1. Introduction
1. The main purpose of this document is to provide you with information about the processing of personal data carried out by us in a concise, transparent, intelligible and easily accessible form, to help you understand how your data are processed.
2. Data are collected fairly and in a transparent manner
2. In order to ensure fair and transparent data collection, we make a point of providing prospects, clients and members of the Lexing® network with information on each processing operation we carry out by means of information notices.
3. Data are collected fairly. No data is collected without the knowledge or information of the data subjects.
3. Data are collected for legitimate and proportionate purposes
4. When we process data, we do so for specific purposes: each data processing carried out by us has a legitimate, specified and explicit purpose.
5. For each of the processing carried out, we undertake to collect and use only personal data that are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. We ensure that the data are kept up to date and take steps to ensure that data that are inaccurate are erased or rectified.
4. What personal data do we process?
7. In the context of the processing of personal data, the purposes of which are presented to you below, Alain Bensoussan Selas, the publisher of the website (“the firm”), collects and processes the following categories of data:
- identification data of data subjects, such as your title, first and last name, email address, telephone number and postal address;
- data relating to the data subject’s professional situation, such as occupation or business contact details;
- economic and financial data;
- connection and log data.
5. What are the legal bases and purposes of our processing?
8. The processing operations carried out by the firm have the following purposes and legal bases:
| N° | Purpose | Legal basis |
| 1. | Managing prospects and contacts | Legitimate interest |
| 2. | Managing the organisation and invitations to firm events | Legitimate interest |
| 3. | Managing external communications | Legitimate interest |
| 4. | Combating and preventing money laundering and the financing of terrorism (risk mapping, training and awareness-raising, lawyers’ (simplified, complementary and reinforced) due diligence when entering into a relationship and during the course of the business relationship, refusal to enter into a relationship, compliance with Know Your Customer and beneficial ownership identification requirements, implementation of internal procedures, where applicable, the phase of reporting suspicions, the appointment of a contact person). | Legal obligation |
6. Who are the recipients of your data?
9. The recipients of your data are:
- the authorised members of the firm;
- the lawyers and employees of member firms of the Lexing international network (“Lexing® network”);
- professional association authorities and financial authorities.
10. We ensure that only authorised persons have access to these data. The firm has a strict clearance policy which ensures that the data it processes are only shared with those authorised to access them.
7. Do we transfer your data?
11. We may transfer personal data outside the European Union as part of the IT tools we use for our business.
12. These transfers will only be carried out after the firm has taken measures to secure them, for example, by using the standard contractual clauses adopted by the European Commission to provide a framework for the resulting flows.
8. How long are we keeping your data?
13. We ensure that data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed.
14. The periods for which we keep your personal data are proportionate to the purposes for which your data were collected.
15. More precisely, our data storage policy is organised as follows:
| N° | Data and purposes | Storage period |
| 1. | Managing Lexing® network members | Duration of membership |
| 2. | Requesting an appointment with a Lexing® network member | Time required to process the appointment request |
| 3. | Managing contacts and prospects | 3 years from the last contact |
| 4. | Combating money laundering and the financing of terrorism | 5 years from the end of the business relationship |
9. How do we ensure the security of your data?
16. The security of your personal data is very important to us.
17. The firm has implemented technical and organisational measures appropriate to the degree of sensitivity of the personal data, in order to ensure the integrity and confidentiality of the data and protect them against malicious intrusion, loss, alteration or disclosure to unauthorised third parties.
18. However, the security and confidentiality of personal data are based on everyone’s good practices and each data subject is invited to be vigilant.
10. Do we use processors?
19. Where the firm uses a service provider, we will only disclose personal data to them after obtaining a commitment and guarantees from them that they will be able to meet security and confidentiality requirements.
20. In compliance with our legal and regulatory obligations, the contracts concluded with our processors set out precisely the terms and conditions of the processing of personal data by them in accordance with personal data protection laws.
11. Cookies
21. More information about cookies can be found in our Cookie Policy.
12. What are your rights?
22. The firm is committed to respecting your rights in relation to the data it processes, in order to guarantee fair and transparent processing taking into account the particular circumstances and context in which your personal data are processed.
12.1. Your rights of access
23. You have the right to obtain confirmation as to whether or not your personal data are being processed and, where that is the case, you have the right to request a copy of your data as well as information about:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient, and where applicable, the international organisations, to whom the personal data have been or will be disclosed, in particular recipients in third countries;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of your personal data or restriction of processing of your personal data or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, and, at least in the latter case, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
12.2. Your right to rectification of your data
24. You have the right to ask us, as the case may be, to rectify or complete your personal data that are inaccurate, incomplete, ambiguous or expired.
12.3. Your right to erasure of your data
25. You have the right to ask us to erase your personal data in the cases provided for by laws and regulations.
26. Please note, however, that the right to erasure is not a general right and can only be exercised if one of the reasons provided for in the applicable laws is met.
12.4. Your right to restriction of processing of your data
27. You have the right to request restriction of processing of your personal data in the cases provided for by laws and regulations.
12.5. Your right to object to processing of your data
28. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on the legitimate interest pursued by the controller (see section above on the legal bases for processing).
29. If you exercise your right to object, we will no longer process your personal data for the processing concerned unless we demonstrate compelling legitimate grounds for the processing which must override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
12.6. Your right to data portability
30. You have the right to portability of your personal data. Please note, however, that the right to data portability is not a general right. Not all data from all processing operations are portable; the right to data portability only concerns processing carried out by automated means to the exclusion of manual or paper processing.
31. This right is limited to processing based on your consent, on the performance of a contract or on the taking of steps prior to entering into a contract.
32. This right does not include derived or inferred data, which are personal data created by the firm.
12.7. Your right to withdraw your consent
33. Where the processing of personal data we carry out is based on your consent, you have the right to withdraw your consent at any time. We will then stop processing your personal data but this will not affect the operations based on consent before its withdrawal.
12.8. Your right to lodge a complaint
34. You have the right to lodge a complaint with the CNIL (3 place de Fontenoy 75007 Paris, France) on the French territory without prejudice to any other administrative or judicial remedy.
12.9. Your right to give post-mortem instructions
35. You have the right to give special instructions on how your personal data should be stored, erased and shared after your death, in the manner described below. These special instructions only concern, and will be limited to, the processing carried out by us.
36. You also have the right, when that person will be designated by the French executive branch, to give general instructions for the same purpose.
12.10. How to exercise your rights?
37. You may exercise the rights listed above by sending a request, together with a document proving your identity by any means, by email to dpo@alain-bensoussan.com or by post to Alain Bensoussan Selas, 58 boulevard Gouvion-Saint-Cyr, 75017 Paris, France.
13. Change to this document
38. We invite you to consult this policy on our website regularly. It may be updated at any time.