Privacy Policy

This privacy policy defines personal data, specifies what types of personal data we collect and for what purposes, how we process it and what your rights are in this regard. Particularly sensitive to the sensitivity of this data, we undertake to take the greatest care of it.

Last modified date: November 3, 2021



1. DEFINITION OF PERSONAL DATA

Personal data is data that allows a person to be identified directly (last name and first name) or indirectly (phone number, address, email address, etc.). This identification is done either with a single piece of data (an identifier), or with a crossing of a set of data.



2. GENERAL PRINCIPLES OF THE PROCESSING OF PERSONAL DATA BY BROADWAYACCESS.FR

We apply the following principles when processing your personal data:
  1. we only collect personal data for specified, explicit and legitimate purposes,
  2. we do not collect data beyond what is necessary to fulfill these purposes,
  3. we do not use personal data for purposes other than those for which it was collected, except as specified herein or with your prior consent,
  4. we do not transfer personal data to third parties, except as specified herein or with your prior consent,
  5. we do our best to ensure that the information is up to date and encourage you to periodically check your personal data,
  6. we put in place appropriate technical and organizational measures to protect your personal data against any accidental or unlawful destruction or against accidental loss, alteration, unauthorized distribution or access as well as against any other form of unlawful processing,
  7. apart from what is specified herein, we do not keep personal data beyond the time necessary to achieve the purpose for which they were collected or for which they are subject to further processing or when required by law.


3. PERSONAL DATA THAT WE COLLECT AND PROCESS

The personal data that we collect and process concerns:

Your e-mail address, your first and last name, your gender, your date of birth and possibly a profile photo that we collect with your consent as part of a registration, registration confirmed by a confirmation e-mail.
As an external user, this registration allows us to give you access to documents and reports concerning certain cases that we manage.
As an intern, this registration allows us to give you access to documents, reports, an activity workflow concerning the cases that you will have to manage. In addition, you will also have access to a trombinoscope, an absence management tool (managed by an external third party) and your payslip library (managed by an external third party).
Company data concerning the business that we manage is not affected by this policy.



4. HOW DO WE USE YOUR PERSONAL DATA?

Here is our use by type of personal data collected:
  1. Your email address serves as the platform access identifier. In addition, we will provide you with information notifications through this;
  2. Your name, first name, date of birth, gender and profile picture are used to give a “social” aspect to the platform. This information is used to customize the formatting and as an intern, they feed the company's trombinoscope (accessible only to Manhattan SAS interns). Except for the case of the company internal trombinoscope, this information is not accessible to other users.


5. WHERE WE STORE AND PROCESS YOUR PERSONAL DATA

Your personal data is stored and processed within the European Economic Area (EEA). Specifically, your data is stored in one of (3) three data centers owned by AWS; present in the Paris area. In the event of transfer of your personal data to a third country, as defined in the General Data Protection Regulation (GDPR), valid laws and regulations regarding such transfers are observed, and applicable legal and security guarantees are taken prior to such transfers.



6. OUR TRANSMISSION OF YOUR PERSONAL DATA TO THIRD PARTIES

We do not sell your personal data and we do not share it with third parties, except as mentioned in this Privacy Policy. We may transmit your personal data to third parties to the extent required by law, a court order or a decision issued by a competent public authority and for law enforcement purposes. In addition, we may share your personal data with the following third parties:

  1. Third parties to establish, assert or defend the rights of Broadway Access or Manhattan SAS;
  2. Third parties in the event of a merger, sale, joint venture, assignment, transfer or other assignment of all or part of the assets managed by Broadway Access or Manhattan SAS (including and without restriction in bankruptcy or similar proceedings);
  3. Other third parties subject to your consent.

When we transmit your personal data to a third party, we take all reasonable measures to ensure that these third parties are bound by obligations of confidentiality with regard to the protection of your personal data. The transmission is carried out in accordance with legal requirements, including through the signing of processing agreements data with relevant third parties, in order to ensure that personal data is only processed in accordance with our instructions, applicable law and regulations. force and for the use specified by us, and to apply the appropriate safety measures.



7. RETENTION OF YOUR PERSONAL DATA

We keep your information for a period that does not exceed that necessary for the purposes for which it was collected. The length of time we keep the information depends on the purposes for which we collected and use it. Personal data is deleted on the date you unsubscribe. Relevant personal information will be deleted at the end of the aforementioned periods, unless such data can be legitimately retained and processed by others purposes for which we have a legal framework.



8. DATA CONTROLLER

Romain Magnan and Louis Fiori through Manhattan SAS (manager of the Broadway Access platform), are the data controllers and responsible for the processing of your data personal.



9. ACCESS TO YOUR PERSONAL DATA AND DATA PORTABILITY

You have the right to receive and access personal data about you, which you have provided to Broadway Access in a structured, commonly used and readable format by a computer (JSON format). You have the right to transmit this data to any third party of your choice. Your personal data processed by Broadway Access can be accessed at simple request or directly to the page: https://www.broadwayaccess.fr/Identity/Account/Manage/PersonalData



10. UPDATING AND / OR DELETION OF YOUR PERSONAL DATA

We encourage you to update your personal data provided to Broadway Access if there is a change. You can do this directly from the page: https://www.broadwayaccess.fr/Identity/Account/Manage. In addition, you can delete your data (and at the same time, your account) directly from the page: https://www.broadwayaccess.fr/Identity/Account/Manage/DeletePersonalData



11. RIGHT TO WITHDRAW YOUR CONSENT

Certain processing activities by Broadway Access may be dependent on your consent. In this regard, you will be entitled to withdraw your consent at any time. The withdrawal of your consent will not affect the legitimacy of the processing carried out before your withdrawal. If you withdraw your consent, Broadway Access and third parties involved in the processing of personal data will cease to process your personal data, except and to the extent that continued processing or storage is permitted or required in accordance with applicable personal data legislation or other applicable laws and regulations. Note that following the withdrawal of your consent, Broadway Access may not be able to meet your requests or provide its services to you.



12. RIGHT TO RESTRICT PROCESSING AND RIGHT TO OBJECT

You have the right to restrict the processing of your personal data if:

But you oppose the erasure of your personal data, if:

For our contact details, see section 16. At any time, you have the right to object to the processing of your personal data for direct marketing purposes.



13. WEBSITE, PLUG-INS AND THIRD-PARTY SERVICES

The Broadway Access website may contain links to third party websites and plug-ins. If you choose to use these third-party websites, plug-ins or services, you may be required to transmit your information to these third parties. Broadway Access is not responsible for content or practices of such websites, plug-ins or services. The collection, use and transmission of your personal data will be subject to the privacy policies of these third parties and not here. We urge you to read the confidentiality and security policies of the third parties concerned.
Specifically :



14. USE BY CHILDREN

The Broadway Access web application is not aimed at children and its intention is not to attract them. Minors must obtain the express consent of their parents or legal representative before providing personal data. If we learn from a parent or legal guardian or other means that a child under the age of sixteen has provided their personal data to Broadway Access, we will delete the child's personal data in our possession.



15. CHANGES TO OUR PRIVACY POLICY

Manhattan SAS may modify or update this Privacy Policy when necessary to reflect changes in law, regulations or current practice. That is why we invite you to consult it periodically. The date of the last update always appears at the top of the document. If there is a material change to this Privacy Policy, we will let you know by posting a notice or sending you a notification.



16. CONTACT DETAILS

If you have any questions regarding this Privacy Policy or the processing of your personal data by Broadway Access, we invite you to contact the persons following: