Black winch

Privacy Policy

Black Winch is committed to protecting your personal data and to ensuring that the

collection and processing of personal data complies with the General Data Protection

Regulation (GDPR).

This statement explains how we process your personal information collected.

In what follows the term "You" or "Your" refers to any person affected by the processing of

personal data which is the subject of this data protection policy.

Processing Your Data

Black Winch processes your personal data for the purposes of, as the case may be:

  • Managing the commercial, financial and marketing relationship between Black Winch and its clients, partners and suppliers. The legal basis for this processing is the legitimate interest of Black Winch to ensure its administrative and financial operations and to develop its business. Commercial prospecting communications are based on your consent, and you may ask at any time not to receive any further commercial solicitations.
  • To manage your application for a job with Black Winch.

In these two situations, Black Winch acts as a "Data Controller" within the meaning of the

Applicable Regulations.

To carry out assignments entrusted to Black Winch by its clients, which may involve the

processing of your personal data if you are employed by a client of Black Winch, or by a

client of a client of Black Winch.

The legal basis for this processing is the legitimate interest of Black Winch in being able to

fulfill its contractual obligations to its clients, and/or the legal obligations that apply to

Black Winch in the exercise of its activities.

Personal Data Collected

When acting in its capacity as Data Controller, Black Winch limits the collection of

personal data to that which is adequate, relevant and strictly necessary for processing.

Black Winch, when acting as a subcontractor for the purposes of carrying out the

assignments entrusted to it by its clients, undertakes contractually within the framework

of its assignment contracts to ensure the utmost respect for the security and

confidentiality of the personal data that it is required to process in this context.

Sensitive Data

Black Winch does not collect any sensitive data except insofar as required by legal and

regulatory provisions (e.g. for recruitment purposes).

"Sensitive data" is any information relating to an individual which reveals: racial or ethnic

origins, political, philosophical or religious opinions, trade union membership, information

relating to health and/or sex life and/or criminal convictions and in certain cases the

national registration number or financial data.

Black Winch has put in place, where necessary, all measures to ensure the protection of

the confidentiality and security of such data so as to avoid any loss or misappropriate or

fraudulent use of the data.

Transmition Of Data

Black Winch undertakes to communicate the personal data collected only to third parties

who are subject to local regulations offering an adequate level of protection in terms of

personal data protection and/or who have expressly agreed to provide an adequate level of

protection in terms of personal data protection. In particular, we may communicate your

data to third parties for the following reasons:

  • Whenever it appears necessary to involve an external service provider in order to respond to your request;
  • When you expressly ask us to communicate your data;
  • At the request of a court or in application of a legal or regulatory provision;
  • If their communication is reasonably related to the sale or all or part of our commercial activities.


Your personal data processed by Black Winch is kept in Europe for a period appropriate to

the purpose of each processing operation and, when Black Winch acts as a subcontractor

to carry out an assignment, for the period defined contractually with the client.

In particular: data relating to prospective clients of Black Winch is kept for a maximum of

two years after the last contact with Black Winch; data relating to candidates for

employment with Black Winch is kept for a maximum of two years after the last contact

with the candidate.

Exceptionally, this data may be kept for longer periods in order to manage complaints or

disputes, or to meet legal and/or regulatory obligations.

Your Rights

You have the right to request access to your personal data and the rectification of

inaccurate data. You may request the erasure of data and the restriction of processing, and

you may also object to processing, in the cases and within the limits provided for by the

applicable legislation. You have the right to the portability of the personal data that you

have provided to Black Winch, under the conditions provided for by the applicable

legislation. You also have the right to define directives relating to the conservation,

deletion and communication after your death of your personal data processed by Black

Winch, in accordance with the applicable laws and regulations.

Where processing is based on your consent, you may withdraw it at any time.

We will verify the identity of the applicant and the validity of the request, taking into

account the specific nature of each right and the consequences and actions resulting

from it, the various types of persons concerned, and the consistency of the information

provided in relation to these rights.

Requests will be processed as quickly as possible and in any event within one month of



You may exercise your rights either by sending an e-mail to

Your request will be processed as quickly as possible, provided that you can prove your

identity by attaching a copy of your official identity document and a telephone number to

your e-mail.

Privacy Leader

The Black Winch Privacy Leader is Sophie Féret.