15 August 2021
This Policy describes how your personal information will be treated as you use Crefovi’s Sites. This Policy does not apply to information provided to us in the course of our solicitor-client relationships, or which is protected by confidentiality, the solicitor-client privilege, the solicitor work product doctrine or any other applicable protection. Nothing, in this Policy, should be understood as creating a solicitor-client relationship with visitors to Crefovi’s Sites or, alternatively, to reduce any of the protections resulting from such relationships.
1. Information we collect from you when you visit Crefovi’s Sites
Like many websites, our server logs capture, and we have in the past 12 months collected, the following internet or other electronic network activity information: information regarding the operating systems of users of Crefovi’s Sites, browser software, Internet Protocol (‟IP”) addresses, and the full Uniform Resource Locator (‟URL”) clickstreams to, through and from the Crefovi’s Sites, including date and time. We may use this information to improve the services we provide through Crefovi’s Sites, to monitor and improve the performance of our servers, to administer Crefovi’s Sites, and to protect and defend our rights, property or safety or that of our clients and other users of Crefovi’s Sites. We also collect, and have in the past 12 months collected, the fact that the visitors of Crefovi’s Sites watched, and when they watched, programs on the Crefovi’s Sites. We log this information to determine which videos the visitors of Crefovi’s Sites consider useful.
2. Information you submit to us through Crefovi’s Sites
You are not required to submit any information to Crefovi’s Sites. However, you may choose to do so by completing forms available in several sections of Crefovi’s Sites, including: Publications, Careers and Events.
If you join one or more of our mailing lists, or otherwise choose to provide personal information to us through Crefovi’s Sites, we will collect, and have in the last 12 months collected, the following information about users of Crefovi’s Sites: first name, last name, email address, phone number, postal address, personal and professional interests; and professional and employment information; and education information. We use that information for the purpose for which it was collected and in accordance with the privacy wording on the relevant part of the Site. In addition, we may use this information to:
- communicate with you about our business;
- provide publications, products and services you request;
- invite you to, and register you for, events;
- add you to mailing lists and send you marketing materials we believe will be of interest to you;
- process and respond to requests, enquiries and complaints, and
- for other purposes and operations which are reasonably related, such as administering, monitoring and improving Crefovi’s Sites, our products and services.
Your information may be accessed by third party service providers who will process that information solely for our benefit and in accordance with our instructions – see Section 6 below for more information. However, we will not provide your personal information to, or share it with, any third party for their own marketing purposes, except in connection with requests you make that clearly involve third parties. This might include publications produced by third parties, or events that are presented or sponsored by third parties. This will be made clear to you before you sign up for the publication or event.
3. Your rights to access and update your personal information
Crefovi takes appropriate steps to avoid unauthorised changes to personal information you submit to Crefovi’s Sites. For so long as Crefovi elects to continue to provide Crefovi’s Sites, and provided that you comply with all agreements concerning the use of Crefovi’s Sites, we will make all reasonable efforts to provide you with online access to your registration data and other personal information so that you may view, update or correct it. To protect your privacy and security, we will also take appropriate steps to verify your identity before granting you access or enabling you to make corrections.
We retain information that is collected through Crefovi’s Sites only for as long as needed for the purpose for which it was provided, or as otherwise required for our legitimate business purposes. Your information may be retained for longer periods, if there are valid legal grounds, for example, if required by law or court order or to defend or pursue legal claims.
You may opt out of receiving marketing and market research communications at any time by using the unsubscribe links provided, or by contacting us at . You may also change your preferences regarding the communications you receive from us here.
For further information on your rights, see Section 10 below.
4. Legal basis for processing your personal information
The majority of the personal information collected by Crefovi is provided by you, voluntarily, on Crefovi’s Sites, for example when you sign up to join a mailing list or register for an event, and is therefore collected with your permission. The remaining personal information is collected for Crefovi’s legitimate business purposes, for example to monitor and improve the quality of Crefovi’s Sites and our services, and to protect and defend our rights, property or safety or that of our clients and other users of Crefovi’s Sites.
Links to websites that are not operated by or for Crefovi (‟Third Party Sites”) are provided solely as a convenience to you. If you use these links, you will leave Crefovi’s Sites. This Policy does not apply to Third Party Sites. We have not reviewed the Third Party Sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third Party Sites listed on, or linked to, from Crefovi’s Sites, you should understand that you do so at your own risk.
6. Sharing of information
The entity responsible for the management and use of Crefovi’s Sites and personal information collected from them is Crefovi SELAS in France. However, Crefovi operates worldwide through its European offices and affiliates, and may transfer personal information across national borders. Crefovi’s Sites are operated on servers located in various jurisdictions, including the United Kingdom (‟UK”). When you access or use Crefovi’s Sites, personal information about you may be transferred outside the country in which you are situated to these other locations.
Crefovi has adopted a set of Binding Corporate Rules (‟BCRs”) which allow personal information originating in the European Economic Area (‟EEA”) and/or the UK to be transferred globally within the firm. The BCRs ensure that such personal information is protected to the same standard when processed by any Crefovi entity or office around the world. For more information, click here.
We have in the last 12 months disclosed for a business purpose the following categories of personal information: (i) identifiers (name, email address, phone number, postal address, IP address, personal and professional interests); (ii) internet or other electronic network activity information (information regarding operating system, browser software, information regarding interaction with Crefovi’s Sites, namely the full URL clickstreams to, through and from Crefovi’s Sites, including date and time, and that programs on Crefovi’s Sites were watched and when they were watched); and (iii) professional and employment information.
Whenever we share personal information about users of Crefovi’s Sites, with our trusted third party service providers, and this involves transferring data outside the EEA and/or the UK, to a country that has not been granted ‟adequate” status by the European Commission, we will, as required by applicable law, put in place appropriate contracts containing standard data protection clauses approved by the European Commission, to protect that information and the rights of individuals.
7. Children’s privacy
We are committed to complying with the Children’s online privacy protection act (‟COPPA”). Crefovi’s Sites and services are not directed to children under the age of 16. We do not knowingly collect personal information from children under the age of 16. If we receive personal information that we discover was provided by a child under the age of 16, we will promptly destroy such information. Schools and parents should supervise their children’s online activities and consider the use of other means to provide a child-friendly, online environment.
Crefovi’s Sites use measures that are appropriate to protect your personal information against unauthorised access, improper use or disclosure, unauthorised or unlawful destruction or accidental loss, and all our employees and any third parties that process your personal information on our behalf are obliged to respect the confidentiality of your information. However, we cannot and do not provide any assurance that these measures will be sufficient to protect the information you choose to transmit to Crefovi’s Sites.
If you have registered to use online services on one of Crefovi’s Sites, your account details will be password protected. It is your responsibility to keep your password confidential and secure, and to sign out once you have finished browsing. Crefovi’s Sites are not designed to store sensitive personal information such as financial, health, criminal, racial or ethnic origin or political affiliation and you should not use Crefovi’s Sites for that purpose.
9. Agreement, changes
By submitting your personal information on Crefovi’s Sites, you agree to the collection and use of your personal information on the basis described above. If you do not agree, please do not provide any personal information via Crefovi’s Sites. If we decide to update our Policy, we will indicate this next to the Policy link on the front page of the Site. If there are material changes to the Policy, we will prominently post and/or communicate such changes prior to implementing them.
Any information collected under previous versions of our Policy will then become subject to the terms of our new Policy.
10. Contacts, rights
In certain circumstances, subject to certain exceptions and applicable law, you may have the following rights in relation to personal information about you:
- the right to know (i) the specific pieces of personal information collected; (ii) the categories of personal information; (iii) the categories of sources of the personal information; (iv) the business or commercial purpose for collecting the personal information; (v) the categories of personal information disclosed for a business purpose; and (vi) the categories of third parties with whom the personal information is shared;
- the right to have personal information corrected, for example if it is incomplete or incorrect;
- the right to opt out of receiving marketing communications at any time;
- the right to request that personal information is deleted;
- the right to restrict or object to the processing of personal information;
- the right to receive a copy of personal information which you have provided to the firm, in a structured, commonly used and machine-readable format (known as ‟data portability”);
- the right not to be discriminated against if you exercise any rights conferred on you by the California consumer privacy act of 2018;
- the right to complain to a Data Protection Authority (see further below).
If you have an online account, you may access, update and correct your personal information – including your marketing choices – using the account management facilities. You may also opt out of receiving marketing and market research communications at any time by contacting us at .
Crefovi does not, and will not, sell your personal information as defined under the California consumer privacy act of 2018.
If you have a query about this statement, or wish to exercise your rights, please contact Crefovi’s Global data privacy officer. California residents may also call our phone number +44 (0)20 3318 9603. You may also appoint an agent to submit a request on your behalf.
Once we receive your request, our Global data privacy officer will contact you or your agent within the timeframe specified by applicable law to confirm receipt of your request and, if needed, to gather more information about your request. Depending on the nature of the request, additional information may be requested. You or your authorised agent may need to provide the following:
- Proof of identity and address (e.g. a copy of your valid passport or driving licence);
- If you are acting as an authorised agent, express notarised permission from the individual on whose behalf you are acting;
- A description of the right(s) you want to exercise and the information to which your request relates.
Please note, we may not be obligated to provide access to personal information or delete any data to the extent that we cannot verify that the person making the request is the person about whom we collect information, or is someone authorised to act on that person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
You also have the right to complain to a Data Protection Authority if you believe that your personal information has been collected or used in breach of relevant privacy legislation or Crefovi’s BCRs. If you are located in the European Union, this will be the Data Protection Authority in the country in which you are located. Alternatively, you may contact the ‟Commission nationale de l’informatique et des libertés” (‟CNIL”), 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07, France. Further information and contact details can be found on https://www.cnil.fr.
Further information about making a complaint, either to Crefovi or to a Data Protection Authority, can be found in Crefovi’s Data privacy complaints procedure.
11. Data controller
The data controller for the Site is: Crefovi SELAS, 59 rue Legendre, 75017, Paris, France.
If you have any questions about your privacy of this Policy, including if you need to access this Policy in an alternative format, please contact Crefovi’s Global data privacy officer.