Privacy Policy

Personal Data Protection

Principles Applied by Fluence

Fluence complies with the principles of purpose limitation, proportionality and data minimization introduced by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).

Fluence collects and processes personal data for a specific, explicit and legitimate purpose, corresponding to the objectives pursued. In order to respect the principle of proportionality, Fluence only collects and processes information that is adequate, relevant and necessary for the purpose of the processing.

The principle of data minimization means that personal data may only be processed if the purposes of the processing cannot be achieved by processing information that does not contain personal data.

Data may only be accessed by persons authorized to do so by virtue of their functions.

Fluence is bound by an obligation to ensure data security. It must therefore take all necessary measures to guarantee confidentiality and prevent any disclosure of information. To this end, Fluence implements an IT charter, data retention and protection policies, and a comprehensive cybersecurity risk management system.

Data Protection Officer (DPO)

The Data Protection Officer at Fluence is Mr. Sébastien Vaxelaire.

Rights and Obligations

Right to Erasure

Individuals whose data has been collected have the right to obtain from the data controller, without undue delay, the erasure of personal data concerning them (right to be forgotten). The right to erasure does not prevail over certain data archiving obligations for specified periods, particularly for compliance with tax obligations or prevention of money laundering and terrorist financing.

Data Portability

The data subject may require a data controller to transmit their personal data to another data controller, without the data controller that initially collected the data being able to object. In this context, data subjects have:

  • The right to receive personal data concerning them that they have provided to a data controller, in a structured, commonly used and machine-readable format, and to transmit it to another data controller
  • The right to have the data transmitted directly from one data controller to another where technically feasible

The right to data portability only applies if the data processing is carried out by automated means and therefore does not cover most paper files.

Respect for Individual Rights

Information relating to data processing is provided on the website. Any person has the right to object, on legitimate grounds, to the processing of data concerning them, unless the processing is mandatory.

Furthermore, any individual who can prove their identity has the right to request from the data controller:

  • Whether or not data concerning them is being processed
  • Communication of the data concerning them in an understandable form, and all available information about its origins
  • Information about the purpose of the processing, the data collected and the recipients

Limited Data Retention Period

Fluence does not retain information in files indefinitely. It establishes a retention period based on the purpose of each file as described in its data archiving procedure.

Exercising Rights as a Data Subject

The rights of prospects, clients, beneficiaries, applicants and employees are:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to object to automated decision-making
  • Right to rectification/restriction of data
  • Right to data portability

A request to exercise a right may be submitted by:

  • Post to 11 rue Pastourelle, 75003 Paris, France
  • Email to contact@fluence.eu
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