As part of its business activities, Delville Management processes personal data. The collection and processing of personal data is 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 information technology, files, and civil liberties, and European Regulation 2024/1689 of June 13, 2024 establishing harmonized rules concerning artificial intelligence.
Delville Management attaches great importance to protecting the privacy and personal data of its interim managers and candidates, customers and prospects, suppliers and service providers.
Delville Management undertakes to collect only personal data that is relevant and necessary for the performance of its business activities, the conditions and methods of collection and processing of which are set out in this Personal Data Protection Policy.
This Data Protection Policy applies to all personal data collection media used by Delville Management, including its websites, LinkedIn page, and "My Manager Space" area.
What is personal data?
Personal data is any information relating to an identified or identifiable natural person, whether directly or indirectly.
What is the purpose of processing your personal data?
Delville Management collects your personal data as part of its activities as an interim management consulting firm. 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 the cases permitted by the applicable regulations:
- In the context of commercial management, pre-contractual negotiations, or the contractual execution of our agreements;
- Within the legal framework of the company's legitimate interest, subject to certain conditions;
- As part of your consent when required.
What personal data does Delville Management collect?
For interim managers and candidates, the data collected by Delville Management may include :
- Civility
- First and last name
- Function
- Photo
- Personal e-mail address
- Videoconference contact details
- Personal telephone numbers
- Personal postal address
- Date of birth
- Training and qualifications
- ID card with immediate deletion after identity verification
- Functions and sectors
- Employment status (fixed-term/permanent)
- Mobility
- Availability and unavailability
- Compensation information
- Professional background and references
- Type of driver's license held
- Administrative information required for contracting
- Login details for the "My Manager Space" area
- All information contained in the CV, with the exception of sensitive information
- Emergency contacts
- History of communications (meetings, emails, etc.)
Each application is subject to an assessment (figure), so that we can offer assignments that match the candidate's profile and the customer's expectations.
Each assignment is subject to a star rating to measure customer satisfaction.
The evaluations carried out will be used as information in the context of assigning future assignments. Finally, it should be noted that all evaluations will remain internal to Delville Management.
For customers, prospects, suppliers and service providers, the data collected by Delville Management may include:
- Civility
- First and last name
- Function
- Professional situation
- Professional contact details
- Administrative information required for contracting and invoicing
- Satisfaction assessment
- History of communications (meetings, emails, etc.)
This data is only collected from you and on professional social networks.
In accordance with the principle of data minimization, Delville Management undertakes to collect and process only personal data that is strictly necessary for the fulfillment of specific, explicit, and legitimate purposes.
The data collected is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. As such, no unnecessary or excessive processing of personal data is carried out.
What are the legal bases for processing your personal data?
Delville Management processes your personal data in order to comply with its legal obligations, or when this data is necessary for the performance of the contract (sending applications by e-mail, letters and monitoring pre-contractual negotiations or the contractual performance of our agreements), or when this is in the legitimate interests of Delville Management (in particular to monitor your navigation on our website via our contact forms, for monitoring exchanges - physical interviews or by videoconference / business cards by telephone or e-mail / exchanges via social networks).
Finally, in certain cases, your consent is required for the processing of your data for marketing purposes.
What are the purposes of processing your personal data?
Delville Management collects and uses your personal data for the needs of its business and in particular for the following purposes:
- Exchange with you in the context of our professional relations
- Follow up on our relationship and improve your experience
- Enabling you to request, obtain, or receive information from Delville Management
- Organize and enable you to take part in specific events
- Enable you to respond to satisfaction surveys
- Send you commercial or institutional communications related to your professional activities
- Conduct sales prospecting activities with professional contacts
- To carry out the administrative management of our pre-contractual negotiations and contractual relations, 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, deletion, portability and opposition).
- Analyze and evaluate the capabilities, skills, and professional experience of interim managers.
- List and select interim managers from our candidate database
- Connecting interim managers with Delville Management's potential clients and/or prospects
- Monitor the execution of assignments at the client's premises
- Conduct internal and statistical analyses for continuous improvement purposes
- 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 who need access to your personal data in order to carry out their work, as well as clients with whom an interim manager is placed, may access it, without prejudice to its possible transmission to bodies responsible for control or inspection in accordance with applicable regulations.
Some of your data may be communicated to technical or service providers, on the understanding that the third-party provider is not entitled to use the data provided for purposes other than the task for which the data is entrusted to them and/or for the sole purpose of performing the service, and always with administrative, technical, and physical security measures in place to protect them from unlawful disclosure, use, modification, and destruction. technical, and physical security measures to protect it from unlawful disclosure, use, modification, and destruction. The recipients of the data are located within the European Union and in the United States. In the event that Delville Management needs to transfer data outside the European Economic Area, Delville Management will do so only in compliance with the laws and regulations pursuant to the adequacy decisions of the European Commission or on the basis of standard contractual clauses that will be concluded with third-party organizations.
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 marketing automation module (formerly "Pardot") involves the transfer of certain personal data 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 do you keep your personal data?
Delville Management retains your personal data for as long as is necessary for the fulfillment of the purposes for which it is to be used, subject to the legal possibilities of archiving, obligations to retain certain data, and/or anonymization.
Your personal data will be stored in accordance with the following terms and conditions, adapted to the category of data subject and the purpose of the processing:
- Manager candidates: Your data will be stored for a period of three years from your last contact with Delville Management. It may then be archived for two additional periods of three years, unless you object. The purpose of storing your data for an extended period is to maintain your access to our platform and services so that we can offer you assignments that match your profile.
- Interim managers: When you have been deployed on 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. It may then be archived for an additional period of 5 years, unless you object. The extended retention of your data is intended to maintain your access to our platform and services so that we can offer you assignments that match your profile.
- Customers, suppliers, and service providers: Your data will be retained for the duration of our business relationship and then, unless you object, for a further period of five years after the end of that relationship or from your last contact with Delville Management. Retaining your data for this extended period enables us to provide you with long-term support in finding solutions tailored to your interim management needs.
You will not receive any marketing communications from us more than three years after your last contact with us.
What security measures are in place?
In order to ensure the security of your personal data, Delville Management has put in place a data protection system reinforced by the use of physical and computer security measures.
Despite these reasonable measures to protect your personal data, no transmission or storage technology is infallible. Accordingly, and in accordance with applicable European regulations, in the event of a proven breach of personal data likely to give rise to a high risk for the rights and freedoms of the persons concerned, Delville Management undertakes to communicate this breach to the competent supervisory authority and, where required by the said regulations, to the persons concerned (individually or generally as the case may be).
Of course, it is also your responsibility to exercise caution to prevent unauthorized access to your personal data and terminals (computer, smartphone, tablet, etc.).
In addition, the Delville Management website may provide 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 with regard to the protection of any personal data they may collect. Consequently, Delville Management declines all responsibility concerning the processing by these third parties of your personal data, which is not subject to the present policy. It is your responsibility to inform yourself 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 accurate information about how your personal data is processed (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 the exceptions provided for by applicable law (e.g., storage necessary to comply with a legal obligation), you have the right to request that Delville Management erase your personal data as soon as possible in the following cases:
- Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- You wish to withdraw your consent to the processing of your personal data and there are no other grounds for such processing;
- You consider and can establish that your personal data has been processed unlawfully;
- Your personal data must be deleted in accordance with a legal obligation.
Right to explainability: When processing is likely to produce legal effects on data subjects, or significantly affect them, particularly through the use of an artificial intelligence system, Delville Management ensures transparency and understanding of the processing. You therefore have the right:
- To obtain clear, understandable, and appropriate explanations, in compliance with obligations of transparency and protection of trade secrets or intellectual property rights;
- To obtain relevant information about the existence of automated decision-making, including decision-making using an artificial intelligence system;
- To be informed of the general logic on which the automated processing is based;
- To understand the importance and consequences of this treatment;
- To request human intervention to review the decision;
- To challenge the automated decision.
Right to object to the processing of your personal data: Where the processing of your personal data is necessary for the performance of a task in the public interest or in the exercise of public authoritý vested in Delville Management, or due to the legitimate interests of Delville Management or a third party, the right to object gives you the right to object to the processing of any personal data in relation to your particular situation. If your personal data is processed for canvassing purposes, you have the right, regardless of the legal basis for such processing, at any time and free of charge, to object to such processing, including profiling insofar as it is related to such canvassing, whether initial or subsequent processing.
Right to limit the processing of your personal data: The applicable regulations provide that this right may be invoked in certain cases, in particular the following:
- When you dispute the accuracy of your personal data;
- When you consider and can establish that the processing of personal data is unlawful but you oppose the erasure of personal data and instead demand the restriction of processing;
- When Delville Management no longer needs your personal data but you still need it to establish, exercise, or defend legal claims;
- When you object to processing that is based on the legitimate interests of the controller, during the verification as to whether the legitimate grounds pursued by the controller prevail over those of the data subject.
Right to portability of your personal data: Where 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 controller without Delville Management hindering this. Where technically possible, you may request that such personal data be directly transferred to another controller by Delville Management. The data concerned by portability is limited to the raw data that you have transmitted to us, to the exclusion of data resulting from work carried out by Delville Management.
Right to withdraw consent to the processing of personal data: When Delville Management processes your personal data on the basis of 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 valid only for the future and does not call into question the lawfulness of the processing carried out prior to this withdrawal or based on any other grounds such as, for example, the performance of a contract.
Right to lodge a complaint with a supervisory authority: If, despite Delville Management's efforts, you feel that your rights have not been respected, you have the right to lodge a complaint with a supervisory authority. A list of supervisory authorities is available on the European Commission website.
Right to decide what happens to your personal data after your death: Finally, you have the right to organize what happens to your personal data after your death by adopting general or specific directives. Delville Management undertakes to respect these directives. In the absence of directives, Delville Management recognizes the possibility for heirs to exercise certain rights, in particular the right of opposition and deletion to close the deceased's account and oppose the processing of his or her data.
How to exercise your rights?
You can exercise your rights to the protection of personal data by sending us your request, together with a copy of any identity document, as follows:
By e-mail to: rgpd@delvillegroup.com
By post:
DELVILLE MANAGEMENT
Administrative department - RGPD
15 avenue de la Grande Armée
75016 Paris, France
Delville Management undertakes to reply as soon as possible, and in any event within one month of receipt of your request.
If your request is submitted electronically, the information will also be provided electronically where possible, unless you expressly request otherwise.
If we do not comply with your request, we will inform you of the reasons for our inaction and you will have the right to lodge a complaint with a supervisory authority and/or to take legal action.
For the purposes of traceability and proof of the deletion of your data, we will retain your deletion request, the date of the effective deletion and the date of the reply sent by Delville Management for a period of 5 years from the effective deletion of the data.
Distribution of the Personal Data Protection Policy
This Personal Data Protection Policy is available on our website www.delville-management.com. Data controller Delville Management SAS is represented by Mac-Mahon, itself represented by its President Patrick Abadie.
Applicable law
This Policy is subject to French law. In the event of a dispute and if an amicable agreement cannot be reached, the competent courts shall be those within the jurisdiction of the Paris Court of Appeal, notwithstanding multiple defendants or the introduction of third parties.
Last updated: 12/01/2025
