AARPI Vatier (hereinafter “Vatier“) is a law firm that works in partnership with its clients. This confidentiality policy applies to the processing of personal data by Vatier concerning (i) any user of the site published by the firm and accessible at www.vatier.com (hereinafter the “Site“) and (ii) clients or prospective clients of Vatier.
We attach the utmost importance to respecting the privacy and personal data of people who come into contact with us, and we implement appropriate technical and organisational measures to ensure that your personal data is processed in accordance with the regulations in force (in particular the General Data Protection Regulation no. 2016/679 of 27 April 2016 (hereinafter “GDPR“) and the French Data Protection Act of 6 January 1978 as amended).
The terms “data” or “personal data“, “processing“, “controller“, “processor” or “recipient” used in this policy have the same meaning as given to them in the RGPD.
Vatier, AARPI located at 41 avenue de Friedland 75008 Paris, is the data controller which, within the meaning of the RGPD, determines the purposes and means of data processing, i.e. for what purpose(s) and how your personal data is processed, in accordance with this privacy policy.
If you have any questions, requests for information or complaints, please contact us:
Identification and contact data: we process the data required to contact you, to fulfil our obligations in terms of the fight against money laundering and the financing of terrorism, to respond to your requests and to process and monitor your cases (whether advisory or contentious), and finally to send you our newsletters or other news and invitations. This data consists of the identification information that you have provided to us (surname, first name, postal address, telephone number and/or e-mail address, occupation, copy of identification documents) as well as any other data that you have entered via the forms on the Site or that you provide to us as part of the processing of your file.
Site user navigation data: in order to ensure that the Site is displayed in the language you use, we use cookies or other types of trackers on our Site. Please refer to our “cookies” policy for more information.
Data relating to criminal convictions and offences: we only process this data if it is necessary for us to deal with your case.
“Sensitive” data: we only process sensitive data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as data concerning health or data concerning a natural person’s sex life or sexual orientation) if this is necessary for the processing of your file.
The “purpose of processing” refers to the purpose for which Vatier processes your data.
“Legal bases” refers to the basis on which the processing carried out by Vatier is based.
| Type of data processed | Purpose of processing | Base légale |
|---|---|---|
| Prospect identification and contact data | Response to requests made via the Site | Legitimate interest |
| Sending newsletters, updates and invitations | Legitimate interest or consent | |
| Customer identification and contact data | Response to requests made via the Site | Legitimate interest |
| Sending out newsletters, updates, invitations and other external communication activities | Legitimate interest or consent | |
| Combating and preventing money laundering and terrorist financing | Legal obligation | |
| Processing and monitoring customer files | Performance of the contract | |
| Data on convictions and offences | Processing and monitoring customer files | Consent and/or establishment, exercise or defence of a legal right |
| “Sensitive” data | Processing and monitoring customer files | Consent and/or establishment, exercise or defence of a legal right |
Personal data is kept for the period necessary to achieve the purposes for which it is collected, as described in article 3, plus the period required by law, in particular:
Current retention period (“active basis”) for personal data:
“Intermediate storage” of personal data (the data is no longer used to achieve the objective set but is still of administrative interest (for example, for the management of a possible dispute) or must be kept to meet a legal obligation): the data (in particular documents and accounting records or necessary for the management of disputes) will be kept for the duration of the limitation period or of the dispute beyond the current storage period and may be consulted on a case-by-case basis by specifically authorised persons.
Some of your data may be transmitted and consulted, or at least hosted, by the following people:
All recipients of your data are located within the European Union (hereinafter “EU”). Your personal data is hosted by service providers located in the EU or the European Economic Area. In the event of data being transferred outside the EU or the European Economic Area, Vatier undertakes to implement appropriate safeguards as permitted by the RGPD.
You have a number of rights over your data, which you can exercise under the conditions set out in the RGPD. You will find a summary below.
| Your rights | Utilities |
|---|---|
| Right of access Article 15 of the RGPD | Obtain a legible and comprehensible copy of the data we hold concerning you, as well as a copy of this charter on a durable medium. |
| Right to rectification Article 16 of the RGPD | Obtain the rectification, updating or completion of data concerning you. |
| Right to withdraw consent Article 7 paragraph 3 of the RGPD | Obtain, for the future, the cessation of the processing of data for which you have consented to the processing. |
| Right to object Article 21 of the RGPD | Obtain, for the future, the cessation of the processing of your data where such processing is based on our legitimate interest or that of a third party (subject in particular to legitimate and compelling grounds) or where your data is used for commercial prospecting purposes. |
| Right to erasure (right to be forgotten) Article 17 of the RGPD | Obtain the deletion of all or part of your data, or its complete and irreversible anonymisation, under certain conditions (in particular if you consider that the data is no longer necessary, if you have withdrawn your consent or if you consider that your data is being processed unlawfully). In such cases, we may nevertheless be required to retain certain data in order to comply with our legal obligations or to enforce our legal rights. |
| Right to restriction of processing Article 18 of the RGPD | Obtain the conservation of your data without further use (for example if you consider that the data is no longer necessary or is being processed unlawfully). In this case, your data is temporarily isolated and no longer used (subject to our legal obligations or the exercise of our legal rights). |
You may exercise these rights at any time and free of charge, except in the case of requests that are manifestly unfounded or excessive (in particular due to their repetitive nature). In this exceptional case we reserve the right, in accordance with the provisions of the RGPD (article 12 paragraph 5), to demand payment of a reasonable fee or to refuse your request.
You can exercise your rights by contacting us:
If you feel that we have not responded satisfactorily to your request, you can contact the Commission Nationale de l’Informatique et des Libertés (CNIL) via its website www.cnil.fr or by post at the following address: CNIL – 3, Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.
VATIER
41, Avenue de Friedland
75008 Paris