Privacy Policy

Effective Date: February 2025

1. Introduction

Welcome to BESPOKE CONSULTING SAS (“Bespoke Consulting,” “we,” “us,” or “our”). We are committed to protecting your personal data in compliance with the General Data Protection Regulation (GDPR), relevant French data protection laws, and guidance from the Commission Nationale de l’Informatique et des Libertés (CNIL).

This Privacy Policy applies to personal data that you provide to us or that we collect when you:

• • Visit or use our websites (including www.bespoke-consulting.fr) or any other Bespoke Consulting web pages that link to this Privacy Policy (“Sites”).
• • Interact with us in the context of requesting information, subscribing to our newsletters, or responding to Bespoke Consulting outreach.

Depending on your relationship with Bespoke Consulting, additional or different privacy statements may apply.

2. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any changes will be posted on this page with an updated “Effective Date.”

3. Types of Personal Data We Collect

We may collect the following categories of personal data:

• • Identifiers: Name, email address, phone number, job title, company name, IP address, and approximate geolocation.
• • Demographics and Preferences: Areas of professional interest, responses to surveys, and other information you voluntarily provide.
• • Internet or Network Activity: Browsing history on our Sites, links clicked, and other usage data collected via cookies or similar technologies.

You are not obliged to provide personal data to us. However, some features (e.g., requesting services or subscribing to updates) may not function properly without certain data.

4. How We Use Your Personal Data

We process your personal data for the following purposes under the lawful bases permitted by GDPR and French law:

1. 1. Legitimate Interests:
   • o Communicate with you about our services, respond to inquiries, and manage our client relationships.
   • o Tailor content, measure the effectiveness of our Sites, and improve user experience.
   • o Conduct surveys and analyze user behavior to enhance our marketing strategies and product offerings.
   • o Ensure the security and functionality of our Sites, IT systems, and network.
2. 2. Consent (where required):
   • o Send marketing communications, newsletters, or event invitations.
   • o Use cookies or similar technologies for analytics and advertising (except where we rely on legitimate interests).
   • o You can withdraw your consent at any time.
3. 3. Legal Obligations:
   • o Comply with applicable laws, regulations, court orders, or government
     requests.
   • o Enforce our legal rights and obligations, defend ourselves in legal
     disputes, and prevent fraud.

5. Disclosure of Your Personal Data

We may share your personal data with:

• • Affiliates and Subsidiaries: For internal business operations and to provide services.
• • Trusted Service Providers: Such as IT hosting, email distribution, marketing support, and security services bound by confidentiality obligations.
• • Advisors and Business Partners: For co-organized publications or events, and to receive professional advice (e.g., legal, financial).
• • Third Parties (Cookies/Analytics): As detailed in our cookie consent manager, we may allow authorized third parties to use cookies or similar technologies for analytics and advertising purposes.
• • Legal Authorities: To comply with a legal obligation, protect our rights or the rights of others, or as required by court order or other legal processes.
• • Corporate Transactions: In connection with a merger, acquisition, sale of assets, financing, bankruptcy, or similar proceedings.

Where we transfer personal data outside of the European Economic Area (EEA), we ensure an adequate level of protection (e.g., through Standard Contractual Clauses or other recognized mechanisms).

6. Retention of Personal Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, and in accordance with:

• • The duration of our ongoing relationship with you (e.g., while you use our services or interact with us).
• • Legal or regulatory requirements (e.g., mandatory record-keeping).
• • Our legitimate interests or legal positions (e.g., statutes of limitation).

7. Marketing Communications

If you no longer wish to receive marketing communications from us, you may unsubscribe at any time using the link provided in our emails or by contacting us directly.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• • Understand how you use our Sites.
• • Personalize and improve your experience.
• • Deliver relevant advertisements (where applicable).

You can manage your cookie preferences through your browser settings or via our cookie consent banner. Please note that disabling cookies may affect the functionality of certain Site features. We do not currently respond to “Do Not Track” signals.

9. Security Measures

We implement industry-standard technical and organizational safeguards to protect your personal data against unauthorized access, disclosure, or misuse. Despite these measures, no system can guarantee complete security. We are not responsible for unauthorized access that is beyond our reasonable control.

10. Third-Party Links

Our Sites may contain links to external websites operated by third parties. We are not responsible for the content, privacy practices, or security of these external sites. We encourage you to review the privacy policies of any website you visit.

11. Compliance with Law

We may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. We may also disclose your personal data where we believe necessary to protect our rights, users, systems, and Sites.

12. Your Rights Under GDPR (and French Law)

Depending on your location and subject to certain limitations, you may have the following rights:

• • Right of Access: Obtain confirmation whether we process your personal data and access a copy of it.
• • Right to Rectification: Request correction of inaccurate or incomplete personal data.
• • Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data, subject to certain exemptions.
• • Right to Restriction: Ask us to limit the processing of your personal data in certain circumstances.
• • Right to Object: Object to certain processing of your personal data based on our legitimate interests or for direct marketing purposes.
• • Right to Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.
• • Right to Withdraw Consent: If processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
• • Right to Lodge a Complaint: You may file a complaint with the CNIL or another competent supervisory authority if you believe your rights have been violated.

To exercise any of these rights, please contact us (see Contact Us below). We may need to verify your identity before processing your request.

13. Children’s Privacy

Our Sites are not designed for, and do not intentionally target, individuals under 18 years of age. We do not knowingly collect personal data from minors.

14. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact:

Data Protection Office
Bespoke Consulting SAS
99 avenue Achille Peretti
92200 Neuilly-sur-Seine, France
Email: Contact@bespoke-consulting.fr