Personal Data Protection Policy

As part of its operations, Delville Management processes personal data. The collection and processing of personal data are carried out in accordance with European Regulation 2016/679 of April 27, 2016, on the protection of personal data, as well as Law No. 78-17 of January 6, 1978, on data processing, files, and freedoms, and European Regulation 2024/1689 of June 13, 2024, establishing harmonised rules concerning artificial intelligence.

Delville Management places great importance on protecting the privacy and personal data of its interim managers and candidates, clients and prospects, suppliers and service providers.

Delville Management commits to collecting only personal data relevant and necessary for its activities, the conditions and methods of collection and processing of which are presented in this Personal Data Protection Policy.

This Data Protection Policy applies to all personal data collection methods implemented by Delville Management, including its websites, LinkedIn page, and the "My Manager Space" area.

What is personal data?

Personal data is any information relating to an identified or identifiable natural person, directly or indirectly.

What is the purpose of processing your personal data?

Delville Management collects your personal data as part of its interim management consulting activities. Your personal data may be collected in paper or electronic format.

The legal basis for processing your personal data

Delville Management processes your personal data in cases permitted by applicable regulations:

For commercial management, pre-contractual negotiations, or the contractual execution of our agreements;
Based on the company's legitimate interest, subject to certain conditions;
When your consent is required.

What personal data does Delville Management collect?

For interim managers and candidates, the data collected by Delville Management may include:

Title
Last name and First name
Position
Photo
Personal email address
Videoconferencing contact details
Personal phone numbers
Personal mailing address
Date of birth
Education and qualifications
Identity card, with immediate deletion after identity verification
Roles and industry
Employment status (Fixed-term/Permanent contract)
Mobility
Availability and unavailability
Remuneration information
Professional background and reference checks
Type of driving license held
Administrative information required for contract establishment
Login details for the "My Manager Space" area
Any information provided in the submitted CV, with the exception of sensitive information
Emergency contacts
Exchange history (interviews, email, etc.)

Each application is subject to an evaluation (numerical score) to propose assignments that match the candidate's profile and the client's expectations.

Each assignment is subject to an evaluation (star rating) to measure client satisfaction.

The evaluations carried out will serve as information for the allocation of subsequent assignments. It is also important to note that all evaluations will remain internal to Delville Management.

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For clients, prospects, suppliers, and service providers, the data collected by Delville Management may include:

Title
Last name and First name
Position
Professional situation
Professional contact details
Administrative information required for contracting and invoicing
Satisfaction assessment
Exchange history (interviews, email, etc.)

This data is collected only from you and from professional social networks.

In accordance with the principle of data minimisation, Delville Management commits to collecting and processing only the personal data strictly necessary for achieving specified, explicit, and legitimate purposes.

The collected data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. Accordingly, no superfluous or excessive personal data processing is carried out.

What are the legal bases for processing your personal data?

Delville Management processes your personal data to comply with its legal obligations, or when this data is necessary for the performance of a contract (sending applications by email, mail, and monitoring pre-contractual negotiations or the contractual execution of our agreements), or when it is in Delville Management's legitimate interest (particularly to track your navigation on our website via our contact forms, for monitoring exchanges – physical or video conference interviews / business cards by phone or email / exchanges via social networks).

Finally, in certain cases, your consent is required for processing your data for marketing purposes.

What are the purposes of processing your personal data?

Delville Management collects and uses your personal data for its business needs, specifically for the following purposes:

Communicate with you as part of our professional relationship.
Maintain our relationship and improve your experience.
Allow you to request, obtain, or receive information from Delville Management.
Organise and allow you to participate in specific events.
Allow you to respond to satisfaction surveys.
Send you commercial or institutional communications related to your professional activities.
Conduct business development activities with professional contacts.
Handle the administrative management of our pre-contractual negotiations and contractual relationships, or for any other purpose necessary to comply with current regulations.
Update your data (update campaigns) and allow you to exercise your rights with Delville Management (requests for access, rectification, erasure, data portability, and objection).
Analyse and evaluate the professional capabilities, skills, and experience of interim managers.
List and select interim managers from our candidate database.
Connect interim managers with Delville Management's potential clients and/or prospects.
Monitor the execution of assignments for clients.
Conduct internal and statistical analyses for continuous improvement.
To manage any complaints, disputes, or legal obligations incumbent upon Delville Management.

Who are the recipients of your personal data?

Your personal data is confidential, and only Delville Management employees for whom access to your personal data is necessary for their activity, as well as clients with whom an interim manager is placed, may access it, without prejudice to its potential transmission to bodies responsible for control or inspection missions in accordance with applicable regulations.

Some of your data may be communicated to technical or service providers, it being understood that the third-party provider does not have the right to use the data provided for purposes other than the assignment for which the data is entrusted to them and/or solely for the needs of service execution, and always with administrative, technical, and physical security measures to protect them against any unlawful disclosure, use, modification, and destruction. Data recipients are located within the European Union and the United States. Should Delville Management need to transfer data outside the European Economic Area, Delville Management would do so only in compliance with laws and regulations under the European Commission's adequacy decisions or based on standard contractual clauses to be concluded with third-party organisations.

Personal data collected via our Salesforce Lightning CRM is now hosted on infrastructure located in France. As such, no transfer to a third country within the meaning of Chapter V of Regulation (EU) 2016/679 ("GDPR") is carried out for this service. However, the use of the Salesforce Marketing Cloud Account Engagement (formerly "Pardot") marketing automation module implies that certain personal data is transferred to the United States, where this service is hosted. This transfer is governed by the Data Privacy Framework (DPF) approved by the European Commission, to which Salesforce adheres.

How long is your personal data retained?

Delville Management retains your personal data for the time necessary to fulfill the purposes for which it was collected, subject to legal archiving possibilities, obligations to retain certain data, and/or anonymisation.

Your personal data will be retained according to the following terms, adapted to the category of data subject and the purpose of processing:

Candidate Managers: Your data will be retained for a period of 3 years from your last contact with Delville Management. They may then be archived for two additional periods of 3 years, unless you object. The extended retention of your data aims to maintain your access to our platform and services so that we can offer you assignments suited to your profile.
Interim Managers: When you have been deployed on an assignment through our services, your data will be retained for a period of 5 years from the end of our business relationship (i.e., the end of your last assignment) or your last contact with Delville Management. They may then be archived for an additional period of 5 years, unless you object. The extended retention of your data aims to maintain your access to our platform and services so that we can offer you assignments suited to your profile.
Clients, suppliers, and service providers: Your data will be retained for the entire duration of our business relationship, then, unless you object, for a further period of 5 years after its termination, or from your last contact with Delville Management. The extended retention of your data allows us to provide long-term support in finding solutions tailored to your interim management needs.

You will not receive commercial communications from us more than 3 years after your last contact with us.

What security measures are in place?

Committed to ensuring the security of your personal data, Delville Management implements enhanced data protection through the use of physical and IT security measures.

Despite these reasonable measures to protect your personal data, no transmission or storage technology is infallible. Therefore, and in accordance with applicable European regulations, in the event of a proven personal data breach likely to result in a high risk to the rights and freedoms of the individuals concerned, Delville Management undertakes to communicate this breach to the competent supervisory authority and, where required by said regulations, to the individuals concerned (individually or generally, as appropriate).

It is, of course, also your responsibility to exercise caution to prevent any unauthorised access to your personal data and your devices (computer, smartphone, tablet, etc.).

Furthermore, the Delville Management website may offer links to third-party websites that may be of interest to you. Delville Management has no control over the content of these third-party sites or over the practices of these third parties regarding the protection of personal data they may collect. Consequently, Delville Management disclaims all responsibility for the processing of your personal data by these third parties, which is not subject to this policy. It is your responsibility to inquire about the personal data protection policies of these third parties.

What are your rights regarding your personal data?

Delville Management strives to provide you with clear and precise information regarding the conditions for processing your personal data (right to information). You also have the following rights: the right to access, rectify, and erase your personal data.

The right of access allows you to access all personal data concerning you held by Delville Management, as well as confirmation of whether or not your personal data is being processed, and the conditions of such processing. You also have the right to obtain from Delville Management, as soon as possible (and by default, within 30 days), the rectification of your personal data. Finally, subject to exceptions provided by applicable law (e.g., retention necessary to comply with a legal obligation), you have the right to request Delville Management to erase your personal data as soon as possible, in the following cases:

Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
You wish to withdraw your consent on which the processing of your personal data was based, and there is no other legal basis justifying this processing;
You consider and can establish that your personal data has been unlawfully processed;
Your personal data must be erased pursuant to a legal obligation.

Right to explainability: When processing is likely to produce legal effects concerning data subjects, or significantly affect them, particularly through the use of an artificial intelligence system, Delville Management ensures the transparency and understanding of the processing. You therefore have the right:

To obtain clear, intelligible, and appropriate explanations, in compliance with transparency obligations and the protection of business secrets or intellectual property rights;
To obtain relevant information about the existence of automated decision-making, particularly decision-making using an artificial intelligence system;
To be informed of the general logic underlying the automated processing;
To understand the significance and consequences of this processing;
To request human intervention to review the decision;
To challenge the automated decision.

Right to object to the processing of your personal data: When the processing of your personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Delville Management, or for the legitimate interests of Delville Management or a third party, the right to object allows you to object to the processing of any personal data related to your particular situation. If your personal data is processed for direct marketing purposes, you have the right, regardless of the legal basis for such processing, at any time and free of charge, to object to this processing, including profiling to the extent that it is related to such direct marketing, whether it is initial or subsequent processing.

Right to restriction of processing of your personal data: Applicable regulations provide that this right may be invoked in certain cases, particularly the following:

When you contest the accuracy of your personal data;
When you consider and can establish that the processing of personal data is unlawful, but you object to the erasure of the personal data and request restriction of processing instead;
When Delville Management no longer needs your personal data but you still require them for the establishment, exercise, or defense of legal claims;
When you object to processing based on the legitimate interests of the data controller, pending verification as to whether the legitimate grounds pursued by the data controller override those of the data subject.

Right to data portability: When processing is based on your consent or a contract, this right to portability allows you to receive the raw personal data you have provided to Delville Management in a structured, commonly used format, and to transmit this personal data to another data controller without hindrance from Delville Management. Where technically feasible, you may request that this personal data be transmitted directly by Delville Management to another data controller. The data covered by portability are limited to the raw data you have provided to us, excluding data resulting from work performed by Delville Management.

Right to withdraw consent to the processing of personal data: When Delville Management processes your personal data based on your consent, you may withdraw it at any time by sending a request to Delville Management. However, and in accordance with applicable law, the withdrawal of your consent is only valid for the future and therefore cannot challenge the lawfulness of processing carried out before this withdrawal or based on another legal basis, such as the performance of a contract.

Right to lodge a complaint with a supervisory authority: If, despite Delville Management's efforts, you believe your rights are not being respected, you have the right to lodge a complaint with a supervisory authority. A list of supervisory authorities is available on the European Commission's website.

Right to decide the fate of your personal data after your death: Finally, you have the right to organise the fate of your personal data post-mortem through the adoption of general or specific directives. Delville Management undertakes to respect these directives. In the absence of directives, Delville Management recognises the right of heirs to exercise certain rights, particularly the right to object and to erasure, to close the deceased's account and object to the processing of their data.

How to exercise your rights?

You can exercise your personal data protection rights by sending us your request, accompanied by a copy of any identification document, as follows:

By email to: rgpd@delvillegroup.com

By mail:

DELVILLE MANAGEMENT

Administrative Department – GDPR

15 avenue de la Grande Armée

75016 Paris

Delville Management commits to responding to you as soon as possible, and in any event, within one month of receiving your request.

If your request is submitted electronically, the information will also be provided to you electronically where possible, unless you expressly request otherwise.

If we do not act on your request, we will inform you of the reasons for our inaction, and you will have the possibility to lodge a complaint with a supervisory authority and/or to seek a judicial remedy.

For traceability purposes and as proof of your data deletion, we will retain your deletion request, the date of effective deletion, and the date of the response sent by Delville Management for a period of 5 years from the effective deletion of the data.

Publication of the Personal Data Protection Policy

This Personal Data Protection Policy is available on our website www.delville-management.com. The data controller, Delville Management SAS, is represented by Mac-Mahon, itself represented by its President Patrick Abadie.

Applicable Law

This Policy is governed by French law. In the event of a dispute and if an amicable agreement cannot be reached, the competent courts will be those within the jurisdiction of the Paris Court of Appeal, notwithstanding multiple defendants or third-party claims.

Last updated: 01/12/2025

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