Privacy Policy

This Privacy Notice describes the practices of Financière TMG (together with its subsidiaries and affiliates, hereinafter also referred to as “SPHEREA Group”, ‘controller’, ‘we’, ‘us’). This Privacy Notice describes how we collect, process, and share your personal data, and the rights and choices that are available to you with respect to your personal data.

We appreciate your interest in our company. Data protection is extremely important for the management of SPHEREA Group.

The use of the websites of the SPHEREA Group is generally possible without the disclosure of any personal data. However, when a data subject wishes to claim special services from our website, the processing of personal data may be necessary. If such processing is necessary and no other legal basis is applicable, we generally acquire the data subject’s declaration of consent.

The processing of personal data such as name, address, E-Mail address, or phone number is carried out under strict adherence to data protection laws, especially the European General Data Protection Regulation (GDPR). With this Privacy Notice, we want to inform the public about the nature, scope and purpose of the data processing on this website. Additionally, we wish to inform any data subjects about their rights according to applicable data protection laws.

The SPHEREA Group has taken appropriate technical and organizational measures to ensure the safety and security of your personal data which we process. Nevertheless, data transfers via the internet always bear some security risks. Therefore, any data subject can freely decide to communicate with us or disclose their data by other means, such as by telephone.

1. Definitions

This Privacy Notice of the SPHEREA Group is based on the terminology used by the GDPR. We aim at the comprehensiveness and readability of this Notice – to ensure this, we provide you with an explanation of the terminology used.

We use the following terms in this Privacy Notice:

1.1 Personal Data

Personal data means any information relating to an identified or identifiable natural person (“data subject”); 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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.2 Data Subject

The data subject is the identified or identifiable natural person, whose personal data are processed by the controller.

1.3 Processing

Processing means any operation on personal data such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.4 Restriction of Processing

Restriction of processing is the special marking of stored personal data with the aim of restricting their processing in the future.

1.5 Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to assess certain personal aspects related to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, personal data, reliability, behavior, location or movements of that natural person.

1.6 Pseudonymization

Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

1.7 Controller

The controller is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by  Union regulations , the controller or the specific criteria for its nomination may be provided for by Union regulations.

1.8 Processor

Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

1.9 Recipient

Recipient means a natural or legal person, authority, authority or other body to which the personal data is disclosed, whether it is a third party. However, authorities which may obtain personal data in the context of a particular investigation in accordance with Union law shall not be deemed to be recipients, the processing of such data by these authorities in accordance with the applicable data protection rules in accordance with the purposes of the processing.

1.10 Third Party

Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

1.11 Consent

The consent of the data subject means any freely given, specific, informed and unambiguous indication of the wishes of the data subject, by which he or she means consent to the processing of personal data concerning him or her by means of a declaration or a clear affirmative act.

1.12 No use of cookies

By using the website, no cookies are collected.

2. Name and Address of the Controller

FINANCIERE TMG
109 AVENUE DU GENERAL EISENHOWER, CS42326
31023 TOULOUSE CEDEX, FRANCE
Website :  spherea.com

3. Name and Address of the Data Protection Officer

Please contact us by post at: 

FINANCIERE TMG
109 avenue du Général Eisenhower, 

CS42326
31023 TOULOUSE CEDEX, FRANCE

E- mail: dpo@spherea.com

4. Collection, processing and storage of personal data by SPHEREA

SPHEREA Group only collects, processes and stores your personal data if this is permitted by law or if you have given your consent. We obtain this data in two ways: either you have provided us with the data or we collect it when you use our services.

4.1 Data we receive through your use of our services

Some data is already collected automatically and for technical reasons when you visit our website. This data is temporarily stored in a so-called log file. The following information is collected without your intervention and stored until automated deletion:

  • The IP address of the requesting computer
  • Date and time of access
  • Name and URL of the file accessed
  • Website from which access was made (referrer URL)
  • The browser used and, if applicable, the operating system of your computer as well as the name of your access provider.

The aforementioned data is processed by us for the following purposes:

  • Ensuring a smooth connection set-up of the website,
  • Ensuring a comfortable use of our website,
  • evaluation of system security and stability.

The above-mentioned data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected.

The legal basis for data processing is Art. 6 GDPR. Our legitimate interest follows from the purposes for data collection listed above. In no case do we use the collected data for the purpose of drawing conclusions about your person.

4.2 Data transfer to a third country or an international organisation

Your data will generally be processed in all companies where SPHEREA Group is located, and especially in the European Union. If, in exceptional cases, your data is also processed in countries outside the European Union (i.e. in so-called third countries), this is done insofar as you have expressly consented to this or it is necessary for our provision of services to you or it is provided for by law (Art. 49 GDPR). In addition, your data will only be processed in third countries if certain measures ensure that an adequate level of data protection exists (e.g. adequacy decision of the EU Commission or so-called suitable guarantees, Art. 44 GDPR).

As a rule, you can use our website without providing us with any personal information directly. For some services, we will request personal information from you in order to be able to process the respective service quickly and in a user-friendly manner or to be able to offer the service at all.

4.3 External links – leaving our website and social media

Generally, you can use our websites without providing any personal information directly to us. For some services we will ask you for personal information. There are also links on our site that will take you out of our site and to the SPHEREA Group site or our customer area.

5. Contact

Data collection and processing using the contact details on our contact page

The website of SPHEREA Group contains a contact form. All address details provided on the contact page of this website, the personal data you provide will be automatically stored. Such personal data transmitted by you to us on a voluntary basis will be stored for the purpose of processing the enquiry or contacting you. This personal data will not be passed on to third parties.

6. Automated decision making

Automated decision-making based on the personal data collected does not take place.

7. Duration of storage

The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted if it is no longer required to achieve the necessary purposes.

8. Your rights

Of course, you retain control over all personal data that you provide to us when visiting the website and using our services. You have the following rights, which you can exercise free of charge.

8.1 Right of access

You have the right to obtain information about your personal data stored at any time (Art.15 GDPR).

8.2 Right to correction, deletion or restriction of processing

You have the right to have your personal data corrected (Art.16 GDPR), erased (Art.17 GDPR) or processing restricted (Art.18 GDPR).

8.3 Right to data portability

You have the right to request a transfer of your personal data from SPHEREA Group to another entity (Art. 20 GDPR).

8.4 Right to object

To exercise your right to object, you must declare your objection to us. In some cases, this can be done directly online  or you can contact the data protection team (see above for contact details). If we process your personal data within the framework of a balancing of interests on the basis of our overriding legitimate interest, you have the right at any time to object to this processing with effect for the future on grounds arising from your particular situation (Art. 21 GDPR).

If you exercise your right to object, we will stop processing the data concerned. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing which override your interests, fundamental rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.

8.5 Right to revoke consent given

You have the right to revoke your consent to the processing of personal data at any time with effect for the future (Art. 7 (3) GDPR). In the event of revocation, we will delete the data concerned without delay, unless further processing can be based on a legal basis for processing. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

8.6 Right to complain

You have the right to complain to a supervisory authority or to our company, insofar as you should have a reason for complaint (Art. 77 GDPR). To exercise your rights against our company, please contact the contact persons listed at the end of this privacy policy.

10. Data security

We use the common SSL (Secure Socket Layer) procedure in conjunction with the highest encryption level supported by your browser. You can see whether an individual page of our website is transmitted in encrypted form by the closed display of the key or lock symbol in the lower status bar of your browser.

We also use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

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