This privacy policy (the “Policy”) is intended to inform you of the practices of ENALIA, a simplified joint stock company with a capital of €500,000, registered at the Paris register of companies under number 539 196 857, and whose head office is located at 42 rue de Washington 75008 PARIS (the “Company”), and its commitments to the collection, use and processing of your Personal Data for the purpose of its business needs, in accordance with Act n°78-17 of 6 January 1978 Data Processing, Data Files and Individual Liberties, amended, and the European (EU) regulation 2016/679, the General Data Protection Regulation (GDPR) on how your Personal Data is processed and the free circulation of said data.
When using the https://www.enalia.com/ website (the “Website”) and receiving offers of energy efficiency services, and the French energy efficiency certificates (CEE) scheme in particular, in accordance with the conditions defined in the French Energy Code, you will be asked to provide the Company with Personal Data.
The Policy can be accessed via the dedicated page on the Website.
By connecting to and browsing the Website, you acknowledge having read, understood, and accepted, without limitation of reserve, the Policy informing you of your rights and liberties with regard to how the Company uses your Personal Data, and the measures it has put in place to protect them, as well as the use of cookies.
The content of the Policy may change over time, especially with regard to its compliance with current regulations, so you are advised to regularly check the Policy in order to stay up to date with the latest changes.
Personal Data: refers to personal data about the User, collected and processed as part of our Services, and primarily within the framework of the CEE scheme. This data can, in any form and directly or indirectly, be used to identify the natural persons whom they concern.
Data Processing Manager: refers to the Company, which determines the Purpose and resources involved in processing Personal Data, in line with applicable legislation, within the framework of and as required by the delivery of Services.
Services: refers to the full range of services offered by the Company within the bounds of its purpose, regarding the delivery of energy retrofitting work under the CEE scheme, and for the following purposes in particular:
- To provide information about the existence of Services, notably via the Website, and to encourage potential beneficiaries to carry out projects eligible for the CEE scheme
- Download the document entitled “white paper”, or any other document as required
- Potentially provide advice on and contact with qualified energy retrofitting professionals (the “Partners”)
- Advice on potential clients’ eligibility for energy retrofitting grants
- Provide information on the delivery of energy retrofitting work under the CEE scheme
- To transfer or ensure the transfer to the Beneficiary of any CEE scheme premiums generated by the work
- Offer subscription to a newsletter
- And any other existing or future service provided by the Company
User: refers to any person in contact with the Company as part of its Services, and in particular:
- Any individual who visits the Website
- Any individual who requests information about the Services (“Potential Clients”) and
- Any individual receiving the Services (hereafter, the Beneficiaries)
PNCEE: refers to the Pôle National des Certificats d’Economie d’Energie (French National Energy Efficiency Certificate Body), the organisation responsible for overseeing the implementation of the CEE scheme, and therefore for centralising CEE scheme requests, assessing and then awarding CEE, and enabling the Beneficiaries to receive the corresponding premiums.
As the Data Processing Manager, the Company collects and processes several different kinds of Personal Data:
1. Data relating to use of the Website and login data:
In order to create and use your user account on the Website, the Company collects and processes Personal Data that is used to identify you. These include: your first name and surname, age, postal address, email address, location, phone numbers (landline and mobile), and your IP address.
On the Website’s contact and user account forms, or when subscribing to a newsletter, fields marked with an asterisk (*) are compulsory and essential to the Company being able to process your request for information. If you do not complete the fields marked with an asterisk, the Company will be unable to process your request. Responses to the other questions are optional.
The Company also collects your IP address and uses cookies when a User is browsing the Website.
2. Data about your home and/or its equipment, as soon as they are required in order to assess your situation with regard to the CEE Scheme:
- The characteristics of your property, such as: location, surface area, year built, type and size of spaces that can be insulated, heating type and kind of energy used
- Your status: owner, tenant, etc.
- The kind of property: detached house, apartment, co-ownership
3. Data collected as part of the assessment, processing, and tracking of the CEE scheme application:
In addition to the Personal Data defined in articles 2.1 and 2.2, the Company also collects the following Personal Data:
- As part of assessing eligibility for certain low income schemes, as defined in the CEE scheme regulations, data that is high risk but not sensitive under the terms of the GDPR: information about your income, submission of your tax report, etc.
- Any information that can be used to identify you found on any document required by the Scheme, including your sworn statement, and including your signature
- As part of checks carried out at your home to verify that the work carried out complies with regulations, either directly or through a service provider, you may be asked to provide photographs of your home (exterior and/or interior)
- As part of later inspections of work carried out at your home, the Company may, itself or through a service provider, record telephone conversations with you, as well as any exchange of letters or emails
Users are informed that their Personal Data will be digitally processed, updated, and used under the responsibility of the Company, in its capacity of Data Processing Manager, for the following purposes/services:
- To create and manage your user account, and to support you in identifying suitable energy efficiency projects
- Overseeing the delivery of your energy retrofitting projects, and inspecting them within the framework of the CEE Scheme
- Obtaining grants for energy retrofitting work under the CEE Scheme
- Compiling applications for any premiums for which you are eligible
- Processing and tracking these applications through the PNCEE
- The Company’s compliance with the legal and regulatory requirements applicable to the CEE Scheme, to which the Company is bound
- To send information and news about the energy retrofitting work and its Services, or to contact you regarding new energy efficiency opportunities
- The processing conducted by the Company is the result of both its legal and regulatory obligations under the CEE Scheme, and its contractual obligations towards its Partners and Beneficiary contacts, as well as Potential Clients and Beneficiaries.
The Company only collects and processes Personal Data that is essential to delivering on the Purpose and Services.
We are committed to obtaining your clear informed consent, unless the data collection is necessary for the contract or falls under one of the Company’s legal obligations.
The Personal Data and information collected and processed by the company are strictly for the use of the Company and any sister companies and/or companies belonging to the same group as the company, their subcontractors, its Partners and their subcontractors, any service provider working for the Company to fulfil the needs of the Services or CEE Scheme (e.g. Personal Data hosting companies, developers of the software used and/or operated by the company, auditing bodies, etc.), as well as their staff or officials, specifically authorised in strict compliance with the Purposes, the PNCEE, and legal and/or government authorities. In general, the Company may share Personal Data with any third party whose work is required, to protect its own legitimate interests.
Any transfer of data to a third country outside the European Economic Area, when required, is done so in compliance with applicable regulations, and with the assurance of adequate data protection.
These terms and conditions are governed by French law. In case of a dispute where no amicable solution can be found, the case will be brought before the French courts in line with current legislation.
The Company is committed to guaranteeing and implementing suitable measures to maintain the security and confidentiality of Personal Data, and to ensure that the individuals authorised to process the data commit to complying with this security and confidentiality obligation. If the integrity, confidentiality, or security of the Personal Data is compromised, the Data Processing Manager will inform the individual immediately by any means necessary.
You can exercise any of the rights described in this section by sending an email to the following address: donneespersonnelles@enalia.com
Or by sending a letter to:
ENALIA
17 place des Reflets
92400 Courbevoie
Your request must include the following information: the full name and address of the person making the request, the subject of the request, the email address provided when the Personal Data was collected, and a copy of a piece of valid photo ID, so that we can verify that the person making the request has the right to do so.
The Company will contact the person making the request as soon as possible to provide full details of the measures taken.
7.1 Right to access, rectify, and erase:
You can view, update, amend, or request the deletion of any Personal Data we hold about you.
It should be specified that due to the constraints imposed by the CEE Scheme, no Personal Data pertaining to a CEE application can be deleted, even at the Beneficiary’s request. If necessary, the Beneficiary may be redirected to the government. This means that the personal information collected under the CEE Scheme is not covered by your data processing rights. By signing a sworn statement, the Beneficiary agrees to their information being collected, and cannot later ask the applying body or government to delete their Personal Data.
7.2 Right to Personal Data Portability
Natural Persons have the right to request that their Personal Data held by the Company be transferred to another Company.
7.3 Right to Restrict or Object to Personal Data Processing
Natural Persons have the right to request the restriction of or object to the processing of their Personal Data held by the Company, a request that the Company cannot refuse, unless it can prove legitimate, imperative reasons for doing so, which take precedence over the user’s rights and freedoms.
7.4 Rights in Relation to Automated Decision Making and Profiling
Natural Persons have the right not to be subjected to decisions based exclusively on automated processes if the decision can have legal repercussions for the individual in question, or have a significant similar effect. In cases where at least one automated process is necessary to carrying out a request of the provision of services, the Company may not then be able to deliver all or part of the Service. In this case, the Natural Person should understand that they have explicitly requested the cancellation of the Service.
8.1 Cookies
The Website may use cookies. A cookie is a small file (under 4 Kb), that the Website stores on the user’s hard drive, containing information about their browser habits (date and time that pages were loaded, browser and language used, pages viewed, frequency and duration of visits to the Website, number of visits, location, etc.). They are used primarily to facilitate visits to the Website.
Cookies installed on your computer can be deleted at any time, and you can use your browser settings to refuse new cookies and get a notification before a new cookie is installed.
For your information, users can find information about how to configure your browser to reject cookies at the following addresses:
- Chrome: https://support.google.com/accounts/answer/61416?hl=en
- Firefox: https://support.mozilla.org/en-US/kb/third-party-cookies-firefox-tracking-protection
- Safari: https://www.apple.com/legal/privacy/en-ww/
- Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
When refusing the installation of one or more cookies on your computer, you acknowledge that some Services may be inaccessible and will not be offered to you.
8.2 Cookies, Statistics, Settings
The cookies that may be installed on your computer when browsing the Website are cookies used exclusively to enable or facilitate electronic communications, or that are strictly essential to providing the expected Service (languages, identification, etc.), or statistical cookies or other cookies under the terms described herein.
When cookies require your consent before installation, a link to “learn more” can be found on the Website landing page, to obtain your consent in line with these purposes. This consent is deemed to be valid for a period of six (6) months. Following this period, the Website will again ask for your consent to save cookies on your hard drive.
This consent can be withdrawn at any time.
8.3 List of Installed Cookies
Statistics Cookies
Statistics cookies help website owners understand how users interact with their websites by collecting and sharing anonymised data
Marketing Cookies
Marketing cookies are used to track visitors across websites. The aim is to display ads that are relevant and of interest to individual users, and therefore more valuable for publishers and third party advertisers.
