PRIVACY POLICY
At EBTrans, we take privacy and confidentiality matters very seriously. We have developed this Privacy Policy (the “Privacy Policy”) to clearly define our ongoing commitment to protecting privacy rights and to explain how we collect, use and disclose personal data when you interact with the French entities of EBTrans group (the “Group”, “EBTrans”).
This Privacy Policy is issued for the entire Group by E.B. TRANS SA a company established at 6 avenue de l’Europe, L-4802 Lamadelaine, whose registration number is B38281.
For the purpose of this Privacy Policy, each entity of the EBTrans group (“we”, “our”, “us”) could be considered as a data controller within the meaning of applicable data protection laws (i.e. the organization which determines why and how to process personal data), when processing your personal data in the context of interactions with you or during the provision of services or products.
Any processing performed by EBTrans is made in accordance with applicable data protection laws, including but not limited to, the European General Data Protection Regulation 2016/679 of 27 April 2016
on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).
In this Privacy Policy, we use the following terms within the meaning of applicable data protection laws:
“personal data” which means any information allowing the direct or indirect identification of an individual natural person;
“processing” which means any act made in relation to such personal data (e.g. collecting, storing, and/or transferring data);
“data subjects”, “you” and “your” refer to you as individuals whose personal data are being processed by EB TRANS, or to individuals associated with you or our clients, suppliers, business partners, contacts, and any other third party on whom we may collect personal data.
Article 1. Collection of personal data
1.1. When do we collect your personal data?
We may collect, store and otherwise process personal data relating to individuals having interactions with entities of EBTrans, including
when we provide services or products to you as a client, when you provide services to us as a supplier, when you contact us or request information from us, when we exchange information or interact in any way, etc.
1.2. How do we obtain your personal data?
- We collect information from you as part of our business acceptance processes and as necessary in the course of providing transport, logistic, equipment maintenance or other services;
- We gather information about you when you provide it to us, or interact with us directly, for instance when engaging with our staff or contacting us;
- We may collect or receive information about you from other sources, such as in order to keep the contact details we already hold for you accurate and up to date using publically available sources.
When we receive personal data from a third party indirectly (e.g. an employer on behalf of its employees), the persons who provide such personal data to EBTrans undertake to do so in compliance with the applicable data protection laws and, in particular, undertake to inform the third party of the processing carried out by EBTrans and, where appropriate, to provide it with this Privacy Policy.
1.3. Update of personal data
We will endeavor to keep the personal data in our possession or control accurate. Data subjects providing personal data are however responsible for promptly informing us of any change to their personal data.
1.4. Refusal to provide your personal data
You have the right to refuse to provide us with your personal data but you are aware that not providing us with some specific personal
data (e.g. data requested when you purchase or use our products or services) may unfortunately prevent us from interacting with you, from providing you with our services, from entering into an agreement or maintaining the related ongoing agreement with you.
Article 2. Types of personal data processed
We aim to be transparent about what we process and why. For further information on our processing activities, please review the relevant section below:
2.1. Clients and individuals associated with clients:
– Collection of your personal data:
We request that our clients provide us with personal data that are necessary for us to run our business acceptance process and carry out the requested services. We may sometimes process personal data on clients and individuals related to clients (employees, managers, etc.) received from a third party or acquired from public sources.
– Types of personal data processed :
- identification information (such as first name, family name, date and place of birth, gender, picture, copy of identity document);
- contact information (such as phone and fax numbers, email address, country of residence);
- financial information (such as identification and number of bank account, credit card number, cardholder name notably linked to the billing);*
- types of services and / or products received or provided;
- other relevant personal details (such as nationality, citizenship, job title, function within a company, preferred language, license plate);
- footage from video surveillance camera;
- any other personal data related to the conduct of the EBTrans’ services to its clients.
In some instances, the personal data we collect may be considered as falling within a specific category of personal data under applicable data protection laws (such as health personal data that could be collected in the context of insurance cases). Such personal data will only be processed in accordance with applicable laws, that is to say to meet any legal or regulatory requirement we may have or for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.
2.2. Business contacts, prospects and other contacts:
– Collection of your personal data :
The personal data of business contacts and prospects that are not clients of EBTrans and do not provide services to us are stored by EBTrans in a database and processed as described below.
Most of the personal data we process with respect to business contacts and prospects is information that is knowingly provided to us by such data subjects (such as when they provide a member of EBTrans with a business card or when they contact us to receive information or request an offer for our services). However, in some instances, we may process personal data received from a third party or accessed from public sources.
– Types of personal data processed :
- identification information (such as first name, family name);
- business contact information (such as phone and fax numbers, email address);
- other relevant professional details (such as nationality, preferred language, job title, function within a company);
- any other personal data in relation with the conduct of EBTrans’ business.
In some instances, the personal data we collect may be considered as falling within a specific category of personal data under applicable data protection laws, (such as health personal data that could be collected in the context of an insurance case involving you).
Such personal data will only be processed in accordance with applicable laws, that is to say to meet any legal or regulatory requirement we may have or for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.
2.3. Suppliers including individual contractors:
– Collection of your personal data :
We may collect personal data from our suppliers and individuals related to our suppliers (employees, persons of contact) and from individual contractors.
Most of the personal data we process with respect to suppliers is information that is knowingly provided to us by them. However, in some instances, we may process personal data of individuals related to suppliers (such as when a supplier being an entity provides us with the contact details of one of its employees).
External service providers processing data on our behalf are contractually obliged to maintain strict confidentiality as per Art. 28 of the GDPR.
– Types of personal data processed :
- identification information (such as surname, family name);
- business contact information (such as phone and fax numbers, email address);
- other relevant professional details (such as job title, function within a company);
- any other personal data in relation with the management by EBTrans of its suppliers.
Article 3. Legal basis for the processing of personal data
We will only process personal data where we have a lawful reason for doing so. The lawful basis for the processing of personal data performed by us will always be one of the following, depending on the concerned processing, nature of personal data and data subjects:
- it is necessary for EBTrans to take measures at your request prior to entering into a contract or for the performance of any contractual obligations towards you;
- it is necessary for EBTrans to be able to perform an obligation according to law or any decision by a public authority, such as to allow us to comply with applicable commercial, tax and any regulatory obligations and to respond to requests and comply with requirements from public authorities and professional supervisory bodies;
- it is necessary for the establishment, exercise or defense of legal claims or proceedings;
- it is necessary for the purposes of the legitimate interest pursued by us or by a third party, such as, but not limited to:
– provide and improve our services to our clients;
– provide information requested by you;
– promote our services, including by sending information on our services and products to our clients;
– manage and administer our relationship with you (e.g sending of invoices, etc.):
- you have given prior consent when required by law, to the processing of your personal data and your consent has been obtained pursuant to applicable laws, such as for us to contact you (as prospective client or contact) and send you commercial communications (invitations to events and information of our services).
No automated decisions will be made in relation to the personal data processed.
Article 4. Recipients of personal data
To achieve the above-listed purposes, we may disclose personal data to the following recipients:
- commercial partners;
- other entities of the EBTrans group;
- clients;
- external services providers;
- subcontractors;
- professional advisors (e.g lawyers, insurers, etc,);
- purchasers or sellers of our assets and entities linked to EBTrans, if any;
- members of public organizations, administrative or legal authorities and supervisory bodies, if applicable.
You are informed that certain of the above-listed recipients may be located outside the territory of the European Economic Area in countries that do not offer a level of protection equivalent to the one granted in the European Union. Any personal data transfer to such recipients will, depending on the nature of the transfer:
- be covered by appropriate safeguards such as standard contractual clauses approved by the European Commission, in which case you may obtain a copy by contacting us; or
- be otherwise authorized under data protection law, as the case may be, as such transfer is necessary for the performance or execution of a contract concluded in your interest or for the establishment, exercise or defense of legal claims or for the performance of a contract between you and us.
Article 5. Retention of personal data
EBTrans will store your personal data only for as long as necessary for the relevant processing activity to be completed and/or for the retention period permitted or required under applicable laws.
In general, the personal data contained in the active prospecting database are kept for three (3) years from the end of the commercial relationship or the last contact.
For more information on the criteria of calculation of the retention periods, do not hesitate to contact the DPO of the EBTrans Group to the contact details indicated below.
Article 6. Technical and organizational security measures
Ensuring that personal data are appropriately protected from data being lost or misused or data breaches is a top priority for EBTrans. We implement adequate technical and organizational security measures, such as, depending on the equipment, password protection, physical locks, etc., to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected.
Access to personal data is permitted to employees for the sole purpose of performing their professional duties. They are subject to a confidentiality obligation and are notably provided with training and documentation in order to improve their practical skills and knowledge on data protection issues.
Article 7. Your rights
7.1. When EBTrans collects and processes your data, you have several rights that you can exercise directly with EBTrans:
- A right of access. The right for any person to obtain information on the treatments implemented by EBTrans or the communication of all the information concerning it held by the entities of the Group.
- A right of rectification. The right for any person to obtain the correction of the inaccurate or incomplete information concerning it held by EBTrans.
- A right to the erasure of data. The right for any person to obtain the erasure of such information when its processing is no longer necessary for the purposes described above, when the processing is not or is no longer lawful for any reason, when you have withdrawn your consent to the processing in accordance with applicable laws, when the erasure is necessary to comply with applicable laws or when you object to the processing due to the absence of any overriding and legitimate reason for such processing.
- A right to object. The right of any person to object, on legitimate grounds, to processing based on a legitimate interest of EBTrans.
- A right to limit the processing. The right to have processing suspended, in particular when you dispute the accuracy of personal data.
- A right to data portability. The right to have your personal data transmitted in a structured format to you or directly to another controller, where technically possible.
- A right to set out instructions on what to do with your personal data after your death.
- A right to lodge a complaint with your local data protection authority, a list of which is available at https://edpb.europa.eu/about-edpb/board/members_en.
7.2. Pour exercer vos droits, nous vous invitons à adresser votre demande à EBTrans, aux coordonnées indiquées ci-dessous.
To exercise your rights, we invite you to send your request to EBTrans, at the contact details indicated below.
EBTrans will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints.
We will only be able to answer favorably to any of the above requests related to the right to oppose, right of erasure and right of restriction provided that it does not interfere with or contradict a legal obligation of EBTrans (e.g. legal obligation to keep the related personal data) or due to any other impediment that would justify that EBTrans would not be able to grant such requests. EBTrans undertakes to handle each request free of charge and within a reasonable timeframe (in any case no longer than 1 month).
For more information about exercising your rights, please visit the following links:
Article 8. Amendment to this Privacy Policy
EBTrans reserves the right to change and/or amend this Privacy Policy at any time. In such case, notification will be given to you by email, or any other methods chosen by us and allowed under applicable law.
Article 9. Contact information
If you have any questions about the processing of your personal data or about this Privacy
Policy, EBTrans has a Data Protection Officer who can be contacted:
– by email: (FR) dpofrance@ebtrans.com or (BELUX) dpobelux@ebtrans.com;
– by writing to the following address: DPO EBTrans, le Fonteny, 44220 Couëron.
This Privacy Policy was last updated on January 30, 2025.
