Privacy policy

Data controller

Herman Twagiramungu, avocat, 1 rue de l'Église, 95120 Ermont, is the controller for the processing described below.

The firm is not required to appoint a data protection officer: it carries out neither large-scale regular and systematic monitoring nor large-scale processing of special-category data. Requests concerning personal data are sent to cabinet@ht-avocat.com.

Data collected by this site

This site has no general contact form, no client area and no newsletter sign-up. The only data transmitted through it is what you voluntarily enter in the application form:

• Identity: surname, first name
• Contact details: email address, telephone number if you provide one
• Application: position applied for, free-text message, curriculum vitae

No browsing data is collected for audience measurement unless you have consented to it.

Purposes and legal bases

• Handling applications: steps taken at your request prior to entering into a contract (article 6.1.b GDPR)
• Retaining an application beyond the current recruitment: your consent (article 6.1.a), obtained through a checkbox that is not pre-ticked
• Audience measurement: your consent, obtained through the cookie banner and off by default
• Replying to an email you send the firm: legitimate interest in answering an enquiry (article 6.1.f)

Retention periods

• Unsuccessful application, with consent: two years from the last contact, the period recommended by the French data protection authority for recruitment data, then deleted
• Unsuccessful application, without consent: deleted at the end of the recruitment process concerned
• Emails sent to the firm: three years from the last exchange, the general limitation period applicable to an enquiry that went no further
• Cookie choice: six months, after which the banner reappears

These periods follow statutory time limits and the guidance of the French data protection authority; they are not undertakings specific to the firm. They do not apply to client files, which are governed by the retention obligations specific to the profession — five years from the end of the retainer, under article 2225 of the Civil Code.

Recipients

Application data is accessible only to the firm's partners and recruitment managers, and to the lawyers of the practice concerned.

No data is sold, rented or transmitted for commercial purposes. No transfer outside the European Union takes place.

Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability provided for by the GDPR. Where processing rests on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out beforehand.

These rights are exercised by email to cabinet@ht-avocat.com. A reply is sent within one month.

You may also lodge a complaint with the French data protection authority (CNIL) — 3, place de Fontenoy, 75007 Paris.

Professional secrecy

Information you send the firm in connection with a request for advice is covered by lawyers' professional secrecy, which is distinct from and broader than personal data protection.

That secrecy is a matter of public policy: the firm cannot be released from it, including by you.