This privacy and personal data protection policy (the "Privacy Policy") defines how Energy Pool Développement SAS (as identified in the legal notice) and its subsidiaries (hereinafter collectively referred to as "Energy Pool") collect, use, store and transmit the personal data of individuals interacting with its website ("You").  

For the record, personal data is any data that allows a natural person to be identified or identifiable (a photo, a name, an IP address, a telephone number, etc.) (hereinafter referred to as "Personal Data" or "PD").

Energy Pool undertakes to comply with current legislation on the protection of personal data, in particular Law No. 78-17 of 6 January 1978 on information technology, files and civil liberties, known as the "Data Protection Act", and European Regulation (EU) No. 2016-679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR").

Energy Pool reserves the right to modify this Policy at any time without notice. We therefore recommend that you consult this page regularly.

When you agree to enter into discussions with Energy Pool, in particular via a contact form, you will be redirected to this Privacy Policy, which informs you of your rights and how your personal data will be processed.

For information on the processing of personal data in connection with recruitment at Energy Pool Développement, please visit the website https://careers.smartrecruiters.com/ENERGYPOOL.   

If you have any questions or requests regarding the processing of your Personal Data, you can contact the Data Protection Officer (DPO) at the following address:

Energy Pool Développement SAS  
For the attention of the DPO
Savoie Technolac – 20, rue du Lac Majeur – Parc Ouragan, Bât. C 
73370 Le Bourget-du-Lac 

Or by email: DPO@energy-pool.eu  

Energy Pool acts as data controller, which means that we decide on the means used to process your personal data and the reasons for processing it.

We are therefore the "lead controller" for the processing of your personal data and are responsible for the conditions under which it is collected, secured and for ensuring that your rights are respected.

The Privacy Policy applies to your personal data if you fall into one of the following categories:

• Employees of Energy Pool's partners, service providers, customers or prospects; 

• Visitors to Energy Pool's premises;

• Users of Energy Pool's website (the "Website") and social media.

We undertake to collect only data that is strictly necessary for the purposes for which it is collected, namely: 

• Identification details (surname, first name),  

• Professional life (company, position),  

• Work contact details (email address, phone number), 

• Images (videos, photographs),  

• Voice for content (articles, videos) on the Website,  

• IP address, unique identifier, Customer Portal usage data, as defined below (optional – only if you accept cookies placed on our Customer Portal).  

No sensitive data within the meaning of the GDPR is collected by Energy Pool.

For contact forms, mandatory fields are marked with an asterisk. If any of the mandatory fields are not filled in, your request may not be processed or its processing may be delayed.

Under the GDPR, processing refers to any action taken on personal data, such as storage, consultation, access, deletion, transfer, etc. This answers the question of how your personal data is used.

We process your personal data in several ways: 

• Collection (see Section VII), 

• Consultation, 

• Organisation (for example, they can be compiled in an Excel file), 

• Use for fulfilling our purposes,

• Extraction (e.g., from one document to another),

• Transfer (between Energy Pool teams or to subcontractors, as defined in Section VIII),  

• Registration on our servers,

• Deletion after use.

Personal data is only collected by Energy Pool to the extent necessary for:

• The preparation and publication of content (articles, videos) on the Website,

• Analysis of the performance and use of the Website,

• Management of requests for information or reports on electricity consumption,

• Newsletter management,

• Business development,

• The performance of the contract or of pre-contractual measures necessary for the conclusion of the contract, 

• Management of unpaid bills and the collection process,

• Managing visitor reception at Energy Pool's premises,

• Improving the performance of our Customer Portal and the user experience it offers, which requires an understanding of user behaviour on the Customer Portal.

Under no circumstances will the data be processed in a manner incompatible with these purposes.

The processing of the data collected is based, depending on the case, on one of the legal grounds provided for by law:

We have access to your personal data in two ways:

• Data provided directly by you (via contact or online registration form, email, social media platforms, visitor register signature or business card);

• Data provided by the staff of the (future) co-contractor on (pre-)contractual documents (contact details for invoicing, operational monitoring and any other contact details necessary for the conclusion or performance of the contract). 

Your personal data is intended for Energy Pool, the data controller, companies within the Energy Pool group, and service providers and subcontractors when their involvement is strictly necessary for the processing of this data. 

Your personal data appearing in content published on the Energy Pool website is intended for anyone visiting the site.

Your personal data is not transferred to third parties for commercial purposes.

Below is a list of our main subcontractors (the full list can be provided on request):

Energy Pool undertakes to retain personal data collected only for the time strictly necessary for the purposes of processing:

A cookie (or tracker) is a small text file (made up of letters and numbers) placed by the website you are visiting on the device you are using to browse (a personal computer, smartphone, tablet, etc.). There are different types:

• Functional cookies so that a website can function properly (for example, remembering your browsing preferences, whether or not you have consented to cookies, and cookies that save your shopping basket on online shopping websites);

• Personalisation cookies to improve your user experience;

• Statistical and audience measurement cookies to analyse traffic and your user experience on the website and thus improve it;

• Advertising cookies to ensure relevant advertising based on each user's profile.

Misconception: The purpose of a cookie is not to collect personal data without the user's knowledge, but to record information about the user's browsing on the website, which can be directly read by Energy Pool during subsequent visits and requests.

As part of its Services, Energy Pool may place cookies on the Customer Portal accessible to Customers in order to better understand their use of the portal, user behaviour and preferences.

However, Energy Pool does not place any cookies on its website.

We use the following cookies on the Customer Portal:

When you visit the Customer Portal for the first time (or if you have previously refused cookies or are logged in using private browsing), a banner will appear to request your consent to the use of cookies (excluding functional cookies).  

You can choose to refuse all cookies or only certain ones.

As a reminder, you can configure your browser software to automatically refuse or delete cookies:

• Google Chrome :  
  https://support.google.com/chrome/answer/95647?hlrm=en 

• Mozilla Firefox : 
  https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer 

• Microsoft Edge : 
  https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy 

Please also note that you can disable certain third-party cookies from the issuer's page, such as Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=fr. 

Cookies are stored for a maximum period of 13 months from the date they are placed.

Personal data stored in cookies is retained for a maximum period of 25 months from the date it is collected.

In accordance with applicable legal and regulatory provisions, users have the right to request:

• access to your personal data and clear information about the use and processing of your data and your rights;

• the verification and rectification of inaccurate personal data;

• an objection to or restriction on the processing or use of your personal data;

• the erasure (right to be forgotten) of personal data;

• the portability of personal data concerning him or her;

• the removal or dissociation of a name and surname from content visible in a search engine.

Please note, however, that these rights are subject to limitations and, in some cases, conditions of applicability. Energy Pool has one (1) month to process your request and provide you with a detailed response, whether or not your request is granted (in whole or in part).

These rights may be exercised at any time by sending a letter or email to the following address:

Energy Pool Developpement 
For the attention of the DPO
Savoie Technolac – 20, rue du Lac Majeur – Parc Ouragan, Bât. C 
73370 Le Bourget-du-Lac 

And by email: DPO@energy-pool.eu  

Users also have the right to lodge a complaint with the CNIL, particularly via its website, by following this link: https://www.cnil.fr/fr/adresser-une-plainte.  

Throughout the entire period during which personal data is stored, Energy Pool shall implement all necessary measures, including appropriate technical and organisational measures, to ensure its confidentiality and security, so as to prevent its damage, erasure or access by unauthorised third parties. In particular, Energy Pool shall endeavour to use secure servers, firewalls and access rights management systems. 

Access to personal data is strictly limited to company employees who are authorised to process it due to their duties and who are subject to a confidentiality obligation, as well as to its subcontractors. Energy Pool will ensure that the Personal Data processed is adequate, relevant and limited.

Your personal data contained in content published on the website and in social media posts and exchanges is accessible outside the European Union due to its presence on the Internet. However, we host this data on servers located within the European Union.  

It may also be transferred outside the European Union in the context of our relationship with our subcontractors, if necessary. If such a transfer of data outside the European Economic Area is implemented, we undertake to ensure that this transfer is accompanied by sufficient and appropriate security guarantees, in accordance with the regulations in force, in particular by means of Standard Contractual Clauses (these are an appendix to the contract with our subcontractors reinforcing the rules applicable to the transfer of personal data with said subcontractor). 

However, Energy Pool undertakes not to transfer your personal data for commercial reasons, in particular, without your prior consent.

The processing does not involve automated decision-making.