{"id":25406,"date":"2022-06-08T02:09:06","date_gmt":"2022-06-08T02:09:06","guid":{"rendered":"https:\/\/strammer.com\/?page_id=25406"},"modified":"2026-03-25T15:22:13","modified_gmt":"2026-03-25T15:22:13","slug":"politique-de-confidentialite","status":"publish","type":"page","link":"https:\/\/strammer.com\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"
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Privacy Policy<\/h1><\/div>\n<\/div><\/div>\n\n\n\n
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1. PURPOSE OF THIS PRIVACY POLICY<\/h3>\n\n\n\n

This Privacy Policy defines our approach to the processing of personal data concerning you that we collect from you or that third parties communicate to us lawfully, as well as the purposes of such processing. It also describes your rights regarding our processing of your personal data, particularly under the General Data Protection Regulation (Regulation (EU) 2016\/679). <\/p>\n\n\n\n

We therefore invite you to take a few moments to read it. Please note that this Privacy Policy applies only to the use of personal data that we have collected from you.<\/p>\n\n\n\n

2. WHO ARE WE? WHAT DO WE DO?<\/h3>\n\n\n\n

Strammer<\/strong> is a consulting and services company registered in the Paris trade register under number 507 558 096 and whose registered office is located at 11 bis rue Leroux \u2013 75116 Paris.<\/p>\n\n\n\n

Strammer carries out consulting and services activities in human resources (Recruitment, Consulting, Executive Support, Coaching) as well as other complementary advice and services to its customers and in accordance with the applicable laws where it is established.<\/p>\n\n\n\n

3. HOW TO CONTACT US?<\/h3>\n\n\n\n

For any questions about this Privacy Policy or the application of your rights in accordance with this Privacy Policy, please contact us by sending an e-mail to the following address: contact@strammer.com Or by post to the following address: Strammer \u2013 DPO \u2013 Data Protection Officer \u2013 11 bis rue Leroux \u2013 75116 Paris.<\/p>\n\n\n\n

4. WHAT PERSONAL DATA DO WE COLLECT?<\/h3>\n\n\n\n

We may collect personal data from you as part of our activities, including during your use of our Site, when you contact us or request information, when you choose our services, or as a result of the relationships you may have with one or more members of our team and our clients.<\/p>\n\n\n\n

The main purposes of processing your personal data are to:<\/p>\n\n\n\n

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  • verify your identity,<\/li>\n\n\n\n
  • provide our Services and Advice,<\/li>\n\n\n\n
  • manage recruitment,<\/li>\n\n\n\n
  • improve, develop, and market new Services,<\/li>\n\n\n\n
  • follow up on requests you send us on the Site or within the framework of our Services,<\/li>\n\n\n\n
  • resolve queries,<\/li>\n\n\n\n
  • comply with any applicable law, court order, or other legal proceedings, as well as the requirements of regulatory authorities,<\/li>\n\n\n\n
  • execute the contracts that bind us to you,<\/li>\n\n\n\n
  • preserve our rights, our property, or our safety or those of third parties, including those of our other clients and users of the Site or our Services,<\/li>\n\n\n\n
  • and respond to any other obligation required by law.<\/li>\n<\/ul>\n\n\n\n

    To achieve these objectives, we may process the following personal data:<\/p>\n\n\n\n

    If you are a visitor to the Site<\/strong>:<\/p>\n\n\n\n

      \n
    • your last name, first name, title, and position,<\/li>\n\n\n\n
    • your contact details, including the company that employs you, your e-mail address and, where applicable, your contact details on social networks,<\/li>\n\n\n\n
    • demographic data, such as your professional address, your preferences, and your interests,<\/li>\n\n\n\n
    • any other information of interest for the provision of Services (professional experience, training, etc.).<\/li>\n<\/ul>\n\n\n\n

      If you are an individual client, benefiting from our Services, or an individual prospect<\/strong>:<\/p>\n\n\n\n

        \n
      • your last name, first name, title, and position,<\/li>\n\n\n\n
      • your contact details, including the company that employs you and your e-mail address,<\/li>\n\n\n\n
      • payment data,<\/li>\n\n\n\n
      • information you provide us as part of the Service provision we perform for you, which depends on the nature of the instructions you addressed to Strammer,<\/li>\n\n\n\n
      • relevant information required by \"Know Your Customer\" or anti-money laundering regulations and as part of onboarding procedures for new clients,<\/li>\n\n\n\n
      • this may include evidence of the source of funds, at the beginning of the relationship and sometimes regularly throughout our relationship with clients; this information may be requested and\/or obtained from third parties,<\/li>\n\n\n\n
      • verification sources may include documentation we request from prospects and\/or via the use of online sources,<\/li>\n\n\n\n
      • information you transmit to us in order to participate in meetings or events, including your dietary choices which may reveal information about your health or religious beliefs,<\/li>\n\n\n\n
      • any other information of interest for the provision of Services.<\/li>\n<\/ul>\n\n\n\n

        Strammer primarily serves companies that transmit their instructions (i.e., legal entities) and which are therefore, in principle, not data subjects within the meaning of the European Union General Data Protection Regulation.<\/p>\n\n\n\n

        However, in the context of transmitting these instructions, personal data may be sent to us (for example, personal data relating in particular to executives or staff members of our existing or potential client companies, personal data of a stakeholder, supplier, or buyer, including those relating to their advisors or their staff or persons with similar functions, as the case may be).<\/p>\n\n\n\n

        If you are an individual whose personal data we process in the context of our Service provision (notably individual clients or client companies), we may process various types of personal data depending on the Services provided, as indicated above.<\/p>\n\n\n\n

        This may involve personal data relating, in particular, to one of the executives or staff members of our existing or potential client companies, a stakeholder, a supplier, or a buyer, including personal data relating to their advisors, other advisors, or their staff or similar functions, as the case may be.<\/p>\n\n\n\n

        For example, in the case of recruitment consulting assignments, we may receive and then process information regarding your professional experience, your recommendations and references, their contact details, and the dates of your various previous employments.<\/p>\n\n\n\n

        We may also be required to process personal data concerning third parties based on instructions from our own clients or other natural or legal persons having a link with the file covered by our Service provision to our client.<\/p>\n\n\n\n

        This is a non-exhaustive list that reflects the varied nature of the personal data processed in the context of a firm's human resources consulting and services.<\/p>\n\n\n\n

        Regarding existing and potential clients<\/strong>, we also collect information that allows us to market our products and Services that may be of interest to you. In this regard, we collect the following data:<\/p>\n\n\n\n

          \n
        • your last name, first name, title, and position,<\/li>\n\n\n\n
        • other professional information, for example your position and the company for which you work,<\/li>\n\n\n\n
        • fields or subjects that interest you,<\/li>\n\n\n\n
        • additional information likely to be collected, for example events you attend, and possibly your dietary choices if you choose to communicate them to us, it being understood that they may give us indications about your health or religious beliefs, although this is not the purpose.<\/li>\n<\/ul>\n\n\n\n

          If you are a candidate for a position within one of our clients or a group entity<\/strong>:<\/p>\n\n\n\n

            \n
          • your last name, first name, title, and position,<\/li>\n\n\n\n
          • your contact details, including your e-mail address,<\/li>\n\n\n\n
          • your curriculum vitae, including your age and\/or gender if you indicate them to us, your academic background, your professional career, and any other similar subjects and information you choose to communicate to us,<\/li>\n\n\n\n
          • other information of interest for potential recruitment.<\/li>\n<\/ul>\n\n\n\n

            5. HOW DO WE USE YOUR PERSONAL DATA?<\/h3>\n\n\n\n

            We may use your personal data for the following purposes:<\/p>\n\n\n\n

            Our Consulting and Services Provisions:<\/strong><\/p>\n\n\n\n

            We collect and store personal data that you voluntarily transmit to us during your use of the Site and\/or the Services to enable us to perform the Services.<\/p>\n\n\n\n

            Please be aware that our General Terms and Conditions also apply to any provision of Consulting and Services on our part.<\/p>\n\n\n\n

            What is our legal basis?<\/p>\n\n\n\n

            We need to process your data to perform the obligations incumbent upon us under the contract we have, where applicable, concluded with you. We may also use your personal data within our legitimate interest to provide you with the best possible customer service.<\/p>\n\n\n\n

            Customer Services<\/strong><\/p>\n\n\n\n

            We need to process your data to perform the obligations incumbent upon us under the contract we have, where applicable, concluded with you. We may also use your personal data within our legitimate interest to provide you with the best possible customer service.<\/p>\n\n\n\n

            In each case, we may ask you for your contact details, as well as other personal data of interest for your Service request.<\/p>\n\n\n\n

            This information will be used to allow us to follow up on your requests.<\/p>\n\n\n\n

            What is our legal basis?<\/p>\n\n\n\n

            We use your personal data within our legitimate interest to provide you with the best possible customer service.<\/p>\n\n\n\n

            Business Management and Legal Compliance<\/strong><\/strong><\/p>\n\n\n\n

            We use your personal data for our business needs and legal compliance:<\/p>\n\n\n\n

              \n
            • compliance with our legal obligations (including to any regulatory authority or competent body regarding human resources and IT services, \"Know Your Customer\" or anti-money laundering obligations, conflict of interest obligations or similar, including but not limited to the maintenance of mandatory insurance),<\/li>\n\n\n\n
            • asserting our rights in court,<\/li>\n\n\n\n
            • protecting the rights of third parties,<\/li>\n\n\n\n
            • and within the framework of a business transaction.<\/li>\n<\/ul>\n\n\n\n

              What is our legal basis?<\/p>\n\n\n\n

              Our use of your personal data in the framework of a business transaction, to assert our rights in court, or to protect the rights of third parties is based on our legitimate interest or that of a third party. Regarding all other purposes described in this section, we have an obligation to use your personal data to comply with the legal obligations applicable to us.<\/p>\n\n\n\n

              Recruitment<\/strong><\/strong><\/p>\n\n\n\n

              We use your personal data for the following recruitment purposes:<\/p>\n\n\n\n

                \n
              • for Strammer, including for an executive, partner, or associate position, for a training\/internship contract or summer internship, or for support functions, whether the application was received online, by email, hard copy, or during an in-person request,<\/li>\n\n\n\n
              • to ensure compliance with equal opportunity in accordance with applicable law, to guarantee the absence of discrimination based on gender, racial and ethnic origin, age, religion, sexual orientation, disability, or any other motive covered by local legislation.<\/li>\n<\/ul>\n\n\n\n

                What is our legal basis?<\/p>\n\n\n\n

                We will use your personal data in the framework of pre-contractual measures necessary prior to concluding a contract or in accordance with our legitimate interest to guarantee the best possible decision-making for our client or for Strammer regarding recruitment.<\/p>\n\n\n\n

                We will not process any special category of data except where applicable law authorizes us to do so or with your explicit consent.<\/p>\n\n\n\n

                Communications<\/strong><\/p>\n\n\n\n

                We carry out the following marketing activities using your personal data:<\/p>\n\n\n\n

                  \n
                • by postal mail<\/li>\n\n\n\n
                • by email<\/li>\n<\/ul>\n\n\n\n

                  We use the data we observe about you from interactions with our Site, email communications addressed to you, and\/or within the framework of the Services (see the Customer Information and Analysis section below for additional information) to send you communications.<\/p>\n\n\n\n

                  What is our legal basis?<\/p>\n\n\n\n

                  The use of your personal data for prospecting purposes is based on our legitimate interest in developing our relationship with you.<\/p>\n\n\n\n

                  We will send you communications only if you have given us your consent, or unless you object, where the law permits.<\/p>\n\n\n\n

                  Customer Information and Analysis<\/strong><\/p>\n\n\n\n

                  We analyze your contact details along with other personal data we observe about you from your interactions with our Site, emails we send you, and\/or within our Services.<\/p>\n\n\n\n

                  Where you have given consent (if required by law), we use cookies and tracking technologies to collect personal data from your devices. This may include:<\/p>\n\n\n\n

                    \n
                  • an IP address to track Site traffic,<\/li>\n\n\n\n
                  • a session identifier to track usage statistics,<\/li>\n\n\n\n
                  • information regarding professional interests, demographics, and preferences.<\/li>\n<\/ul>\n\n\n\n

                    Our web pages contain \"cookies,\" \"web beacons,\" or \"pixel tags\" (\"Tags\"). These allow us to track the receipt of an email, count users who visited a page, and collect aggregated information. If you click on an email containing a Tag, your details may be crossed with the source email.<\/p>\n\n\n\n

                    We may use \"clickable URLs\" linked to websites we administer.<\/p>\n\n\n\n

                    This helps us estimate the effectiveness of our content and understand what attracts our visitors most.<\/p>\n\n\n\n

                    We use this information for prospecting and client follow\u2011up purposes.<\/p>\n\n\n\n

                    What is our legal basis?<\/p>\n\n\n\n

                    When your data is not anonymous, we use your personal data to fulfill our legitimate interest in guaranteeing you and our other clients the best products and services.<\/p>\n\n\n\n

                    If we intend to use your data for other purposes, we will inform you using your available contact details.<\/p>\n\n\n\n

                    6. WHAT IS OUR LEGAL BASIS?<\/h3>\n\n\n\n

                    Generally, we need to use your personal data:<\/p>\n\n\n\n

                      \n
                    • to perform obligations resulting from any contract that binds us,<\/li>\n\n\n\n
                    • to respond to our legitimate interest or that of a third party aimed at ensuring the best possible Services,<\/li>\n\n\n\n
                    • or to comply with the legal obligations incumbent upon us.<\/li>\n<\/ul>\n\n\n\n

                      7. PERSONS WITH WHOM WE SHARE YOUR PERSONAL DATA<\/h3>\n\n\n\n

                      Strammer is a human resources consulting and services company, and any information we collect or that you provide to us may be shared with and processed by any of the entities for the purposes indicated above only after obtaining your express agreement.<\/p>\n\n\n\n

                      We may also share your personal data with the following categories of third parties when necessary:<\/p>\n\n\n\n

                        \n
                      • our professional advisors, such as lawyers and accountants,<\/li>\n\n\n\n
                      • public or regulatory authorities,<\/li>\n\n\n\n
                      • insurance companies providing professional civil liability insurance coverage,<\/li>\n\n\n\n
                      • regulatory bodies\/tax authorities\/trade and company registers,<\/li>\n\n\n\n
                      • third parties to whom we outsource certain services, including, in particular, document processing and translation services, confidential document destruction services, IT system providers or software publishers, IT support service providers, and information and document storage providers,<\/li>\n\n\n\n
                      • third parties whom we call upon as part of the services we perform on behalf of our clients, such as coaches, graphologists, technical experts, assessors, etc.,<\/li>\n\n\n\n
                      • third-party providers to assist us with client data analysis, such as Google Analytics,<\/li>\n\n\n\n
                      • third-party postal or private messaging providers who help us deliver our direct mail marketing campaigns or provide you with documents related to a file.<\/li>\n<\/ul>\n\n\n\n

                        Please note that this is not an exhaustive list and other circumstances could lead us to share your personal data with other parties to provide the Services in the most efficient way possible.<\/p>\n\n\n\n

                        8. OUR USE OF COOKIES AND OTHER SIMILAR TECHNIQUES<\/h3>\n\n\n\n

                        Please be aware that our Site uses certain Tags, tracking files, and other technologies. We invite you to visit our sites and services in private browsing mode if you wish to disable them.<\/p>\n\n\n\n

                        Please consult our Cookie Policy<\/strong> to learn more about the cookies we use and how to manage and delete them.<\/p>\n\n\n\n

                        9. THIRD-PARTY CONTRACTORS AND OTHER DATA CONTROLLERS<\/h3>\n\n\n\n

                        As indicated above, we may use third-party subcontractors to provide the Services, who may process your personal data on our behalf and according to our instructions.<\/p>\n\n\n\n

                        This includes, for example, document processing and translation services, confidential document destruction services, IT system providers or software publishers, IT support service providers, and document storage providers. We carry out the necessary checks and put in place contractual documentation with any subcontractor we use to ensure appropriate processing of personal data by the latter, in compliance with our legal and regulatory obligations.<\/p>\n\n\n\n

                        Furthermore, we may appoint external controllers to provide Services (for example, accountants, lawyers, or other third-party experts). When we do so, we will comply with our legal and regulatory obligations regarding personal data, notably by putting in place appropriate safeguards.<\/p>\n\n\n\n

                        10. COUNTRIES TO WHICH WE TRANSFER YOUR DATA<\/h3>\n\n\n\n

                        In order to provide you with the Services, we may be required to transfer your personal data to countries other than those where you provided this data.<\/p>\n\n\n\n

                        If you are located within the European Economic Area (EEA), please note that when necessary to perform the Services, we transfer personal data to countries outside the EEA (for example, in the context of recruitment located outside the EEA).<\/p>\n\n\n\n

                        In these cases, we ensure that appropriate safeguards are put in place to ensure an adequate level of protection for your personal data in accordance with European Commission directives.<\/p>\n\n\n\n

                        11. DURATION OF RETENTION OF YOUR PERSONAL DATA<\/h3>\n\n\n\n

                        Regarding visitors to the Site and our online services, we will retain personal data for at least three years from the date of our last interaction with you and in accordance with the obligations imposed on us under the EU General Data Protection Regulation or any equivalent law applicable elsewhere in the world, or for longer periods if we are required to do so in accordance with our regulatory obligations or professional civil liability obligations.<\/p>\n\n\n\n

                        Regarding the provision of Services to a client, we will retain personal data for the duration of the contractual relationship and at least six years from the date of our last interaction with the client and in accordance with the obligations imposed on us under the EU General Data Protection Regulation or an equivalent law applicable elsewhere in the world, or for longer periods if we are required to do so in accordance with our regulatory obligations or professional civil liability obligations. We may then destroy these files without notice and without incurring any liability.<\/p>\n\n\n\n

                        We may delete personal data that is only used for short-term purposes, such as specific marketing campaigns.<\/p>\n\n\n\n

                        12. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA<\/h3>\n\n\n\n

                        We are committed to ensuring the security of personal data communicated to us and we have implemented information system security policies and appropriate technical rules and measures to protect personal data under our control against unauthorized access, modification, use, and disclosure or unlawful destruction or accidental loss of such data.<\/p>\n\n\n\n

                        All our partners, employees, consultants, workers, and data processors who have access to personal data are required to respect the confidentiality of said data.<\/p>\n\n\n\n

                        13. ACCESS TO YOUR DATA AND OTHER RIGHTS<\/h3>\n\n\n\n

                        You have the following rights regarding your personal data:<\/p>\n\n\n\n

                        Right of access<\/p>\n\n\n\n

                        Upon request, we will tell you if we process your data and provide a copy.<\/p>\n\n\n\n

                        Right to rectification<\/p>\n\n\n\n

                        You have the right to request the correction of inaccurate or incomplete data.<\/p>\n\n\n\n

                        Right to erasure<\/p>\n\n\n\n

                        You may request that we delete or remove your personal data in certain circumstances, for example when it is no longer needed or when you withdraw your consent (as applicable). If you have the right to have your data erased and we have made it public, we will take reasonable steps\u2014taking into account available technologies\u2014to inform third parties processing that data of your request for erasure.<\/p>\n\n\n\n

                        Right to restriction of processing<\/p>\n\n\n\n

                        You can ask us to \"block\" or limit the processing of your data.<\/p>\n\n\n\n

                        Right to data portability<\/p>\n\n\n\n

                        You have the right to obtain and reuse your data in a machine-readable format.<\/p>\n\n\n\n

                        Right to object<\/p>\n\n\n\n

                        You can object to the processing of your personal data, and we will terminate it:<\/p>\n\n\n\n

                          \n
                        • if this processing is based on our legitimate interest or that of a third party to process your personal data, unless the processing meets our compelling legitimate interests,<\/li>\n\n\n\n
                        • or in the event of processing of your personal data for prospecting purposes.<\/li>\n<\/ul>\n\n\n\n

                          Your rights in the context of automated decision-making and profiling<\/p>\n\n\n\n

                          You have the right not to be subject to a decision based on exclusively automated processing, including profiling, producing legal effects or effects significantly affecting you, unless profiling is necessary for the conclusion or performance of a contract between you and us or for compliance with our legal obligations.<\/p>\n\n\n\n

                          Your right to withdraw your consent<\/p>\n\n\n\n

                          If we process your personal data on the basis of your consent, you have the right to withdraw this consent at any time, without prejudice to the lawfulness of the processing based on consent carried out before the withdrawal.<\/p>\n\n\n\n

                          Your right to a digital will<\/p>\n\n\n\n

                          You may provide general or specific directives regarding the fate of your personal data after your death.<\/p>\n\n\n\n

                          Your right to lodge a complaint with a supervisory authority<\/p>\n\n\n\n

                          If you have a concern regarding any aspect of our privacy practices, including the way we have handled your personal data, you may contact the competent supervisory authority. (CNIL \u2013 www.cnil.fr)<\/p>\n\n\n\n

                          Please be aware that some of these rights may be limited when a compelling interest or a legal obligation for us to continue processing the data prevails, or when the data cannot be disclosed due to our professional obligations.<\/p>\n\n\n\n

                          14. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS<\/h3>\n\n\n\n

                          Le Site contient des liens vers d’autres sites dont les pratiques de collecte d’information peuvent diff\u00e9rer des n\u00f4tres. Les visiteurs sont pri\u00e9s de consulter les politiques de confidentialit\u00e9 des autres sites. En effet, Strammer n’exerce aucun contr\u00f4le sur les informations qui sont communiqu\u00e9es \u00e0 ces tiers ou collect\u00e9es par ces derniers.<\/p>\n\n\n\n

                          15. CHANGES TO THIS PRIVACY POLICY<\/h3>\n\n\n\n

                          We may make periodic changes to this Privacy Policy. To ensure that you are always aware of how we use your personal data, we will update this Privacy Policy periodically to reflect any changes in the way we use your personal data.<\/p>\n\n\n\n

                          We may also make necessary changes to comply with changes in current legislation and regulations. Whenever possible, we will notify you of any significant changes. However, we encourage you to consult this Privacy Policy regularly to find out how we use your personal data.<\/p>\n\n\n\n

                          <\/div>\n\n\n\n

                          Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.<\/p>

                          You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.<\/p>

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