We attach great importance to the respect of your privacy and the protection of your personal data and ensure the compliance and legality of the processing of personal data with the legislation and regulations applicable in France and Europe, in particular the French Data  Protection Act of 6 January 1978, as amended, and the Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (hereinafter the “GDPR”).

The purpose of this privacy policy is to describe the various data processing that bvanudgeconsulting.com (hereinafter “BVA Nudge Consulting”) implements on the website.

In particular, it aims to inform you about :

• how your personal data is collected. Personal data is any information relating to a natural person that can be identified, directly or indirectly. This may include first and last name, age, postal or e-mail address, telephone number, location or IP address (non-exhaustive list);
• the purposes and legal base of the various processing operations involving your personal data;
• the period for which your personal data will be kept and the rights you have regarding this data;
• the person responsible for collecting and processing your personal data and the recipients of this data;
• the website’s cookie policy.

This policy completes the legal notices available at the following address: https://www.bvanudgeconsulting.com/legal-notice.

It comes into force on the date of its publication and applies to all personal data collected by BVA Nudge Consulting on its website https://www.bvanudgeconsulting.com/.

BVA Nudge Consulting reserves the right to modify this policy at any time in order to ensure the users of the site (hereinafter the “Users”) of its conformity with the legislation and regulations in force. We therefore invite you to read this policy regularly.

1. Principles relating to the collection and processing of personal data (hereinafter the “Data”)

In accordance with Articles 5 and 6 of the GDPR, Data shall be:

• a) processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency);
• b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; 
• c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation);
• d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
• e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation); 
• f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality).

Processing shall be lawful only if and to the extent that at least one of the following applies:

• a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• c) processing is necessary for compliance with a legal obligation to which the controller is subject;
• d) processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

2. Nature of Data processing

In order to operate its website, BVA Nudge Consulting may need to collect and process your Data to allow you to access the features and services offered by the website. The functionalities and services concerned are in particular the following:

• You can contact us using the “Contact us” form, available from various sections of the website. The purpose of this form is to allow professionals and private individuals to formulate a request (e.g. expertise, other information request);
• You can subscribe to the BVA Nudge Consulting newsletter via the contact form or via the “Subscribe” button available from the “Join our mailing list to be the first to know about our upcoming events and workshops” banner;
• You can subscribe to BVA Nudge Consulting podcasts via a contact form available from the “BE Good! podcast” section of the site;
• Finally, you can download books and white papers via a contact form, available from the “Our books and white papers” section of the site.

2.1. Purposes of Data processing

Data is collected and processed for the following purposes: 

• Management and follow-up of your contact requests;
• Communication of our marketing offers and other exclusive content via the subscription to the BVA Nudge Consulting Newsletter;
• The consideration of your request to subscribe to the podcasts offered by BVA Nudge Consulting;
• Communication of case studies and useful guides via downloadable books and white papers.

2.2. Legal bases for Data processing

As a data controller, understood as the legal person who determines the purposes and means of the Data processing it carries out, BVA Nudge Consulting collects and processes Data for the aforementioned purposes, which are based on the following legal bases:

3. Data processed by BVA Nudge Consulting

The Data likely to be collected and processed by BVA Nudge Consulting for the purposes mentioned above are the following:

• Last name
• First name
• E-mail
• Company name/ Organisation
• Job title
• Industry
• Your request (for the contact form)
• Services offered by BVA Nudge Consulting in which you are interested (consulting, training, our events, career opportunities, something else, …);
• Country/Region

You can also subscribe to the BVA Nudge Consulting Newsletter in different ways:

• from the “Contact us” form when sending your request by checking the “News (or Comms) emails from BVA Nudge Consulting” box;
• by filling in a contact form via the “Subscribe” button available from the “Join our mailing list to be the first to know about our upcoming events and workshops” banner and checking the “News (or Comms) emails from BVA Nudge Consulting” box;
• when you subscribe to BVA Nudge Consulting podcasts by checking the “I agree to receive other communications from BVA Nudge Consulting” box;
• when you download books and white papers by checking the « News (or Comms) emails from BVA Nudge Consulting” box.

You may opt out of such communications at any time by clicking on the “unsubscribe” link at the end of each BVA Nudge Consulting communication.

4. Data collection mode

Data is collected directly from the User, who agrees to provide it by filling out the various forms mentioned in Article 3 “Data processed by BVA Nudge Consulting” of this privacy policy.

5. Mandatory nature of Data collection

Data fields identified with an asterisk are mandatory: without this information, we cannot process your request.

6. Automated individual decision-making

The processing is not subject to any automated decision-making.

7. Data Subjects

Data processing only concerns Users who who would like to access BVA Nudge Consulting services, in accordance with the terms and conditions defined in Article 2 “Nature of Data Processing”.

8. Data recipients

8.1. Categories of recipients

The Data recipients are authorized internal members of BVA Nudge Consulting. [SB1] 

8.2. Data Transfers/Transfers outside the EU

BVA Nudge Consulting endeavors to keep your Data in the European Union. However, the Data collected by BVA Nudge Consulting may be transferred to third-party subcontractors established outside the European Union as part of the IT tools it uses in its activities.

In the event that Data is transferred to a third-party partner located outside the European Union, BVA Nudge Consulting will ensure that the Data is transferred using the appropriate legal instruments, in particular the European Commission’s standard contractual clauses, in order to guarantee the security of your Data and the respect of your rights.

9. Data retention period

BVA Nudge Consulting ensures that the retention periods of your Data are proportionate to the purposes for which they were collected.

Thus, following the last contact you had with one of our services, the Data is kept for a period of three (3) years. Your Data is then destroyed in accordance with applicable regulations.

10. Security

As a data controller, BVA Nudge Consulting takes all necessary precautions to protect the security, integrity and confidentiality of your Data.

We have implemented technical and organizational measures to limit access to your Data, including the physical security of the buildings housing our systems and the security of our computer system in order to protect them against loss, alteration or disclosure to unauthorized third parties.

11. Websites and social networks

When you browse the BVA Nudge Consulting website, we would like to inform you that some buttons and links on the website may allow you to access external resources (social networks, other websites).

The use of these external resources may lead to the collection and processing of your Data by the social networks or websites concerned. We therefore highly recommend you to consult their privacy policies to understand the information that may be collected, used or shared by these social networks or websites. Please note that, in this context, BVA Nudge Consulting is not a data controller within the meaning of the GDPR.

12. Your rights on your Data

In accordance with the French Data Protection Act and the GDPR, you can exercise the following rights:

• Right of access, to request the rectification and restriction of your Data;
• Right to object to the processing of your Data;
• Right to erasure (‘right to be forgotten’) of your Data;
• Right to withdraw your consent at any time;
• Right to Data portability in accordance with the applicable regulations.

You also have the right to express specific or general instructions concerning the storage, erasure and communication of your post-mortem Data.

This right must be exercised by mailing a request to the Data Protection Officer, whose contact details are given below. Requests concerning the fate of post-mortem Data must be accompanied by a copy of an identity document in order to be processed.

In the absence of such instructions, BVA Nudge Consulting will comply with the requests of heirs as exhaustively set out in the French Data Protection Act.

Finally, you may also lodge a complaint with the supervisory authorities, in particular the  National Commission for Computing and Freedom (CNIL) or any other competent authority, if you consider, after contacting us, that one of your rights has not been respected.

To learn more about your rights, you can visit the CNIL website at the following link : https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles

13. Data Protection Officer

The Data Protection Officer (DPO) is your contact for any request, including exercising your rights on the processing of your Data:

Contact by e-mail : dpo@bva-group.com

Contact by post :

DPO

123 Boulevard de Grenelle

75015 Paris

14.  Login data and cookies

We use login data and cookies (small files stored on your computer) to ensure the proper functioning of our website and services. For more information on this subject, please consult our cookie policy below.