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
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.
Black Winch processes your personal data for the purposes of, as the case may be:
In these two situations, Black Winch acts as a "Data Controller" within the meaning of the
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.
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.
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.
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:
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.
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 email@example.com.
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
The Black Winch Privacy Leader is Sophie Féret.