In the normal course of its interim management consulting activity, X-PM Transition Partners processes personal data. The collection and processing of personal data is carried out in accordance with the French law n° 78-17 of 6 January 1978 on data processing, files and liberties, modified by the European Regulation 2016/679 of 27 April 2016 on the protection of personal data.
X-PM Transition Partners attaches great importance to the protection of the privacy and personal data of all persons involved in its activity. X-PM Transition Partners undertakes to collect only the personal data that is relevant and necessary for the normal performance of its activity, the terms and conditions of collection and processing of which are set out in this Personal Data Protection Policy.
In the normal course of its interim management consulting activity, X-PM Transition Partners may collect your personal data – clients, prospects, suppliers, employees, interim managers – in both paper and electronic format.
X-PM Transition Partners processes your personal data in the cases permitted by the applicable regulations:
X-PM Transition Partners takes the principle of collecting data that is essential and limited to the normal functioning of its activity and for which it is processed. For interim managers and candidates, the data collected by X-PM Transition Partners may include: Civil status / Name and first name / Postal address and personal email / Personal telephone numbers / Date of birth / Training and diplomas / Professional situation (past and present functions, career path), as well as any information indicated in the CV transmitted, with the exception of so-called sensitive information / All administrative information necessary for the contractualisation.
For clients, prospects, suppliers and service providers, the data collected by X-PM Transition Partners may include: Civil status / Name and first name / Company / Professional position / Professional contact details / All administrative information necessary for the contract. This data is only collected from you and on professional social networks.
X-PM Transition Partners collects and uses your Personal Data for the normal needs of its activity and in particular for the following purposes:
X-PM Transition Partners only keeps your Personal Data for as long as is necessary to fulfil the purposes set out above, subject to the legal possibilities of archiving, obligations to retain certain data and/or anonymisation, and according to the following criteria:
Your personal data is confidential and only the employees and associates of X-PM Transition Partners, for whom access to your Personal Data is necessary for their activity, may access it, without prejudice to its possible transmission to the bodies responsible for a mission of control or inspection in accordance with the applicable regulations. The employees and partners of X-PM Transition Partners are bound by confidentiality obligations with regard to your Personal Data.
Some of your data may be communicated to technical or service providers in the express context of services entrusted by X-PM Transition Partners. X-PM Transition Partners does not authorise these service providers to use the data provided for any purpose other than the mission for which the data is entrusted to them and/or for the sole purpose of carrying out the service and always with administrative, technical and physical security measures to protect it against any unlawful disclosure, use, modification and destruction.
Some of the Personal Data collected through the normal use of the website www.x-pm.com are transferred to the servers of a partner specialised in recruitment technologies, located in Europe, in the Netherlands, where they are then stored, and with whom X-PM Transition Partners has concluded a contract guaranteeing the rights of the persons concerned to their Personal Data. This contractual commitment also covers the level of guarantees concerning the protection of Personal Data, as well as the purposes of the processing.
X-PM Transition Partners ensures the security of your Personal Data by implementing enhanced data protection through the use of physical and IT security measures. Despite these reasonable measures to protect your personal data, no transmission or storage technology is infallible. Thus, and in accordance with the applicable European regulations, in the event of a proven breach of Personal Data likely to give rise to a high risk for the rights and freedoms of the persons concerned, X-PM Transition Partners undertakes to communicate this breach to the competent supervisory authority and, where required by the said regulations, to the persons concerned (individually or in general, depending on the case). It is of course also your responsibility to exercise caution to prevent any unauthorised access to your Personal Data and to your terminals (computer, smartphone, tablet, etc.). In addition, the website www.x-pm.com may provide links to third party websites that may be of interest to you. X-PM Transition Partners has no control over the content of these third party websites or over the practices of these third parties with regard to the protection of personal data that they may collect. Accordingly, X-PM Transition Partners disclaims any responsibility for the processing by such third parties of your Personal Data, not subject to this policy. It is your responsibility to inform yourself about the Personal Data protection policies of these third parties.
X-PM Transition Partners strives to provide you with clear and accurate information about the conditions under which your Personal Data is processed (right of information).
You also have the following rights:
Right of access, rectification and deletion of your Personal Data:
The right of access allows you to have access to X-PM Transition Partners to all the Personal Data concerning you as well as confirmation as to whether or not your Personal Data is processed, and the conditions of this processing. You also have the right to obtain from X-PM Transition Partners, as soon as possible (and by default, within 30 days), the rectification of your Personal Data. Finally, subject to the exceptions provided for by the applicable law (e.g.: retention necessary to comply with a legal obligation), you have the right to ask X-PM Transition Partners for the deletion, as soon as possible, of your Personal Data, in the following cases:
Right to object to the processing of your Personal Data:
Where the processing of your Personal Data is necessary for the performance of a task carried out in the public interest or in the exercise of public authoritý vested in X-PM Transition Partners, or due to the legitimate interests of X-PM Transition Partners or a third party, the right to object allows you to have the right to object to the processing of any Personal Data in relation to your particular situation.
If your Personal Data is processed for the purpose of canvassing, you have the right, regardless of the legal basis for such processing, at any time and free of charge, to object to such processing, including profiling insofar as it is related to such canvassing, whether it is initial or subsequent processing.
Right to limit the processing of your personal data:
The applicable regulations provide that this right may be invoked in certain cases, in particular the following:
Right to the portability of your Personal Data:
Where processing is based on your consent or a contract, this right to portability allows you to receive the raw Personal Data you have provided to X-PM Transition Partners in a structured, commonly used format and to transmit this Personal Data to another controller without X-PM Transition Partners interfering with it. Where technically possible, you may request that such Personal Data be directly transmitted to another controller by X-PM Transition Partners. The data concerned by the portability is limited to the raw data that you have transmitted to us, excluding data resulting from a work of X-PM Transition Partners.
Right to withdraw consent to process Personal Data:
Where X-PM Transition Partners processes your Personal Data on the basis of your consent, you may withdraw it at any time by sending a request to X-PM Transition Partners (see below “How to exercise my rights?”). On the other hand, and in accordance with the applicable law, the withdrawal of your consent is only valid for the future and cannot therefore call into question the lawfulness of the processing carried out prior to this withdrawal nor be based on any other grounds such as, for example, the performance of a contract.
Right to lodge a complaint with a supervisory authority:
If, despite the efforts of X-PM Transition Partners, you believe that your rights have not been respected, you have the right to lodge a complaint with a supervisory authority. A list of supervisory authorities is available on the European Commission’s website.
Right to decide what happens to your Personal Data after your death:
Finally, you have the right to organise the fate of your Personal Data post-mortem through the adoption of general or specific directives. X-PM Transition Partners undertakes to respect these directives. In the absence of directives, X-PM Transition Partners recognises the possibility for heirs to exercise certain rights, in particular the right to oppose and delete to close the account of the deceased and to oppose the processing of his data.
You can exercise your rights relating to the protection of Personal Data by sending us your request, together with a copy of any identity document, as follows
X-PM Transition Partners undertakes to reply to you as soon as possible, and in any event within one month of receiving your request. If your request is submitted in electronic form, the information will also be provided to you electronically where possible, unless you expressly request otherwise. If we do not comply with your request, we will inform you of the reasons for our failure to act and you will have the right to lodge a complaint with a supervisory authority and/or to seek legal redress. For the purposes of traceability and proof of the deletion of your data, we will retain your request for deletion, the date of the actual deletion and the date of the response sent by X-PM Transition Partners for a period of 5 years from the actual deletion of the data.
X-PM Transition Partners has appointed Alexis Beguier as Data Protection Officer (DPO).
This Policy is subject to French law. In the event of a dispute and in the event that an amicable agreement cannot be reached, the competent courts will be those within the jurisdiction of the Paris Court of Appeal, notwithstanding multiple defendants or the introduction of third parties.
Last update: 4 november 2022