Personal Data Protection Policy
Schneider Electric Foundation
Under the aegis of the Fondation de France
1 – Preamble
Fondation de France and its sheltered foundations* are particularly attentive to the protection of privacy and personal data.
The aim of this policy is therefore to inform you about the principles and guidelines implemented by Fondation de France and its sheltered foundations with regard to the processing of personal data. It applies to all data processing carried out by Fondation de France and its sheltered foundations via their websites and in the context of their external relations, regardless of the nature thereof.
*Foundations sheltered by Fondation de France have no legal personality. Fondation de France therefore acts in the capacity of data controller. Consequently, the principles and guidelines presented in this policy apply to the sheltered foundations under the same terms, unless indicated otherwise.
2 – Definitions
“¨Personal data”: any information making it possible to identify a natural person, whether directly or indirectly.
“Data processing”: any operation carried out on personal data, such as their collection, conversion, use, transmission or communication.
“Data controller”: legal entity responsible for determining the purposes of the processing and the means employed.
3 – Undertakings
Fondation de France, in its capacity as data controller, and its sheltered foundations undertake to collect and process your personal data in accordance with the provisions of French law no. 78-17 of 6 January 1978 as amended (the French Data Protection Act) and the European Regulation of 25 May 2018 on data protection (hereinafter referred to as the “GDPR").
In order to ensure compliance with these rules, Fondation de France has appointed a Data Protection Officer to be the primary point of contact for the Commission Nationale de l’Informatique et des Libertés (the French data protection authority, hereinafter referred to as the “CNIL”) and the lead within the organisation for issues concerning personal data protection. He fulfils the same role with regard to the sheltered foundations.
Should you have any questions concerning this policy, you may therefore contact the Data Protection Officer of Fondation de France at the following address: [email protected].
4 – Data Collected
Fondation de France and its sheltered foundations* seek to only collect and process personal data that are relevant, appropriate, non-excessive and strictly necessary for the purposes for which they are processed.
Fondation de France may have to collect various categories of personal data, including but not limited to the following:
Fondation de France processes identification data when you submit a request to receive information, open an account, receive newsletters or exercise your data protection rights. It also processes this type of data to maintain its relations with third parties, such as donors, founders and service providers. This may, for example, include your first name and surname, among other things.
Fondation de France processes contact data to maintain its relations with third parties and respond to the different types of request indicated above. These data also enable it to respond to applications for jobs / internships / work-study placements and voluntary work. In the context of calls for projects, these data enable it to communicate with project leaders in order to process their application and inform them of its progress. This may, for example, include your address, email address and telephone number, among other things.
Fondation de France processes application data in order to consider, respond to and examine the quality and pertinence of applications for offers of employment / internships / work-study placements and voluntary work. It may therefore collect information pertaining to your qualifications and professional experience. In the context of calls for projects, these data enable it, in particular, to evaluate and select applications by project leaders. The data collected vary according to the projects and may concern the project leader’s professional experience and academic background (covering letter, CV etc.) or information concerning the project itself.
- Transaction data, payment data and other economic and financial information.
Fondation de France processes transaction and payment data when you decide to pass on your estate (gifts, bequests, donations etc.) and in connection with the consequences thereof (issuance of tax receipts etc.).
Fondation de France processes connection data when you access its various digital portals (donor area, founder area, project leader area, TalentSoft applicant area). This may, for example, include information relating to your login details.
Mandatory data is indicated by an asterisk in the personal data forms accessible via the Fondation de France’s websites.
* The sheltered foundations may have to collect different categories of personal data and are not always concerned by all the categories indicated above.
5 – Purposes and Legal Bases of Collection
The processing operations carried out by Fondation de France and its sheltered foundations* are done so for explicit, legitimate and specified purposes.
These purposes are primarily as follows:
- Management of your requests (information, account creation, sending of newsletters);
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, namely its interest in responding to the requests it receives.
- Management of your applications (voluntary work, employment and/or work placements);
In this context, the legal basis for the processing is the implementation of pre-contractual measures.
- Communication and fundraising campaigns;
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, namely its interest in communicating information concerning its actions, raising funds to pursue its objects and measuring the results of its marketing campaigns.
- Management of gifts and donor relations;
In this context, the legal basis of the processing is compliance with its legal obligation to issue a tax receipt and the legitimate interest of Fondation de France, namely its interest in securing donor loyalty and conducting analyses of the gifts it collects.
- Management of relations with prospects;
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, namely its interest in maintaining relations with potential donors, testators and founders in order to secure their support.
- Management of relations with service providers and suppliers;
In this context, the legal basis of the processing is the performance of contracts binding Fondation de France to its service providers and suppliers, as well as compliance with its legal obligations in terms of accounting.
- Management of the process for the selection, assessment and implementation of projects;
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, namely its interest in examining the funding applications it receives, informing applicants of the progress of their applications and funding the selected projects.
- Management of the creation and life cycle of the sheltered foundations;
In this context, the legal basis of the processing is the performance of contracts binding Fondation de France to its sheltered foundations.
This purpose is specific to Fondation de France.
- Management and monitoring of the processing of donations.
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, namely its interest in managing the donations it receives and ensuring the traceability of their processing.
- Analysis of your browsing history (please see our cookie policy);
In this context, the legal basis for the processing is the legitimate interest of Fondation de France, with regard to cookies strictly necessary for the operation of websites, and consent for all other types of cookies (cookies for targeted advertising, “social network” cookies, functional cookies and audience measurement cookies).
- Management of the exercising of your rights.
In this context, the legal basis for the processing is the legal obligation of Fondation de France, namely its obligation to respond to requests by data subjects wishing to exercise their rights and to inform them of their rights.
*Data collected by the sheltered foundations vary from one sheltered foundation to another. Consequently, not all the purposes specific to each sheltered foundation are presented in this policy. Those specific to Fondation de France are indicated accordingly.
6 – Recipients of the Collected Data
Fondation de France and its sheltered foundations only pass on your personal data to authorised and specified recipients.
As the sheltered foundations lack any legal responsibility, Fondation de France is also the recipient of certain data they collect.
Access to your personal data is therefore limited to Fondation de France’s internal departments and to third partied appointed by Fondation de France to carry out certain processing. These third parties only act on the instructions of Fondation de France and only have access to those data necessary for them to perform their services. These third parties are also contractually bound by an obligation of confidentiality and security with regard to your personal data, as provided by the legislation in force.
Your personal data are under no circumstances transferred or passed on to other third parties, with the exception of partners in the charity sector.
The sheltered foundations respect under the same terms the principles laid down by Fondation de France on this subject.
7- Retention of the Collected Data
Fondation de France only retains your personal data for as long as is necessary given the purposes for which they were collected and in compliance with the legislation in force. Fondation de France may retain your personal data for longer, however, in particular in order to fulfil its legal obligations or for evidentiary purposes.
The sheltered foundations respect under the same terms the principles laid down by Fondation de France on this subject.
8 – Security of the Collected Data
Fondation de France seeks to protect your personal data. Fondation de France therefore implements appropriate technical and organisational security measures to avoid any alteration, loss or unauthorised access to your personal data.
Although Fondation de France ensures the security of your personal data, no transmission of data via the Internet is completely secure. Fondation de France cannot, therefore, guarantee the security of the information you transmit to it via the Internet.
The sheltered foundations respect under the same terms the Fondation de France’s policy regarding the security of collected data.
9 – Transfer of the Collected Data
Fondation de France outsources certain processing operations and may, in this context, transfer data outside the European Union. With regard to such transfers, Fondation de France undertakes to enter into contractual clauses with the third parties concerned guaranteeing a suitable level of protection for your personal data.
The sheltered foundations respect under the same terms the Fondation de France’s policy regarding the transfer of collected data.
10 - Exercising of Data Subjects’ Rights
Pursuant to the applicable data protection regulations, you have a right of access and rectification with regard to your personal data. In certain cases, you also have the right to demand the erasure of your data, the right to restrict or oppose their processing and a right to their portability. You can also set out general instructions for the fate of your personal data and how you would like your rights to be exercised after your death.
These rights may be exercised by contacting Fondation de France’s Data Protection Officer by email at [email protected] or by post at the following address:
Fondation de France
Data Protection Officer
40 avenue Hoche
75008 Paris
Data subjects’ rights with regard to the sheltered foundations are exercised under the same terms, accompanied by an additional indication of the sheltered foundation concerned.
11 – Right of Complaint
Pursuant to the applicable regulations, you have the right to lodge a complaint with the CNIL.
This may be submitted online at https://www.cnil.fr/fr/plaintes or by post at the following address:
Commission Nationale de l'Informatique et des Libertés
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
12 – Amendments
Fondation de France may update this policy at any time to adapt it to new practices, if the legal and regulatory framework requires or in line with CNIL guidelines. In this case, the version date of this policy will be updated. You are responsible for verifying the updates to this policy on Fondation de France’s websites.