The purpose of this Privacy Policy is to inform you about the manner in which your personal data is collected and/or processed in the context of using the “PUREVENT” system and the dedicated App (hereinafter “PUREVENT” and the “App”).
Ventilairsec sells and installs the PUREVENT system through partner installers (hereinafter the “Installer”).
In this context, your personal data may be processed by both Ventilairsec and the Installer under the conditions set out in this Privacy Policy.
Protecting your privacy and your personal data is a priority for Ventilairsec, who is committed to processing your data in full compliance with the French Data Protection Act of 6 January 1978, as amended by law no. 2018-493 of 20 June 2018 (hereinafter the “French Data Protection Act”) and the Council of Europe’s General Data Protection Regulation of 27 April 2016 (hereinafter the “GDPR”).
In all cases, Ventilairsec undertakes to respect the following two basic principles:
- You remain in charge of your personal data;
- Your data shall be processed in a transparent, confidential and secure manner.
1.DATA CONTROLLER IDENTITY & CONTACT DETAILS
The controller of the data processed via the PUREVENT App is Ventilairsec.
However, in the context of maintenance operations that may be carried out on the Purevent system, the Installer may need to access some of your personal data.
In this case, Ventilairsec and the Installer are joint data controllers.
For this reason, in accordance with Article 26 of the GDPR, Ventilairsec and the Installer entered into an agreement on joint processing of personal data, in which their mutual obligations were set out to ensure the privacy and security of your data.
Legal notice The data controller is, within the meaning of the French Data Protection Act, the person who determines the means and purposes of the processing. Where two or more data controllers jointly determine the purposes and means of the processing, they are joint data controllers (or joint managers). The data processor is a person who processes the personal data on behalf of the data controller, acting under the authority of the data controller and on the latter’s instructions.
Ventilairsec is a French limited liability company (Société À Responsabilité Limitée or SARL) registered with the Nantes Trade and Companies Register under number B 490 141 991, having its registered office at 16 rue des Imprimeurs, 44220 Couëron, France.
For any queries concerning the management and use of your personal data, you may contact us:
- Either via the contact form on our website available at this address: https://www.ventilairsec.co.uk/contact/
- Or by e-mail to dpo@ventilairsec.com
- Or by post to Ventilairsec, 16 rue des Imprimeurs, 44220 Couëron, France
- Or by telephone at + 33 (0)2 40 04 19 44
- Or by fax to + 33 (0)2 40 03 96 11
2.DATA COLLECTION & ORIGIN
Some of your data is collected directly from you. This mainly concerns the identification data required to create your user account on the App.
Your personal data is also collected from information gathered, calculated or analysed by the PUREVENT system and from the use made thereof.
In all cases, your data is collected and processed solely for the purposes of the agreement entered into with the Installer, for the performance of said agreement, and to allow Ventilairsec and the Installer respond to your inquiries about the PUREVENT system.
3.PROCESSING PURPOSES AND LEGAL BASIS
Your data is collected and processed for:
| Purposes of the processing | Legal basis |
|---|---|
| Analysis of certain information relating to your environment (air, humidity, CO2 levels, surface area of your home, etc.) to regulate the VMI® system | Contractual: processing is necessary for performance of the supply contract for the PUREVENT® system. |
| Creation of an account on the App | Contractual: lprocessing is necessary to allow you to control the VMI® system remotely. |
| Carrying out maintenance operations on the VMI® system and/or the App | The legitimate interest of Ventilairsec and the Installer to provide you with products in good working order. |
| Improvements to the VMI® system and/or the App | The legitimate interest of Ventilairsec to develop its products and its business. |
| To manage and respond to your requests to exercise rights under the French Data Protection Ac | Legal provisions laid down by the GDPR (Article 15 et seq.) and the French Data Protection Act (Article 48 et seq.). |
4.DATA PROCESSED
The mandatory or optional nature of the personal data requested and the possible consequences of failure to respond on your part are specified at the time of data collection.
Here is the detail of the personal data that we may have on you:
| User identification data |
|
| Data relating to equipment |
|
| Data relating to the User’s home |
|
| Data calculated or analysed by the PUREVENT® system |
|
5.DATA RECIPIENTS
Within the limits of their respective remits and for the purposes mentioned in clause 4, the main persons likely to have access to your data are as follows:
- Internal departments at Ventilairsec;
- Internal departments at the Installer company, solely in the framework of processing in connection with maintenance operations;
- External providers whose services Ventilairsec and the Installer may use in the context of specific missions (VMI® installation, IT providers, etc.)
- Providers involved in the implementation of products and services offered.
Additional information regarding the list of Ventilairsec providers:
- Where applicable, the relevant jurisdictions, mediators, chartered accountants, statutory auditors, lawyers, bailiffs, debt collection agencies, police or gendarmerie authorities in the event of theft or a court requisition, and the emergency services.
6.DATA RETENTION PERIOD
Your data shall be retained during the period necessary for supply of the PUREVENT system. It may be retained for a longer period, in particular for proof purposes, in compliance with the prescriptions of the GDPR and applicable legal provisions, it being specified that you may object to the processing of your personal data at any time.
For information purposes only, the legal retention periods are as follows:
| For App login data | 1 year after termination of the agreement or closure of the account |
| For data relating to your account on the App | 5 years after termination of the agreement Or 3 years after the last activity on your account |
| For responses to inquiries about our products | 3 years after your last date of contact |
| For managing and responding to your requests to exercise rights under the French Data Protection Act | 1 year in the case of exercising the right to access or rectify 3 years in the case of exercising the right to object |
7.YOUR RIGHTS
In accordance with the French Data Protection Act and the GDPR, you have the following rights :
- the right to access (article 15 RGPD), rectify (article 16 RGPD), update and complete your data (more details)
- the right to block or erase your personal data (article 17 RGPD), where it is inaccurate, incomplete, ambiguous, outdated, or where its collection, use, disclosure or retention is prohibited (more details)
- the right to withdraw your consent at any time (article 13-2c RGPD)
- the right to restrict processing of your data (article 18 RGPD)
- the right to object to processing of your data (article 21 RGPD) (more details)
- the right to portability of the data you provided to us, where your data is subject to automated processing based on your consent or on a contract (article 20 RGPD)
- the right to define what becomes of your data after your death and to decide whether (or not) we disclose your data to a third party you designate in advance (more details).
In the event of death, and in the absence of instructions from you, we undertake to destroy your data, unless its retention is necessary for proof purposes or to meet a legal requirement.
You may exercise your rights by sending an e-mail to dpo@ventilairsec.com or a letter to Ventilairsec, 16 rue des Imprimeurs, 44220 Couëron, France.
Lastly, you may also lodge a complaint with the supervisory authorities, in particular, CNIL (https://www.cnil.fr/fr/plaintes).
8.TRANSFER OUTSIDE THE EUROPEAN UNION
Ventilairsec undertakes not to transfer your data outside the European Union.
In the event that Ventilairsec uses providers located outside the European Union, Users shall be informed, as early as possible, of the conditions of such transfer, in particular, the measures taken by Ventilairsec to ensure the privacy and security of their data.
9.DATA SECURITY
Ventilairsec and its data processors, if any, undertake to implement all technical and organisational means to ensure the security of personal data processing and the privacy of your data, in accordance with the French Data Protection Act and the GDPR.
To this end, Ventilairsec shall take all necessary precautions, in view of the nature of your data and the risks posed by our processing, to preserve the security of the data and, in particular, prevent it from being altered or damaged, or prevent unauthorised third parties from having access to it (physical protection of premises, authentication process for our customers with personal and secure access via confidential logins and passwords, connection logging, encryption of certain data, etc.).
