WMH Project PRIVACY AND DATA PROTECTION POLICY

 

WMH Project, SAS company with a share capital of €373 337,70 euros, recorded at Nanterre trade register, under number 420 423 420, is located 4, place des Saisons – 92400 Courbevoie. WMH Project is a group of different subsidiaries specialised in the organisation of professional events, the creation of stands and content

 

In accordance with Article 27 of the GDPR, WMH Project, SAS company with a share capital of €373 337,70, recorded at Nanterre trade register, under number 420 423 420, and located 4 place des Saisons – 92400 Courbevoie is the representative appointed by the WMH Project Group within the European Union.

 

WMH Project's priority is to continuously improve its services in order to best meet the needs of its Clients.

For this purpose, we may collect and store certain information, including personal data, about individuals such as you.

Protecting your personal data is an aspect that we take very seriously in all of our business processes and about which we want to be transparent.

 

The purpose of this document is to define the conditions under which WMH Project undertakes to carry out the processing of personal data.

In the context of their contractual relations, the parties undertake to comply with the regulations in force applicable to the processing of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applicable from 25 May 2018.

 

It would be very difficult, if not impossible, in most countries, to offer you our services if you do not allow us to process your data.

 

As a result, by providing personal data to WMH Project, you agree to the legally binding nature of this Privacy and Data Protection Policy, as amended from time to time, and expressly consent to it. WMH Project may not process your personal data if you do not agree to this Privacy and Data Protection Policy or if you cannot enter into a binding contract.

 

 

 

1. Scope of the Privacy and Data Protection Policy

This Privacy and Data Protection Policy applies to all services offered by WMH Project.

It does not apply to services offered by other companies or natural persons. It does not concern the practices followed in the processing of information by other companies and organisations that advertise WMH Project services or apply to third parties operating websites to which the WMH Project website or its other digital assets may refer.

 

 

 

2. Data collected and method of collection

WMH Project collects general data and personal data about you:

  • From you when you provide it with your information and contact details;
  • From its Clients (in this case the Client must ensure that it is duly authorised to disclose such information and that you are aware of the different points detailed in this Privacy and Data Protection Policy);
  • From participants in meetings and events it organises for its Clients;
  • From users of its website or those of its Clients; and through third parties (such as online service providers or single authentication services).

Upon receipt of data, WMH Project creates an electronic profile for each individual or entity (the "Contact Profile") in its tools.

 

The Contact Profile may include the following information:

  • name;
  • gender;
  • date of birth;
  • address;
  • telephone numbers :
  • email addresses;
  • nationality;
  • physical location data during an event;
  • food preferences or allergies;
  • information on the person to be contacted in the event of an emergency;
  • name of employer and/or position;
  • business sector and/or interests;
  • credit card references/numbers;
  • travel destinations;
  • travel programmes;
  • travel preferences ;
  • hosting preferences;
  • other preferences communicated;
  • passport information;
  • visa information;
  • additional information requested by Clients for the relevant events;
  • company's workforce;
  • turnover of the company;
  • date of creation of the company

 

By participating in an event, the data subject consents, free of charge and without any consideration whatsoever, to the use, reproduction, modification and dissemination on any existing or future medium of the sound and visual recordings made in connection with the event by video and/or audio recording, and/or photographs, on which he or she appears and, in particular, on the social networks or sites of any WMH Project group company within the meaning of the regulations in force, or their partners, throughout the usage period of the video and/or audio recordings, and/or the photographs.

 

 

 

3. Purposes of data collection

WMH Project uses the data collected to ensure, preserve, protect and improve the overall quality of its services.

Data collection is also a way of protecting it and protecting its users.

WMH Project limits the collection of data to what is strictly necessary to achieve these purposes.

 

In addition to creating Contact Profiles, WMH Project uses your data for the following purposes for which you grant consent:

  1. a) Bookings and on-line registration : Contact Profiles are stored in a database as a reference document consulted when making a reservation or performing on-line registration at a digital event.

 When a reservation is made, WMH Project creates a reservation code that contains all personal data and booking information necessary to meet your request and comply with the regulatory requirements of certain destinations.

To make reservations, WMH Project may transfer your personal data to different third-party travel providers (such as airlines, hotels, car rental companies, online booking tools, geolocation tool providers for security and safety purposes, and computer reservation systems) based in your country of origin or in a country of destination or transit and also to government entities of certain destinations.

Legal basis: consent, contract.

 

  1. b) Consolidation of travel data : at the request of a Client, WMH Project or a third party may prepare information reports that summarise and analyse expenses by destination, travel provider, etc. These reports, which may contain personal data from your Contact Profile, are then provided to the Client who requested them.

Legal basis: consent, legitimate interest.

 

  1. c) Compliance with the travel policy: at the request of a Client, WMH Project may prepare a report on compliance with the event's compliance policy, the Client's budgetary compliance policy or travel policy and identify any deviations in compliance.

Legal basis: consent, legitimate interest.

 

  1. d) New products and services: to improve its services, and on the basis of the data provided to it, WMH Project may provide you with additional information about the events and/or current or future trips. This may include the list of restaurants near a specific hotel in the destination city or the list of car parks at the departure airport.

    Legal basis: consent, legitimate interest.

Legal basis: consent, legitimate interest.

 

  1. e) Promotion and marketing: WMH Project may use your data to personalize your experience on its website by presenting you with more relevant advertising, sending you marketing communications that may be of interest to you, including information about our services, case studies, thought leadership articles or white papers, blog updates, etc. WMH Project uses third-party service providers to present services and offers tailored to the preferences and interests determined by your online activity over time.

WMH Project may use your data for promotional and marketing purposes for its current Clients or prospective Clients and/or for third parties in its business line.

WMH Project may use your data to personalize your experience on the website of the event by presenting you with more relevant advertisements and sending you marketing communications you have chosen when registering.

WMH Project may use your data to analyse trends and offer other services to its Clients, such as new events or other services. Legal basis: consent, legitimate interest.

 

  1. f) Technical data: WMH Project, or third parties whom it instructs, evaluates this data for purely statistical purposes and only anonymously, in order to optimise its website and improve its usability, efficiency and security.

WMH Project may, in particular, use technical data to measure the success of its marketing campaigns, compile statistics on the use of its website and response rates, and use aggregated personal data to calculate the percentage of users of its website with a specific telephone code.
Legal basis: consent, legitimate interest.

Legal basis: consent, legitimate interest.

 

  1. g) Other purposes: WMH Project may use your data for such purposes as it deems necessary or appropriate: (a) under applicable legislation, including the laws in force outside your country of residence; (b) to comply with legal proceedings; (c) to respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (d) to enforce its terms and conditions; (e) to protect its activities; (f) to protect its rights, confidentiality, security or property, to protect you or protect other persons; (g) to make use of all available remedies or limit the damage it may undergo; and (h) to allow you to respond to one of its offers of employment.

    Legal basis: consent, legitimate interest.

Legal basis: consent, legitimate interest.

 

WMH Project will ask you to express your consent before using your data for a purpose other than those set out in this Policy, subject to applicable mandatory provisions.

 

 

 

4. Obligations of the agency in its capacity as data processor

  1. a) General

WMH Project undertakes to:

  • Process the data only for the sole purpose(s) for which it is subcontracted

 

  • Process the data in accordance with the documented instructions of the CLIENT, contained in the Agreement. If WMH Project considers that an instruction constitutes a violation of the regulations in force, or any other provision of European Union law or the law of the Member States relating to data protection, it shall immediately inform the CLIENT. Furthermore, if WMH Proejct is required to carry out a transfer of data to a third country or an international organisation, under the law of the European Union or the law of the Member State to which it is subject, it must inform the CLIENT of this legal obligation prior to processing, unless the relevant law prohibits such notification on important grounds of public interest;

 

  • Ensure the confidentiality of the personal data processed under this Agreement;

 

  • Ensure that persons authorised to process personal data under this Agreement:

 

  • Undertake to respect confidentiality or be subject to an appropriate legal obligation of confidentiality,

 

  • Receive the necessary training on the protection of personal data;

 

  • Take into account, with regard to its tools, products, applications or services, the principles of data protection by design and data protection by default.

 

  • - Keep a record of the processing operations on personal data carried out on behalf of the client, in accordance with the Regulations in force.

 

  • Work with the client in the event of future changes in the Regulations in force, to consider the updates necessary to bring them into compliance.

 

  1. b) Subcontracting

To perform its services, WMH Project uses its own subcontractors (hereinafter referred to as "sub-processors"), listed in Appendix 1.

 

Sub-processors are required to comply with the obligations of the Agreement. The AGENCY is responsible for ensuring that sub-processors have the same sufficient guarantees as to the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the Regulation. If sub-processors fail to meet their data protection obligations, the Provider shall remain fully liable to the Controller for the performance of its obligations by the other processors.

 

 

5. Retention period

WMH Project will retain general data and personal data for as long as reasonably necessary, taking into account its need to respond to requests or to resolve problems, to provide improved services and new services, and to comply with legal requirements under applicable law or requests from its Clients relating to past travel events or activities. WMH Project will retain the general data and personal data for a maximum period of five years in an active database in the absence of any specific legal requirement.

WMH Project will retain the data of candidates for an offer of employment for a maximum period of two years.

You can cancel/delete your WMH Project account by sending an e-mail to our Data Protection Officer at dpo@wmhproject.fr.

 

6. Storage site and database controller

The Contact Profiles managed by WMH Project are stored in central cloud databases via third-party service provider physical facilities located in Europe. These third-party service providers have signed our specific data protection clauses.

Here is a non-exhaustive list of our service providers:

  • Captag
  • Netkin
  • SpotMe
  • NewTelaps
  • Digitevent
  • Newbeatprod
  • Dromis
  • Viewon

 

Internally, Sébastien LAGNEL is our data controller.

Your data will only be transferred outside the European Economic Area after adequate safeguards have been put in place, such as signing a contractual agreement, in accordance with applicable data protection laws and regulations.

 

 

7 Your obligations

You must ensure that the data you provide to us is :

  • correct ;
  • accurate;
  • up-to-date;
  • sincere; and
  • in compliance with all applicable laws.

In particular, to the extent that our communications will be made primarily by email, you are asked to notify us of any changes to your email address. You can also change it directly in your Contact Profile.

WMH Project is committed to respecting the privacy right of minors and we strongly encourage parents and guardians to play an active role in the online activities of their children or wards. WMH Project does not use its digital assets to target minors under fourteen (14) years of age or knowingly collect information from children for the purpose of selling products or services.

 

 

Data transfer and communication

a) General provisions

WMH Project is a global group with offices in Europe and Asia.

As a result, your personal data may be transferred to and outside Switzerland, including to countries where data protection laws may differ and be less stringent than those applied in your country of residence.

You hereby expressly agree and authorise WMH Project to transfer and disclose your data as follows:

 

1) Transfers within the WMH Project group: Transfers are made within WMH Project and its subsidiaries in support of its activities and/or services.

 

2) Transfers to third parties: WMH Project solicits the assistance of third parties in connection with travel services, organising meetings and events and/or other services it provides to its clients (such as emergency online booking services, hotel booking services, ground transportation services, air ticket issuance services, badge providers) and will share personal data with these third parties in certain circumstances for the purposes of its mission and objectives.

WMH Project may also transfer personal data to third parties at the request of its Clients. These may include sponsors and exhibitors or other third parties for the purpose of data consolidation or monitoring services for the purpose of generating statistics.

During events or congresses, sponsors or exhibitors may scan the badges of participants or delegates, with their consent.

Therefore, the collection and use of the personal data thus created is governed by the privacy policy of each sponsor or exhibitor. WMH Project may transfer your data to third parties for promotional and marketing purposes as set out in point 3e) above.

WMH Project may also transfer your data to a third party in connection with any reorganisation, merger, sale, common interest, assignment, transfer or other disposal of all or part of its business, assets or inventories (including in the context of bankruptcy proceedings or similar proceedings). Prior to a data transfer, third parties (with the exception of travel providers and authorised transfers as is the case within the EU) are asked to sign a data transfer agreement by which they undertake to comply with applicable data protection legislation.

 

3) Regulatory transfers: WMH Project may be legally required to transfer data to governments and regulatory and/or supervisory authorities.

 

b) Electronic data transfer

If you visit any of the websites belonging to WMH Project, your data will be transmitted through a public open network. It can therefore be transmitted without limits of borders. It is therefore at risk of being intercepted and read by third parties, which would allow them to infer an existing or future business relationship between yourself and WMH Project.

 

In addition, the information you transmit or authorise WMH Project to transmit electronically, in particular by e-mail, SMS, contact form, etc. is generally not encrypted and, as such, it is neither confidential nor secure. And, even in the case of encrypted transmission, the sender and recipient are never encrypted. Third parties can therefore infer an existing or future business relationship between yourself and WMH Project.

In case of disclosure of personal information to WMH Project, we may transfer your personal data to countries where data protection laws may differ and be less stringent than those applied in your country of residence, as already indicated above. In particular, it may be transferred to the United States. You should therefore know that the government authorities of these countries (and in particular the US authorities) may have access to your personal data.

 

 

9. Security and organisational measures

To ensure the security of your data on its websites and systems, WMH Project has put in place appropriate technical, contractual, administrative, physical and organisational measures to protect your personal data from loss, destruction, unauthorised access, and any accidental or unlawful disclosure and alteration. These measures are continuously developed in line with technological advances and are regularly reviewed to ensure compliance with all applicable privacy laws. However, we cannot guarantee, and do not guarantee, the security of your personal data and therefore reject all liability in this respect.

Only authorised WMH Project personnel, third-party company personnel (that is, service providers) and authorised personnel of our Clients (who have contractually agreed to maintain the security of all information) have access to your personal data. All WMH Project employees who have access to your personal data are required to comply with the confidentiality rules applicable to staff, and all third-party employees who have access to your personal data have signed confidentiality agreements. In addition, data transfer agreements have been signed with third-party companies that have access to your personal data in order to protect its security.

 

 

10. Your rights

In accordance with applicable data protection laws and regulations, you have a right of access, a right to rectification of your data, a right to restrict the processing of your data and to object to such processing, as well as the right to data portability to the extent provided. In addition, you have the right to refer the matter to the supervisory authority.

 

Under certain conditions, you also have the right to block and have the personal data held by WMH Project erased, unless it is retained for legitimate purposes or for legal purposes. For further information, please contact the Data Protection Officer at the above-mentioned email address.

 

In case of questions or problems with the data processing carried out by WMH Project, you should contact the Data Protection Officer at privacy@wmhproject.fr.

In accordance with the GDPR, WMH Project grants you many rights to the use and disclosure of your personal data for marketing purposes (right to erasure, right to rectification, right to restriction of processing, etc.).

You may contact the Data Protection Officer at the address indicated above to exercise your right of objection to no longer receive the electronic marketing messages sent by WMH Project and to request that we do not share your personal data with unaffiliated third parties for the purposes of their marketing objectives.

WMH Project will make every effort to meet your request(s) as soon as possible.

Please note, however, that WMH Project will not be able to delete your personal data from the databases of unaffiliated third parties with which it has already shared it (that is, those to whom we have already provided your personal data on the date of application of your objection request) even in the context of exercising your right of objection as indicated above. Please also note that we may always send you important administrative messages and that you cannot object to their receipt even if you exercise your right to object to our marketing messages.

 

11. Amendments

WMH Project may revise and update this Policy in order to comply with applicable privacy and data protection laws. WMH Project will post any changes to this Policy on its website and, in the event of major changes, will notify you by email at the email address indicated in your Contact Profile.

 

 

12. Contact

Please contact our Data Protection Officer for further assistance.

E-mail: dpo@wmhproject.fr

Address: Tour Alto, 4 place des Saisons - 92400 Courbevoie