Privacy Policy
Littler France (hereafter “Littler France” or “we”) attaches great importance to the protection of privacy and personal data.
As the party responsible for processing this data, we commit to implementing adequate measures to ensure its protection, confidentiality and security, and to processing and using it in accordance with the applicable provisions, in particular the European Regulation 2016/679 of April 27, 2016 (known as the “RGPD”) and the French Data Protection Act no. 78-17 of January 6, 1978.
The purpose of this data protection policy is to inform you about how we process your personal data and about our data protection commitments.
Article 1. DEFINITIONS
The terms mentioned below have the following meanings in this Privacy Policy:
- Client: refers to any natural or legal person who is a customer of Littler France.
- Site: refers to the Littler France website, its content and all its graphic and technical components.
- User: refers to any person accessing and browsing the Site or any Customer or prospect of Littler France.
- Services: refers to all services offered by Littler France (consulting, litigation, inter or intra-company training).
The terms “personal data”, “processing”, “data processor” and ” subcontractor” have the meaning given to them in Article 4 of the RGPD.
Article 2. DATA PROCESSOR
Littler France as Data Processor
In its capacity as a law firm, and by virtue of its ethical requirement of independence, Littler France, a limited liability company (société d’exercice libéral à responsabilité limitée) with share capital of 200,000.00 euros, registered with the Paris Trade and Companies Registry under number 921 792 040, whose registered office is located at 156, boulevard Haussmann, 75008 Paris, will be considered as the distinct responsible party for the processing of data communicated by its clients for its advisory and litigation activities.
As the recipient of data provided by its clients, Littler France is responsible for its own processing and cannot be considered as a subcontractor with respect to its clients.
Littler France as Subcontractor
According to CNIL doctrine (cf. GUIDE CNIL : Les avocats et la loi informatique et libertés, 2011), only activities for which the law firm acts on the basis of instructions strictly defined by its clients, such as audit missions, will leave room for a subcontracting situation.
Article 3. DATA PROTECTION OFFICER
Our Data Protection Officer (hereafter “DPO”) is here to respond to all requests, including the exercising of rights, relating to your personal data.
You can reach him :
- Either by e-mail to the following address: dpo@littler.fr
- Or by post to Littler France, Service DPO, 156, boulevard Haussmann, 75008 Paris.
The DPO’s mission is to inform, advise and control Littler France’s compliance with the processing operations carried out via the Site.
In accordance with data protection regulations, the DPO acts as a point of contact:
- Regarding data subjects for all matters relating to data processing carried out by Littler France or the exercise of your rights;
- Regarding the CNIL as part of its cooperation mission. The DPO may also contact this authority to request an opinion or prior consultation on all subjects concerning the protection of personal data ;
- Regarding other DPOs appointed by participating Subcontractor or Data Processor organizations.
Article 4. TYPE OF DATA COLLECTED
The information provided below is not intended to be exhaustive and aims above all to inform Users about the categories of data that Littler France is likely to collect.
Non-technical data
- Identification: last name, first name, title, civility, position, pseudonym
- Contact details: telephone, e-mail address, postal address, fax, …
- Photo when you grant us this right (usually taken at events)
- All data and documents transmitted by our clients in the context of consulting and litigation files, including information on employees, IRPs, service providers or any other third party involved or likely to be involved in our clients’ activities.
- Data relating to the means of payment used by a client (bank details such as RIB, transfers, SEPA direct debit mandates, checks, etc).
Technical data
Identification data (IP)
Connection data (logs in particular)
Consent (click) data, mainly for online subscriptions (e.g. newsletters)
Littler France does not process sensitive data within the meaning of Article 9 of the RGPD, apart from those included in Article 9.2 f), in other words data necessary “for the establishment, exercise or defence of legal claims or whenever courts act in their judicial capacity“.
Article 5. BASIS OF COLLECTION
Littler France only collects data about you directly from you, during our various exchanges through online requests, letters and telephone calls, among others.
This collection may be based on the performance of a contract or pre-contractual measures taken at your request, compliance with a legal obligation, or the legitimate interests of Littler France.
When necessary, Littler France commints to obtaining your consent.
Littler France may send legal newsletters to users who have agreed to receive them. If users no longer wish to receive such information, they may send an e-mail at any time and without giving any other reason to the following address: dpo@littler.fr
Article 6. TYPE OF DATA PROCESSED
We take care to collect and process personal data that is relevant, adequate, not excessive and strictly necessary to achieve the purposes that have been previously determined.
Business contacts ( clients, prospects, other external contacts)
In the context of our fee agreements with our clients and the performance of assignments on their behalf, we collect and process personal data concerning our clients, as well as their employees, representatives, service providers and managers.
We may also collect and process personal data provided by prospective clients at various events, meetings or exchanges.
Finally, we may collect data from various external contacts in the course of our duties and day-to-day activities (colleagues, opposing parties, judges, members of the authorities, students, etc.).
In these situations, we may have access to identity and contact data, but also to other personal data that you provide directly to us if this is necessary for the performance of our tasks.
Users of the Littler France website
Within the framework of the use of the Littler France website at https://www.littler.fr (the “Site”), Littler France collects and processes certain personal data concerning you as a user of the Site (the “User”). These personal data of Users are collected when :
- If you sign up for information mornings or newsletters offered by Littler France, we will collect your e-mail address;
- You browse the Site, in which case we collect your technical and browsing information;
- You apply online via the recruitment module, in which case we collect your identity and contact details, your CV, your cover letter and any other information you consider relevant to the processing of your application;
- You contact us to ask questions about our news, training or any other subject related to our business, in which case we collect your identity and contact data and any other information you voluntarily provide us that is relevant to the processing of your request.
- When your personal data is transmitted to us via a form, the mandatory information to be filled in is indicated at the time of collection.
- Any failure to answer or any answer judged abnormal by Littler France can involve the refusal of Littler France to take into account your request.
Article 7. PURPOSE OF PROCESSING YOUR PERSONAL DATA
Littler France is committed to collecting and processing your personal data in a transparent, confidential and secure manner.
Your personal data may be processed for the following purposes:
- If you are a client: clients’ personal data is processed for the purposes of managing the contractual relationship we have with them, including (I) contact and communication, (II) performance of assigned tasks, in particular the provision of legal services, (III) contract and invoice management, (IV) accounting management and (V) follow-up of the contractual relationship. In addition, and subject to their lack of opposition, clients may receive newsletters, informative content on various professional and legal subjects, press releases, invitations to training courses or events organized by Littler France, all in an exclusively professional context. In this context, the personal data collected may be used for analysis purposes (such as click and open rates). In this context, we process your personal data for the purposes of fulfilling the contract and complying with our legal obligations (accounting and tax), with the exception of processing carried out for the purposes of analysis and commercial prospecting, which is based on Littler France’s legitimate economic interest in promoting its services and developing its relationships, which benefits both clients (who have access to additional services free of charge) and Littler France, without prejudice to the interests, rights and fundamental freedoms of these clients.
- If you are an external contact: the personal data of external contacts is processed for the purposes of managing our activities (e.g. processing the data of students to provide them with training, processing the data of colleagues and/or the opposing party to manage a Client’s case, processing the data of members of the judicial and administrative authorities to manage ongoing proceedings and/or ask them legal questions, etc.) and communicating with these persons. In certain cases, subject to their not objecting, External Contacts may receive newsletters, informative content on various legal subjects, invitations to training courses or events organized by Littler France, in a professional context only. The processing carried out in this context is based on Littler France’s legitimate interest in carrying out the assignments entrusted to it by its Clients, providing quality services and developing its relations, without infringing the interests, rights and fundamental freedoms of external contacts.
- If you are a user: users’ personal data is processed for the purposes of (I) communication and management of requests/requests submitted, (II) analysis of browsing on the Site and/or (III) commercial prospecting (sending newsletters, informative content on various legal subjects, invitations to training courses) when a User communicates his/her email address for this purpose on the Site and does not subsequently express opposition. In this case, the treatments implemented are based on the legitimate economic interest of Littler France to promote its services and to develop its relations, to constantly improve its Site and to easily communicate with its Users, which benefits both the Users (who have access to quality services and a Site) and Littler France, without infringing the interests, rights and fundamental freedoms of these Users.
- If you are a candidate: candidates’ personal data is processed for the purposes of managing and selecting the applications submitted.
Article 8. LENGTH OF TIME YOUR PERSONAL DATA IS KEPT
Littler France keeps your personal data for as long as necessary to achieve the purposes for which they were collected and processed. However, Littler France may keep your personal data for a longer period of time in order to comply with legal obligations and in particular applicable limitation periods.
Littler France keeps your personal data for the following periods:
- We keep our clients’ data for the duration of the contractual relationship and the usual 5-year limitation period. However, in certain situations, we may need to keep this data for longer if this is necessary to ensure the follow-up of the legal services we provide, in particular in the event that legal proceedings are underway and not all remedies have been exhausted. Data required for accounting purposes is kept for a period of 10 years in order to comply with current accounting and tax obligations.
- External contact data is kept for as long as is necessary to achieve the intended purpose, unless it is collected as part of a client file, in which case it is kept for the same period as the client data mentioned above.
- Data collected for commercial prospecting and analysis purposes is kept for 3 years following the last contact with the person concerned.
- When your data is collected in the context of requests or questions concerning the Littler France site and services, we keep it for the time necessary to manage these requests.
Article 9. PERSONAL DATA RECIPIENTS
Internal recipients
The personal data collected and processed by Littler France is accessible to the competent internal departments, i.e. :
- The partners and associates
- Non-lawyer staff (including administrative staff such as trainees or assistants) dealing with Clients’ requests
- Billing department
- Communications department
- IT department
- External recipients
This data may also be communicated to third parties, acting as subcontractors, bound by a subcontracting contract, to perform services such as:
- Accommodation,
- Contact management (CRM),
- Billing management,
- Communication,
- Translation,
- Reprography,
- Database management,
- Site management and IT maintenance.
These Subcontractors act only on instructions from Littler France and have access to your personal data only to perform their services. They are bound by the same security and confidentiality obligations as Littler France.
Finally, your personal data may be shared with third parties in the context of a client file, to the following persons or departments:
- Administration judiciaire,
- Judicial administration,
- Auxiliaries of justice,
- Colleagues,
- Experts,
- Representatives,
- Bailiffs,
- Investigators,
- Ordinal instances,
- Administration, etc.
Article 10. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
In some cases, your personal information will be stored on servers located outside the EEA.
This is particularly the case when we are required to work with our Littler Global international network with offices located outside the EEA, and in particular in Canada, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Singapore, the United Kingdom, the United States and Venezuela. We have taken appropriate measures to ensure that your data is stored securely via the contractualization of standard contractual clauses approved by the European Commission (art. 46 RGPD).
Article 11. YOUR RIGHTS
In accordance with the applicable regulations, you have the following rights with regard to your personal data:
- The right of access (Article 15 RGPD): You have the right to obtain confirmation that personal data concerning you are or are not being processed and, where they are, to obtain access to and a copy of said data.
The right of rectification (Article 16 RGPD): You have the right to obtain the rectification of personal data concerning you that are inaccurate. You also have the right to have incomplete personal data completed, including by providing a supplementary declaration. - The right to deletion (Article 17 RGPD): In certain cases, you have the right to obtain the deletion of your personal data, when they are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or storage is prohibited.
- The right to withdraw your consent at any time (Article 7 RGPD).
- The right to the limitation of processing (Article 18 RGPD): In certain cases, you have the right to obtain the limitation of the processing of your personal data.
- The right to portability (Article 20 RGPD): You have the right to receive the personal data concerning you that you have provided to Littler France, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without Littler France hindering it. This right only applies where the processing of your personal data is based on your consent or on the performance of a contract and where said Processing is carried out using automated processes.
- The right to object (Article 21 RGPD): You have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data concerning you.
- The right not to be subject to a decision based exclusively on automated processing (Article 22 of the RGPD).
- The right to transmit instructions concerning the use of data after death (Article 85 LIL): You have the right to give Littler France instructions concerning the use of your personal data after your death.
In order to exercise your rights, please send a request to :
- by e-mail to: dpo@littler.fr
- or by post to Littler France, Service DPO, 156, boulevard Haussmann, 75008 Paris
In the event of any difficulty relating to the management of your personal data, you may lodge a complaint with the CNIL (3 Place de Fontenoy, 75007 Paris) or any other competent authority. However, please contact us before filing a complaint with the CNIL.
Article 12. DATA SECURITY
Littler France is responsible for determining and implementing appropriate security measures to protect data against accidental or unlawful destruction, loss, alteration or unauthorized disclosure.
These measures can include, for example, security measures for access to premises (locking of offices, use of badges, etc.), securing access to computers and smartphones (use of regularly changed access codes), use of passwords and logins to access business applications, management of data access authorizations (particularly for financial, accounting and communications departments), and regular change of Wi-Fi network passwords.
Littler France may also call on third parties to carry out vulnerability audits and penetration tests, as required.
In the event of a change in the technology used to ensure the security and confidentiality of personal data, Littler France undertakes to use means of protection of superior performance.
In the event of subcontracting the processing of personal data, Littler France undertakes to contractually impose security guarantees on its subcontractors, including technical data protection measures and appropriate human resources.
Article 13. EVOLUTION
This personal data policy may be modified or adapted at any time in the event of legal developments, decisions and recommendations of the Cnil (Commission Nationale de l’Informatique et des Libertés) or current practices.
Any updates to this policy will be brought to the attention of clients and contacts by any means chosen by Littler France, including electronically (for example, by e-mail or online).