WMH Project PRIVACY AND DATA PROTECTION POLICY
WMH Project, a simplified joint stock company with a capital of 373,337.70 euros, registered in the Nanterre Trade and Companies Register under the number 402 423 420, whose head office is located at 4, place des Saisons, 92400 Courbevoie. The WMH Project group is composed of various subsidiaries specialized in the organization of professional events, travel, and the creation of stands and content.
In accordance with Article 27 of the RGPD, WMH Project, a simplified joint stock company with a capital of 373,337.70 euros, registered in the Nanterre Trade and Companies Register under the number 402 423 420, whose registered office is located at 4, place des Saisons, 92400 Courbevoie, is the designated representative of 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.
The protection of your personal data is something we take very seriously in all our business processes and we want to be transparent about it.
The purpose of this document is to define the conditions under which WMH Project undertakes to manage personal data processing operations.
In the context of their contractual relationship, 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 as of 25 May 2018.
It would be very difficult, if not impossible in most countries, for us to offer you our services if you do not give us permission to process your data.
Accordingly, by communicating personal data to WMH Project, you agree to the legally binding nature of this Confidentiality and Data Protection Policy, as it may be amended from time to time, and explicitly consent to it. WMH Project will not be able to process your personal data if you do not accept this Confidentiality and Data Protection Policy or if you are unable to conclude 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 and its subsidiaries.
It does not apply to services offered by other companies or individuals. It does not apply to the information processing practices of other companies and organizations that advertise WMH Project's services, nor does it apply to third-party operators of websites to which WMH Project's website or other digital assets may link.
2. Data collected and method of collection
WMH Project collects general and personal data about you through :
- Your bias when you provide your information and contact details;
- The participants of the meetings and events it organizes for its Clients;
- Through users of its website or those of its Clients; and through third parties (such as online service providers or single sign-on services).
Upon receipt of the 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:
- date of birth ;
- telephone numbers :
- e-mail addresses;
- physical location data during an event;
- food preferences or allergies ;
- emergency contact information;
- name of employer and/or position ;
- sector of activity and/or interests ;
- references/credit card numbers ;
- travel destinations ;
- travel programs ;
- travel preferences ;
- accommodation preferences ;
- other preferences communicated ;
- passport information ;
- visa information ;
- additional information requested by Clients for the events concerned
- Number of employees in the company
- Company's turnover
- Date of creation of the company
By participating in an event, the person concerned 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 means of video and/or audio recordings and/or photographs in which he or she is featured, and in particular on the social networks or websites of any company in the WMH Project group within the meaning of the regulations in force, or their partners, for the entire duration of the exploitation of the video and/or audio recordings and/or photographs.
3. Purpose of data collection
WMH Project and its subsidiaries use the data collected to ensure, preserve, protect and improve the overall quality of its services.
Collecting data is also a way to protect it and its users.
WMH Project and its subsidiaries limit the collection of data to that which is strictly necessary to achieve these purposes.
In addition to creating Contact Profiles, WMH Project and its affiliates use your data for the following purposes to which you consent:
- a) Reservations and online registration: Contact Profiles are kept in a database as a reference document consulted when making a reservation or registering online for a digital event.
When a reservation is made, WMH Project and its affiliates will create a reservation code that contains all the personal data and reservation information necessary to fulfill your request and to comply with regulatory requirements for certain destinations.
In order to make reservations, WMH Project and its subsidiaries may have to transfer your personal data to various third-party travel service providers (such as airlines, hotels, car rental companies, online reservation tools, providers of geolocation tools for the purposes of security and safety, and computer reservation systems) based in your country of origin or in a country of destination or transit and also to the government entities of certain destinations.
Legal basis: consent, contract.
- b) Consolidation of travel data: at the request of a Client, WMH Project and/or its subsidiaries and/or a third party may prepare information reports that summarize and analyze expenses by destination, by travel provider, etc. These reports, which may contain personal data from your Contact Profile, are then given to the Client who requested them.
Legal basis: consent, legitimate interest.
- c) Travel Policy Compliance: At the request of a Client, WMH Project and its affiliates may report on compliance with that Client's event compliance policy, budget compliance policy, or travel policy and identify any compliance gaps.
Legal basis: consent, legitimate interest.
- d) New products and services: with a view to improving its services, and on the basis of the data communicated to it, WMH Project and its subsidiaries may send you additional information relating to events and/or trips currently planned or to come. This may include a list of restaurants near a specific hotel in the destination city or a list of parking lots at the departure airport.
Legal basis: consent, legitimate interest.
- e) Promotion and marketing: WMH Project and its subsidiaries may use your data to personalize your experience on its website by presenting you with more relevant advertisements, sending you marketing communications that may be of interest to you, including information about our services, case studies, thought leadership or white papers, blog updates, etc. For example, WMH Project and its affiliates use third-party service providers to present services and offers tailored to the preferences and interests determined by your online activity over time.
WMH Project and its subsidiaries may use your data for promotional and marketing purposes for its current or prospective Clients and/or for third parties in its sector of activity.
WMH Project and its affiliates may use your data to personalize your experience on the event website by presenting you with more relevant advertisements and sending you marketing communications that you selected during registration.
WMH Project and its subsidiaries may use your data to analyze trends and to offer other services to its Clients, such as new events or other services.
Legal basis: consent, legitimate interest.
- f) Technical data: WMH Project, its subsidiaries or third parties instructed by them, evaluates this data for purely statistical purposes and only in an anonymous manner, in order to optimise its website and improve its usability, efficiency and security.
WMH Project and its subsidiaries may, in particular, use technical data to measure the success of its marketing campaigns, compile statistics on the use of its website and on 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.
- g) Other purposes: WMH Project and its subsidiaries may use your data for the purposes that it considers necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (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 business; (f) to protect its rights, privacy, safety or property, to protect you or others; (g) to pursue all available remedies or limit the damages it may sustain; and (h) to allow you to respond to any of its employment opportunities.
Legal basis: consent, legitimate interest.
WMH Project and/or its subsidiaries will ask you to express your consent before using your data for a purpose other than those presented in this Policy, subject to the applicable mandatory provisions.
4. Obligations of the agency as a subcontractor
- a) General
WMH Project and its affiliates are committed to:
- Process data only for the sole purpose(s) for which it is outsourced;
- To process the data in accordance with the documented instructions of the CLIENT, set out in the Contract. If WMH Project and its subsidiaries consider that an instruction constitutes a violation of the Regulations in force, or of any other provision of Union law or of the law of the Member States relating to data protection, it shall immediately inform the CLIENT thereof, if WMH Project and its subsidiaries are obliged to transfer data to a third country or to an international organisation, by virtue of the law of the Union or the law of the Member State to which it is subject, it must inform the CLIENT of this legal obligation prior to the processing, unless the law concerned prohibits such information for important reasons of public interest;
- To guarantee the confidentiality of personal data processed under this Contract;
- Ensure that persons authorized to process personal data under this Agreement:
- Are committed to confidentiality or are subject to an appropriate legal obligation of confidentiality,
- Receive the necessary training in the protection of personal data;
- Consider the principles of data protection by design and data protection by default for its tools, products, applications or services.
- To keep a record of the personal data processing operations carried out on behalf of the client, in accordance with the Regulations in force.
- Collaborate with the client in the event of future changes in the regulations in force, in order to consider the updates necessary to comply with them.
- b) Subcontracting
In order to carry out its services, WMH Project and its subsidiaries call upon its own subcontractors (hereinafter referred to as "subsequent subcontractors"), listed in Appendix 1.
Subsequent subcontractors are required to comply with the obligations of the Contract. It is the responsibility of WMH Project and its subsidiaries to ensure that the subsequent subcontractors present the same sufficient guarantees regarding the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the Regulation. If the sub-processors do not fulfill their data protection obligations, the Provider shall remain fully responsible to the Controller for the performance by the other sub-processors of their obligations.
5. Shelf life
WMH Project and its subsidiaries will retain general and personal data for the maximum reasonable period of time necessary, taking into account the need to respond to requests or resolve problems, to provide improved and new services, and to comply with legal requirements under current legislation or requests from its Clients relating to past travel events or activities. WMH Project and its affiliates will retain general and personal data for a maximum of five years on an active basis in the absence of any specific legal requirements.
WMH Project and its affiliates will retain the data of job applicants for a maximum of two years.
You can cancel/delete your WMH Project account by sending an email to our Data Protection Officer at firstname.lastname@example.org.
6. Site of conservation and responsible for the treatment of the database
The Contact Profiles managed by WMH Project and its subsidiaries are stored in central databases in the cloud via the physical facilities of third-party providers located in Europe. These third-party service providers have signed our specific clauses relating to data protection.
Here is a non-exhaustive list of our providers:
Internally, Sébastien LAGNEL is our data controller.
Your data will only be transferred outside the European Economic Area after adequate safeguards, such as a contractual agreement, have been put in place in accordance with applicable data protection laws and regulations.
7. your obligations
You must ensure that the data you provide to us is :
- correct ;
- exact ;
- to date;
- sincere; and
- comply with all applicable laws.
In particular, since our communications will be primarily by e-mail, you are requested to notify us of any changes to your e-mail address. You can also change it directly in your Contact Profile.
WMH Project and its affiliates will respect the privacy rights of minors and we strongly encourage parents and guardians to take an active role in their children's or wards' online activities. WMH Project and its affiliates will not use its digital assets to target minors under the age of fourteen (14) or to knowingly collect information from children for the purpose of selling products or services.
8. Transfer and communication of data
a) General stipulations
The WMH Project Group and its subsidiaries have offices in Europe and Asia.
As a result, your personal data may be transferred to and from Switzerland, including to countries where data protection laws may be different and less stringent than those applied in your country of residence.
You hereby expressly agree and authorize WMH Project and its affiliates 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 and its affiliates solicits certain third parties for support services in connection with travel, meeting and event planning and/or other services it provides to its clients (such as emergency online booking services, hotel reservation services, ground transportation services, airline ticketing services, badge providers) and will, under certain circumstances, share personal data with such third parties for the purposes of its mission and objectives.
WMH Project and its subsidiaries may also transfer personal data to third parties at the request of its Clients. This may include sponsors and exhibitors or other third parties for the purposes of data consolidation or monitoring services with a view to generating statistics.
At events or conventions, sponsors or exhibitors may scan attendees' or delegates' badges with their consent.
WMH Project and its subsidiaries may also transfer your data to a third party in the context of any reorganisation, merger, sale, joint venture, assignment, transfer or any other form of disposal of all or part of its business, assets or stocks (in particular in the context of bankruptcy proceedings or any similar proceedings). Prior to a data transfer, third parties (with the exception of travel providers and authorized transfers such as within the EU) are required to sign a data transfer agreement in which they agree to comply with applicable data protection legislation.
3) Regulatory Transfers: WMH Project and its affiliates may be legally required to transfer data to governments as well as regulatory and/or supervisory authorities.
b) Electronic data transfer
If you visit one of the WMH Project websites, your data will be transmitted via a public open network. It can therefore be transmitted without border restrictions. There is therefore a risk that it may be intercepted and read by third parties, which would enable them to infer an existing or future professional relationship between you and WMH Project and its subsidiaries.
In addition, the information that you transmit or that you authorize WMH Project and its subsidiaries to transmit to you electronically, in particular by e-mail, SMS, contact form, etc., is generally unencrypted and, as a result, it is neither confidential nor secure. Even in the case of encrypted transmission, the sender and recipient are never encrypted. Third parties can therefore infer an existing or future professional relationship between you and WMH Project and its subsidiaries.
In the event that personal information is communicated to WMH Project and its subsidiaries, we may have to transfer your personal data to countries where the laws relating to data protection may differ and be less strict than those applied in your country of residence, as indicated above. In particular, it may be transferred to the United States. You should therefore be aware that government authorities in these countries (and in particular the US authorities) may have access to your personal data.
9. Security and organizational measures
To guarantee the security of your data on its websites and in its systems, WMH Project and its subsidiaries have put in place the appropriate technical, contractual, administrative, physical and organizational measures to protect your personal data from loss, destruction, unauthorized access, and accidental or illicit disclosure and alteration. These measures are continuously developed as technology advances and are regularly reviewed to ensure compliance with all applicable privacy laws. However, we cannot and do not guarantee the security of your personal data and therefore disclaim any liability in this regard.
Only authorized personnel of WMH Project and its subsidiaries, personnel of third party companies (i.e., service providers) and authorized personnel of our Clients (who have contractually agreed to keep all information secure) have access to your personal data. All employees of WMH Project and its affiliates who have access to your personal data are required to comply with applicable personnel confidentiality rules, and all employees of third parties who have access to your personal data have signed confidentiality agreements. In addition, agreements relating to the transfer of data have been signed with third-party companies that have access to your personal data in order to preserve its security.
10. Your rights
In accordance with the applicable data protection laws and regulations, you have the right to access, rectify, limit and object to the processing of your data, as well as the right to data portability to the extent provided. In addition, you have the right to appeal to the supervisory authority.
Under certain conditions, you also have the right to block and have deleted your personal data kept by WMH Project and its subsidiaries, unless they are kept for legitimate purposes or legal purposes. For any further information, you should contact the Data Protection Officer at the e-mail address indicated above.
If you have any questions or problems with the data processing carried out by WMH Project and its subsidiaries, you should contact the Data Protection Officer at email@example.com
In accordance with the RGPD, WMH Project grants you numerous rights with regard to the use and disclosure of your personal data for marketing purposes (right to erasure, right to rectification, right to limitation of processing, etc.).
You may contact the Data Protection Officer at the address indicated above to exercise your right to object to no longer receiving electronic marketing messages sent by WMH Project and its affiliates and to request that we do not share your personal data with unaffiliated third parties for their marketing purposes.
WMH Project will make every effort to satisfy your request(s) as quickly as possible.
Please note, however, that WMH Project will not be able to remove your personal data from the databases of unaffiliated third parties with whom it has already shared it (i.e., to whom we have already provided your personal data as of the date of implementation of your objection request) even in connection with the exercise of your right to object as described above. Please also note that we may still send you important administrative messages and you cannot opt-out of receiving them even if you exercise your right to opt-out of our marketing messages.
WMH Project may need to revise and update this Policy in order to comply with applicable privacy and data protection laws. WMH Project will publish all changes to this Policy on its website and, in the event of major changes, will notify you by e-mail to the e-mail address indicated in your Contact Profile.
Please contact our Data Protection Officer for further assistance.
Address : Tour Alto, 4 place des Saisons - 92400 Courbevoie