Last update: June 4, 2021
In addition to the Social Support and Psychological Support subjects to separate terms and conditions, the “LVMH Heart Fund Program” also proposes an exceptional financial support (the “Financial Support”), funded by the LVMH Heart Fund Association, a dedicated non-profit association created by LVMH Group, to eligible employees of LVMH or entities controlled by LVMH facing a situation of great difficulty in their private life and subject to the terms and conditions available at https://www.workplaceoptions.com/terms-of-use-lvmh/. When you apply for such financial support of the LVMH Heart Fund Program on the WPO website available at the following address https://www.advantageengagement.com/forms/lvmh/lvmh_eng.html (the “WPO Website”), you disclose your personal data to WPO. No entity from the LVMH Group, including the LVMH Heart Fund Association, will access the personal data you have provided to WPO. Your personal data are protected by law. WPO has implemented high standards of confidentiality and security in order to protect your personal data.
Please read this privacy policy carefully as it explains how WPO uses your personal data. Should you have any questions, you may directly contact WPO by sending an email to dataprotection@workplaceoptions.com
1. What kind of personal data are processed?
All personal data provided by you through your application for the LVMH Heart Fund Program or when your communicate with WPO are:
| Type of data |
Examples of data |
| Identification data |
First name, last name |
| Personal contact details |
Personal email address, personal postal address, personal phone number |
| Employment information |
Employer’s identity, employment situation (full-time or past-time), last pay slip |
| Data related to your child (only where applicable) |
First name, last name, personal postal address, age, disability situation (if relevant for major child only) |
| Data related to the situation of great difficulty you are facing |
Nature of the event (accident, natural disaster, external domestic disaster, personal crisis, other), description of the event (date, concerned individual, explanation of the event), nature of your financial needs and amount of funds you are looking to receive, document(s) evidencing the existence of the event, any other information on the event |
| Financial information |
Absence of funds received as part of the LVMH Heart Fund Program, date of the funds’ allocation and amount of the allocated funds, banking details |
All the requested information are necessary for WPO in order to review your application for the LVMH Heart Fund Program. If you do not provide them, your application cannot be processed.
The WPO Website only utilizes a session cookie which is mandatory. Tracking cookies are not used. Please see the Cookies Policy of WPO.
2. For what PURPOSES does WPO use your personal data?
WPO processes your personal data for the following purposes only:
| Purposes |
Examples of use of your personal data |
Legal bases |
| Review of your application for the LVMH Heart Fund Program |
· to ensure that you meet all the prerequisites to receive funds from the LVMH Heart Fund Program
· to determine the amount of the funds to be allocated (if you are eligible) |
pre-contractual steps prior to entering into the terms and conditions |
| Funds allocation |
· to organize the funds allocation
· to allocate the funds |
Performance of the terms and conditions |
| Management of your information request or complaint |
· to process and answer your information request
· to process and answer your complaint |
Performance of the terms and conditions |
| Management of the WPO Website used for your application for the LVMH Heart Fund Program |
· to evaluate and improve the online platform
· to facilitate your use of the online platform
· to take steps designed to protect the security of the online platform |
Legitimate interest of WPO to improve the online platform, as well as your user experience on the online platform |
| Statistical evaluations |
· to establish (anonymous) statistics and surveys on the management of LVMH Heart Fund Program |
Legitimate interest of WPO in improving its services and products |
| Pre-litigation or litigation management |
· to take action against any misconduct
· to manage any dispute or litigation |
Legitimate interest of WPO in defending its rights and interests |
| Compliance with legal and regulatory obligations |
· to comply with legal and regulatory obligations
· to process your requests to exercise your rights |
Legal and regulatory obligations to which WPO is subject |
3. Who can access your personal data?
Your personal data may be transmitted to the following recipients:
| Recipients |
Purposes |
| WPO’s subcontractors (hosting provider, IT service providers, etc.) |
Exclusively for technical or logistical purposes |
| Administrative or judiciary authorities |
Exclusively in the case of an express and justified request or in case of an alleged violation of legal or regulatory provisions |
| Lawyers and all interested parties |
Exclusively in the case of the management of possible disputes and other legal matters where appropriate |
| Other third parties |
Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of WPO or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as assets of WPO |
4. Will your personal data be transferred outside of your country?
If you are located within the EU/EEA/UK, your personal data will be, as far as possible, processed within the EU/EEA/UK. In the case that your personal data are transferred outside of the EU/EEA/UK, WPO will, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient is established, implement all necessary measures through the adoption of appropriate safeguards (such as standard contractual clauses and any supplementary measures as and if required by applicable data protection laws). A copy of such safeguards can be obtained by sending an email directly to WPO at dataprotection@workplaceoptions.com.
| Name of the recipient |
Third country |
Adopted safeguards |
| Workplace Options LLC |
USA |
Standard Contractual Clauses |
If you are located outside the EU/EEA/UK, WPO will comply with local applicable data protection legislation’s requirements and/or restrictions regarding location and transfers of personal data.
- How does WPO protect your personal data?
WPO has implemented technical and organizational measures in order to protect your personal data, in particular against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures will guarantee high standards of confidentiality and security adapted to the risks and nature of the personal data to be protected. WPO reviews and updates its practices regularly to enhance your privacy and ensure that its internal policies are followed.
If you have identified a vulnerability or would like to report a security incident, you may send an email to security@workplaceoptions.com
6. For how long are your personal data STORED?
As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations. In the absence of applicable exceptions, the data collected via your application for the LVMH Heart Fund Program will be kept until, where applicable, either the application is rejected or the payment of the funds.
Beyond, WPO will keep your personal data for:
- five (5) yearsfrom the termination of the LVMH Heart Fund Program for evidence purposes relating to legal claims;
- ten (10) yearsfrom the end of the relevant tax year for personal data retained for accounting purposes.
7. What are your rights regarding your personal data?
You have the following rights over your personal data:
- you can request the accessto your personal data in order to obtain clear, transparent and understandable information on how WPO processes your personal data and on your rights (as provided in this policy), as well as a copy of your personal data.
- you can request the rectification of your personal data in order to obtain the modification of your personal data if they are obsolete, inaccurate or incomplete.
- you can objectto the processing of your personal data when the processing is based on WPO’s legitimate interest. WPO will no longer process your personal data unless WPO demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims.
- you can request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies:
-
- you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for WPO to verify the accuracy of such personal data;
- the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use;
- WPO no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
- you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of WPO may override your interests, rights and freedoms.
- you can ask to receive your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another controllerwhere technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions:
-
- your request is only related to your personal data (excluding anonymous or third party data);
- your request does not adversely affect the rights or freedoms of others, in particular those of WPO (including trade secrets or intellectual property rights);
- the processing is carried out by automated means (paper files are therefore not included);
- the processing is based on consent or the performance of a contract (to check if it is the case, you can see the article 2 of this policy).
- you can request the deletion of your personal data (or right to be forgotten), where one of the following legal grounds applies:
-
- you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (such as an obligation for WPO to keep certain personal data);
- your personal data are no longer useful for the original purposes for which they were collected or for any other type of processing;
- the use that is made of your data does not comply with the applicable legal or regulatory provisions.
- You candefine either general or specific guidelines regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You may revoke your instructions at any time.
Under certain circumstances, WPO may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.
If you have any questions or wish to exercise your rights, you may directly contact WPO by sending an email to dataprotection@workplaceoptions.com
If needed, you may also lodge a complaint with your national data protection authority (the CNIL for France). This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
