security of our working premises.
- On what legal grounds we process your data?
When one of the above-mentioned purposes is pursued, we have a clearly defined legal basis in order to process your data. Therefore RUNSTEAD ensures we collect and use your personal data only if:
we needed it in order to fulfil an agreement between you and RUNSTEAD; this data is necessary to comply with a legal obligation under the laws applicable in our jurisdictions; you gave us your consent to use your personal data for a specific purpose; we have a legitimate interest to use your data for the stated purpose, and this interest does not override yours; The legitimate interest can have a relatively broad interpretation as a legal basis. To bring clarity to this aspect, we consider our legitimate interest in relation to clients and external experts to be:
Maintaining and update our pool of business contacts and external experts;
Project a positive external image for RUNSTEAD;
Improve the quality of our services;
Exchange information between the different RUNSTEAD entities (intra-group transfers);
Extension of our client base;
Involve RUNSTEAD in new tender opportunities;
Attract qualified external experts into RUNSTEAD network and projects.
Moreover, we will also have a valid legal basis when we:
require processing your data to protect your or another person’s vital interests;
need to carry out a task in the public interest or in the exercise of official authority vested in us.
We will only use your data for the above-listed interests as long as they are not overridden by your interests and fundamental rights. In this regard, each time this legal basis will be used, we will make a balancing test between this interest and your rights and liberties, in order not to limit disproportionately the latest.
- What categories of your personal data we use?
As mentioned above, when carrying out our objectives we process several categories of personal data. The amount of data will vary depending on the purpose of our cooperation with you, but in most cases will include the following categories:
General information: name, surname, position, phone number, email, signature, company name and company information (which you represent); bank account number;
Historical data of our cooperation: the history of requests, projects performed together and feedback; results of our cooperation (project documentation, proposals etc.);
Social aspects and publications: photo and contact information publication on our official website and social networks;
Data collected resulting of video surveillance in our premises: video image, time and location in our premises;
Data for tender applications (solely for external experts): work experience, company name, project experience, education, languages;
Special categories of personal data
Special categories of personal data is data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
During your contractual relationship with RUNSTEAD, we will process this type of personal data only in the cases mentioned bellow and always within the framework of a solid legal basis:
to guarantee the security of our premises (video/biometric data); and when we have your consent to do so for specific purposes (photos at events and their publication).
In cases, you submit to us your information in the free format (e.g. CVs for application to tenders) certain categories of special categories of personal data which is not required for the purpose of our cooperation might appear there. The processing of such type of information is unnecessary to our purposes and we advise you to limit the use of such categories of personal data in these documents. Though if such data was provided willingly by you, we will treat it the same way as any other data categories, described in the current privacy notice.
- Storage, retention and erasure of personal data
RUNSTEAD ensures that your data is stored in a centralized and organized manner, namely on our accounting systems administrative cloud-based account and in our internal management system. Your information may also be stored on secure corporate email accounts, as a result of intra-group data transfers. Moreover, we also store relevant documents (e.g. contracts, invoices) in paper-based form in adequate physical storage spaces.
We keep your personal information only as long as we need it for the purposes described in this Privacy Notice. Our retention periods are based on criteria that include legally mandated retention periods, our intellectual property or ownership rights, contract requirements, operational directives or needs and for potential and pending litigation.
- Security of your personal data
To ensure the security of the data provided by you in the course of our services, we implement the technical, legal and organisational means necessary to ensure a high level of protection of your personal data. We implement and monitor constantly thorough access rights system, which ensures that only the authorized and relevant personnel can access it uniquely for lawful and clearly defined purposes.
Moreover, non-disclosure agreements are signed with all the concerned employees, in order to maintain the confidentiality of the documents and information provided by you.
- Transfers of personal data
In the course of our activities, your personal data may be transferred within our group of companies (intra-group transfers).
6.1. Intra-group transfers of personal data
RUNSTEAD is composed of several legal entities, forming what is called a group of undertakings. In order to pursue our activity, personal data exchanges may take place in order to:
respond to your – client or expert – requests and needs;
apply for tenders offers in which are involved other offices and branches of RUNSTEAD; and
share experience and statistical information with other branches;
RUNSTEAD develops a holistic approach in protecting the personal data of its clients, therefore ensuring that you will benefit from the same guarantees and rights for the whole group.
6.2. Extra-group transfers of personal data
In the context of its operations, RUNSTEAD may share your personal data with entities outside our group of undertakings. This happens mainly with:
contracting entities (private companies or public authorities), based on your explicit consent or when fulfilling contractual obligations (e.g. for applying to a tender);
public authorities or law enforcement bodies, upon request and in order to fulfill a legal requirement; third parties, for specific service providing (e.g. accounting services)
Due to the international structure and reach of our actives, part of our operations is situated outside the European Economic Area . Therefore, we may transfer your personal data outside to countries without adequacy decision from the European Commission.
To mitigate and ensure an EU-level of data protection, RUNSTEAD uses Standard contractual clauses approved by the European Commission for all our trans-border transfers, which constitute a GDPR-compliant adequate safeguard for such operations.
- Your rights
7.1. Right to access your personal data
You can request and you are entitled to obtain from us insight into the personal data we process, where it comes from and what we use it for. You can obtain information about how long we store your data and who receives data about you. Your right of access may, however, be restricted by legislation, protection of other persons’ privacy and considerations for our business and practices. Our know-how, business confidential data, as well as internal assessments and material may also as such be exempt from the right of insight.
7.2. Right to rectification and erasure of data
If you have discovered that the personal information we have about you is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased with the restrictions that follow from existing legislation and rights to process data.
7.3. Right to a restriction of use
If you believe that the data we have processed about you is incorrect or incomplete, or if you have objected to the use of the data, you may demand that we restrict the use of these data to storage. Use will only be restricted to storage until the correctness of the data can be established, or it can be checked whether our legitimate interests outweigh your interests.
If you are entitled to have the data we have registered about you erased, you may instead request us to restrict the use of these data to storage.
7.4. Right to data portability
If we use data based on your consent or as a result of an agreement, and the data processing is automated, you have a right to receive the copy of the data you have provided in an electronic machine-readable format.
7.5. Right to object
You have the right to object against RUNSTEAD processing your personal data when we invoke our legitimate interest for such an operation when we carry a task in the public interest or for direct marketing purposes.
7.6. Automated individual decision-making
You also shall have the right to object to a decision based solely on automated processing, including profiling. In these situations, RUNSTEAD will guarantee suitable measures to safeguard your rights, mainly the right to human intervention when reviewing such cases.
You will be notified if any automated decision-making is performed in relation to your personal data.
7.7. Withdrawal of consent
If we process personal data based on your consent, you can withdraw your consent to disclose data at any given time. Please also note that we will continue to use your personal data if we have to fulfill a legal or contractual obligation.
- Accuracy and updating your personal data
We will update your personal data continuously during the period it is stored in our database. This is done for internal organization purposes and in order to permit better adequacy between your needs and requests and the services we provide. In this regard, it is possible for you to update your data by notifying through an email to [email protected]
- Updates to this privacy notice
We may revise this Policy from time to time by posting an updated version on our website. If substantial changes are made, that may significantly influence your rights or increase your responsibilities, we will notify you by email. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices.
- Contact details and complaint lodging
You are always welcome to contact us if you have any questions about your privacy rights and how we register and use the personal data provided by you for business purposes. Our office in France Artemis Resisdence, Avenue des Tulipes, 93370 montfermeil, Ile de France, and you can contact the responsible person by email at [email protected].