This policy is effective as of 25/05/2018
PILOT CORPORATION OF EUROPE takes very seriously its responsibility to ensure the protection of your personal data and comply with the EU regulations, in particular the General Data Protection Regulation (EU) 2016/679 of April 27th, 2016 (hereafter “GDPR”) and applicable supplementing national provisions.
We are therefore informing you on the principles that we apply regarding your personal data.
First, be informed that we do not process data on a large scale. Our main activity is to manufacture and sell writing instruments, run and promote our brand.
We do not transfer your personal data to third parties, except to:
- Pilot distributors located in Europe for justified reasons (eg. implementation of a promotional game organised by PCE in several European countries),
- our subcontractors in specific conditions, where necessary,
- other third parties, if we are legally obliged to do so.
Neither ourselves nor our subcontractors collect your personal data with the intention of trading them to third parties or use them for marketing purposes without your consent or make a detailed profile about you by collecting your personal data.
- the processing is necessary for performance of a contract with you or in order to take steps prior to entering into a contract with you at your request;
- the processing is necessary for the purposes of our legitimate interests (such as, but not limited to, our interest to answer to your enquiry, manage a contractual relationship with you, or improve our products and our websites) and such interests are not overridden by your own interests, fundamental rights or freedom;
- the processing is made with your consent, where such consent is required in order to meet our obligations for compliance purposes.
We will inform you in compliance with the GDPR, when we collect your data, of the purposes of such collection and processing, the legal basis of such processing, the recipients of your data, the duration of the processing and your rights with respect to the data provided to us.
When you trade or enter in contact with PILOT CORPORATION OF EUROPE, the data controller for personal data:
- customers, whether professional or individual, current or prospective,
- job applicants,
- visitors to our websites
Is PILOT CORPORATION OF EUROPE.
Our registered address is PAE de la Caille 74350 Allonzier-la-Caille - France
To contact us with a data protection query regarding the processing of your personal data, please use the email privacy[at]piloteurope.com.
What are the rules applying to you?
- If you are a B2B customer or supplier
- If you are a Consumer…
- If you are a Visitor to our Websites and social networks
- If you are a job applicant
What rules apply to every situation?
- Where do we store your data?
- Is it secured?
- How do we work with our subcontractors?
- What are your rights?
What are the rules applying to you?
As business partners, we need to collect personal data concerning our suppliers or customers’ representatives or correspondents.
We collect your data when you contact us or when we enter into a contractual relationship.
The collection and processing of these data are necessary to liaise with you (eg. to provide a quotation) for the execution of the contract and to keep track of our business partnership, to conduct marketing activities, as well as for fraud prevention purposes and to comply with our obligations under applicable laws and regulations, and to defend and assess a legal right.
We may hold the following personal information:
- Name, job title and contact information such as professional email address and phone number,
- Some necessary economic information about your situation (e.g. invoice history payment information) if you are a sole trader.
These personal data are disclosed to PILOT CORPORATION OF EUROPE in order to deal with your business (e.g. sales, supply chain, accounting.) They can be disclosed to other “Pilot Partners” (Pilot entities or exclusive local distributors in Europe) when necessary. For example, if a European Master Agreement is signed between our two companies, we may need to send useful personal data to other Pilot Partners, which are implementing the contract in the countries. Pilot Partners must comply with applicable laws and regulations regarding the protection of personal data, and are bound by contractual obligations with PILOT CORPORATION OF EUROPE.
We will not disclose any information to any company outside the Pilot Partners network except if required to do so by law.
Personal data collected during our business relationship will be retained for the time necessary to achieve the specific data processing purposes described herein or at the time the data is collected, unless shorter or longer retention periods apply under applicable laws. In particular, we will retain mandatory accounting documentation such as invoices for 10 years, following the end of the current financial year.
If you are a prospective Customer or Supplier and you make a specific enquiry to us via email, phone or the contact form available on our website, we may use this information and contact details to follow-up on your enquiry or to arrange a visit from one of our sales managers.
You may have a question or an enquiry and we give you the possibility to contact us via our email address or via a contact form on our website.
If you contact us, we will handle the following personal data:
- Your title, name,
- Your email address,
- Your postal address,
- Your phone number, if submitted.
These personal data are disclosed to the customer service of PILOT CORPORATION OF EUROPE, only in order to get in contact with you and answer you. They can be disclosed to other Pilot entities when necessary.
For example, if you contact Pilot Corporation of Europe directly, we might send your request and contact details to the relevant local Pilot Partner, if it is appropriate: for example the local Pilot company or the exclusive distributor in the country in which you live.
Information about you will be retained only to meet your request, unless shorter or longer retention periods apply under local or applicable laws. They are not used for any other purpose.
You may want to participate in one of our contest games.
When you participate, we may ask you to supply the following personal data:
- Your title, name,
- Your email address,
- Your home address.
These personal data are disclosed to Pilot country distributors in Europe participating in the game and any subcontractors in charge of implementing the game and will only be used for the purpose of running the game, managing the awards and sending them, as well as to comply with our obligations under applicable laws and regulations, and to defend and assess a legal right.
For example, our subcontractors (specialised service companies) can be in charge of processing the participation, running the draw, sending prizes to winners,… We only disclose your personal data to our subcontractors bound with contractual obligations with us in order to run the game. We do not sell and demand our subcontractors not to sell your personal data or use it for another purpose without your consent.
We may use your email address for marketing purposes, only with your consent (see section “if you register to our newsletter” for more explanations).
Your personal information will be retained exclusively for the time necessary to achieve the specific data processing purposes described herein, unless shorter or longer retention periods apply under local or other applicable laws.
When you visit our Website(s), we do not collect your personal data.
Cookies are small text files that are saved in the web browser or are saved on your computer system by the web browser. Cookies mainly help us to provide you a good service on our website.
If cookies are blocked (especially technical cookies), it may not be possible to use our websites without issues, or may not be possible at all.
The cookies issued by our Website are used for:
- Enabling core site functionality, namely adapting the presentation of our Site to the display preferences of your terminal (responsive design according to your device, language used, display resolution, operating system used, etc.). These cookies are only used for the purpose of providing you a good display of the site and are required;
- Obtaining statistics about the use and volumes of visits to our Site in order to improve the performance of our services, subject to your acceptance by continuing your browsing on our Site.
We use Google Analytics or any similar analytic tool. The information collected is aggregated and does not allow individual identification. To find out more about Google Analytics: http://www.google.com/analytics/learn/privacy.html.
To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
- Helping to memorise the information you have transmitted to our Site to facilitate access to your account or to a game in order to avoid you having to identify yourself several times in one session, subject to your acceptance.
You may choose to save the cookies on your terminal or on the contrary refuse them by configuring your browser. The configuration of each browser being different, we give below the information which will enable you to find out how to modify your wishes regarding Cookies. You may also contact the Site http://youronlinechoices.com, and follow the instructions proposed by this Site to help you control, authorise or block the cookies held in your terminal.
- For Chrome™ : https://support.google.com/chrome/answer/95647?hl=en
- For Internet Explorer™ : https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
- For FirefoxTM : https://support.mozilla.org/t5/Cookies-and-cache/Enable-and-disable-cookies-that-websites-use-to-track-your/ta-p/2784
- For Safari™ : http://support.apple.com/kb/PH17191?viewlocale=en_US&locale=en_US
- For Opera™ : http://help.opera.com/Windows/10.20/en/cookies.html.
We are likely to include on our Site computer applications from third parties, such as for example Youtube. They are using cookies if you use them and we have no control over their process as they are acting for themselves.
Social networks such as Facebook or Twitter are normally likely to identify you thanks to their button, even if you did not click on it when you consulted our Site and we have no control over their process either. However, we do not show active social network buttons from our website and these third parties cannot identify you when you are only consulting our website.
For more information concerning cookies and the use of your personal data by these applications or social networks, we advise you to consult their policies and general conditions for use.
You may apply for a job with us. You may be able to do so using our email address or contact form or via one of our service provider such as a job agency.
As a job applicant, we will hold the personal information your provide us in your CV such as
- Your name,
- contact information,
- job history.
All of the information you provide during the recruitment process will only be used for legitimate interests notably in order to process your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process to unauthorised personnel, which will be held securely internally.
We will use the contact details you provide to us to contact you on the progress of your application.
We will use the other information you provide to assess your suitability for the role you have applied for.
We will retain information about you:
- If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 5 years following the end of your employment.
- If you are not selected for interview, or unsuccessful at the interview process, your information will not be retained by us. Where permission is obtained, we will retain your CV for up to 2 years from the date of your consent.
What rules apply to every situation?
PILOT CORPORATION OF EUROPE does not store your personal data outside the European Economic Area (EEA).
If it happens that one of our subcontractors must store some of your personal data outside the EEA, we make sure that our subcontractor is committed to provide the same guarantees of security and same level of protection you would have in the EEA (see next questions).
We aim at always keeping your data confidential, safe and secure.
We are taking great care for the choice of our IP devices, software, our subcontractors and for improving our internal processes. We take and require that our subcontractors take, appropriate technical and organisational measures to protect your data, prevent loss, destruction, unauthorised or unlawful access and use of your data. We ensure that the internal and external personnel who have access to your data are bound by appropriate security and confidentiality responsibilities.
Despite the measures we take, please note that no electronic transmission or storage information is 100% secure and that we cannot guarantee that loss, destruction, unauthorized or unlawful access and use of your data will never occur.
We may have to communicate your personal information to our subcontractors.
- If you participate in a game, we may work with an agency to organise the game;
- If you place an order, we need to give your personal information to our carrier;
- If you apply for a job via a job agency, the agency collects your information.
A list of these subcontractors, with indication of where they are located, is available upon request at privacy[at]piloteurope.com. In order to treat you fairly prior to sharing your information, we formalise contractual relations with our subcontractors. We ask them to process your data only for the purposes and for the time as determined by us. We ensure that persons authorised to process your personal data have committed themselves to confidentiality and that they implement technical and organisational measures to ensure a good level of security.
We make sure that our subcontractor does not subcontract its work, without our consent.
Your data may also be shared with authorities, institutions, public entities, or other legitimate recipients as permitted by applicable laws and regulations, and for instance to protect and defend our rights.
As provided for in the GDPR, in certain circumstances as defined by applicable laws and regulations, you have the following rights about the personal data you provided us with:
- The right to be informed of the data processing and its conditions.
- The right of access : you can obtain confirmation as to whether or not we process personal data that concerns you, and if so, you can ask for a copy of your personal data and a copy of the data you have provided in a machine-readable format.
- The right to rectification : You may ask to modify, update or correct your data in certain cases, especially if they are inaccurate. If you have an account, you can modify some of your personal data through your account.
- The right to erasure : you may ask us to delete or delete all or part of your personal data subject to legal conditions.
- The right to restrict processing : you may restrict process for example because an information is not accurate until it is corrected.
- The right to data portability : you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used machine-readable format and to transmit it to another data controller.
- The right to object : you can request that we stop the processing of your data, unless we demonstrate compelling legitimate grounds which override your interests, freedom and rights. You always have the right to object to direct marketing.
- The right not to be subject to a decision based solely on automated processing, including profiling, if this decision produces legal effects on you and similarly significantly affects you.
- The right to withdraw your consent if the processing was made on this ground.
- The right to give instructions to a third party with respect to the processing of your data after your death.
Please note that exercising such rights may be subject to requirements and conditions as set forth in applicable laws and regulations.
Guidance to these rights can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens
If, at any time, you want to use your rights, please email: privacy[at]piloteurope.com
We will reply to you as soon as possible and in any case within 1 month upon receipt of your request.
We may ask you to confirm your identity.
You also have the right to lodge a complaint about our processing with the supervisory authority.
In France you can contact:
- Commission Nationale de l'Informatique et des Libertés
- 3 Place de Fontenoy
- TSA 80715
- 75334 PARIS CEDEX 07