Note: ONTBO can be brought to modify the terms of the present Policy relating to the Protection of the Data, in particular in the event of implementation of a new treatment of Personal Data. You are invited to consult this page regularly in order to ensure that You are in agreement with any modification. You will be informed of such changes either by a special notice on our Website or by an email notification.

Personal Data means any information or set of information that allows You to be identified directly (e.g., your first and last name, email address, home address, etc.) or indirectly (e.g., through pseudonymized data such as a unique identification number, etc.). Unique identifiers may also be considered Personal Data such as, for example, the IP address of your computer.

2. Who are the data controllers responsible for protecting your Personal Data?

A data controller is an entity that determines the purposes and means of processing your Personal Data and is responsible to You for compliance with applicable data protection regulations.

Aphelior has appointed a Data Protection Officer (DPO) who will be your contact for any question relating to the processing of your Data. This person will be reachable:

Concerning the management of the Internet Site and the institutional communications, ONTBO is the person in charge of the treatment.

• by using the contact form available at https://www.ontbo.com/contact/
• by mail to the following address Aphelior Personal Data Protection Officer, 31 rue de Paris, 60200 Compiègne, France.

3. Why and how do we use the Personal Information we collect?

3.1 How do we collect your Personal Information? 

We collect your Personal Information in the following ways:

• directly from You when You use our Website and services (by filling out various forms on the Website, communicating directly with Us, etc.) ;
• directly from You when You use our Website and services (by filling out various forms on the Website, communicating directly with Us, etc.) ;

3.2 What Data Do We Collect?

ONTBO collects several types of Personal Data about You:

Personal Data We Collect Directly From You

We collect Personal Information that You provide directly to Us when You use our Website.

This is the case, in particular, when You :

• interact with Us through the contact forms,
• sign up to receive our newsletters or corporate literature,
• respond to job offers.

The categories of Personal Data We collect include:

• Identification and contact information: namely, your name, first name, email address, information necessary to identify you when You interact with Us,

Personal Data We Collect Automatically

We automatically collect certain Personal Information about You when You access or use the Website, including:

• Technical Data : We collect information about the device You use to connect and your use of the Website (such as operating system version, type of browser used, whether You use a proxy, IP address, access times, pages visited, and the link that brought You to our Website), 

3.3 On what legal grounds and for what purposes do We use the Data We collect?

In accordance with the applicable regulations on the protection of personal data, We only collect Personal Data when We have a legal basis to do so.

Personal Data are collected either :

(i) on the basis of your consent,
(ii) in our legitimate interest,
(iii) to fulfill our legal obligations.

(i) We collect Personal Information on the basis of your consent for the following purposes: 

• Manage your requests and questions We use your Information to provide you with the information you request,
• Send you newsletters,

(ii) We collect Personal Information on the basis of our legitimate interest for the following purposes:

• Defending our interests in the event of a dispute or legal action,
• Managing cyber security of the Website, 
• Preventing fraudulent activities to ensure the security of our assets and content.

(iii) We may also retain your Personal Information when We are required by law to do so or to enforce any rights We may have under the law.

3.4 Who has access to Your Data? 

3.4.1. Accessibility within ONTBO

Your Data are treated by ONTBO for the purposes mentioned above and are accessible only to the members of the personnel of ONTBO having need to know it within the framework of the exercise of their functions.

3.4.2 Accessibility by tiers

Your Data may also be made available to third parties, namely

(i) our subcontractors and service providers intervening for technical and logistical reasons (carriers, hosting, security and maintenance service providers of the Website, fraud management service providers, technical service providers in charge of sending emails and newsletters, anti-spam and anti-robot service providers, recruitment agencies that can advise Us in the management of our candidate databases and help Us in the selection of profiles within these databases, etc);

(ii) any authority, jurisdiction or other third party where such disclosure is required by law, regulation or court order, or where such disclosure is necessary for the protection and defense of our rights.

3.5 Is Personal Data transferred outside the European Economic Area? 

Your Data are treated in France by ONTBO. However, we may use service providers located abroad or who themselves use subcontractors located abroad, including outside the European Economic Area (EEA) in countries whose regulations on the protection of personal data differ from those applicable within the EEA.

Any transfer of your Data outside the EEA will be made with appropriate safeguards that comply with applicable data protection regulations. We will provide You with a copy of the applicable safeguards upon request.

4. What are your rights regarding your Data ?

4.1 Access, rectification and portability

In accordance with the regulations in force, You have the right to access Your Data. You also have the right to request the correction of inaccurate Personal Data and, depending on the purpose of the processing, to request that incomplete Personal Data be completed.

In order to respond to your request, We may ask You to provide proof of identity. We may also ask You to provide additional information or proof of identity. We will do our best to respond to your request as soon as possible.

You may, to the extent permitted by law, exercise your right to Data portability allowing You to recover, in an interoperable format, the Personal Data You have provided to Us.

4.2 Right to erase your Data and to limit the processing of your Data 

You may request the deletion of your Personal Data in the following cases:

• You believe that the processing of your Personal Data by Us is no longer necessary for the purposes set out in this Data Protection Policy,
• You consider that the processing is unlawful or dispute the accuracy of the Data We process about You,
• You have withdrawn your consent to the processing of your Data.

You may also, to the extent permitted by law, request that we limit the processing of your Data.

Please note that notwithstanding the exercise of your right to erasure of Data or limitation of processing, We will retain some of your Personal Data where We are required to do so by law or in order to exercise or defend our rights.

4.3 Right to establish instructions for the management of your Personal Data after your death

For France and where required by local law, You may determine how You want Us to handle Your Personal Data after Your death.

4.4 How to exercise Your rights regarding the protection of Your Data

You may exercise your data protection rights in the following ways:

• en utilisant le formulaire de contact accessible à l’adresse https://www.ontbo/contact/
• by mail to the following address Personal Data Protection Officer Aphelior, 31 rue de Paris, 60200 Compiègne, France.

Where the processing of your Data is based on your consent (such as, for example, newsletter subscriptions), You may withdraw it at any time, without justification. This right can be exercised by changing your options relating to subscriptions to our newsletters by clicking on the link provided for this purpose in each email We send You.

5. How is the security of your Personal Information ensured?

ONTBO implements technical and organizational measures in accordance with the legal requirements and applicable French and European regulations, which ensure the security and confidentiality of your Data.

ONTBO requires its providers and subcontractors, under the terms of written commitments, that they present guarantees and implement sufficient security measures to ensure the protection of Personal Data that they are committed to process, in accordance with the requirements of the applicable regulation on the protection of personal data.

However, ONTBO does not control all the risks related to the operation of Internet and draws your attention to the existence of risks inherent in the use of any Internet site.

6. Cookies

We use purely technical cookies to ensure the proper functioning of the Website and anonymous cookies for statistical analysis. These cookies do not collect any of your Personal Data.

7. Third-party websites

The Website may contain links to third party websites that We do not control and that are governed by their own privacy and data protection policies. This Privacy Policy does not apply to such third party sites. We invite You to consult the privacy and data protection policies of these third party sites that You visit to find out how they treat your Data. Aphelior is not responsible for the use of your Data by these third parties.

8. How can you contact us if you have any questions or complaints?

If You have any questions about this Data Protection Policy or if You have any requests or complaints about Your Personal Data, You can contact Us as follows:

• by using the contact form available at https://www.ontbo.com/contact/
• by mail to the following address Aphelior Personal Data Protection Officer, 31 rue de Paris, 60200 Compiègne, France.

In the event of a complaint about the manner in which We process your Data, You also have the right to contact the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: +33 (0)1 53 73 22 22, www.cnil.fr.