Briefing Note on Data Confidentiality in the context of GDPR



ATR undertakes, within the framework of its activities, to ensure the protection, confidentiality and security of all your personal data while respecting your privacy.

This information note is intended to inform you about the measures implemented to process your personal data. This note also informs you of the personal data protection rights that you can exercise.

ATR is committed to protecting the data of individuals in accordance with the European Data Protection Regulation 2016/679 of 27 April 2016 (GDPR) and all applicable national laws and regulations on the protection of personal data.

This information note is applicable to the following data subjects: customers; suppliers.

Processing of your Personal Data

A. What is personal data?
Personal data is any information relating to an identified or identifiable natural person. An “identifiable natural person” is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an on-line identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.
The personal data listed below are sensitive data:

• Information that reveals the alleged racial or ethnic origin;
• Political opinions;
• Religious or philosophical beliefs;
• Trade union membership;
• Genetic data;
• Biometric data for the purpose of uniquely identifying a natural person;
• Health data;
• Data concerning the sexual life or sexual orientation of a natural person;
• Data relating to criminal convictions or offences;
• The Unique National Identification Number (NIR for France).

B. What will your data be used for (purpose of processing)?

Your personal data is used in the context of processing for the management of the Into Life website and customer service.

C. What data is collected and how?
Within the framework of the defined processing operation, the following data are collected:

• Identity data (title, surname, first name, user name)
• Professional details (company, country, job position, email and phone)

The data used are from:

• Collected during your navigation on the ATR Into Life website and whose collection you have consented to (cookies) through the contact form and newsletter registration

The collection of your data is necessary to carry out the defined processing.

Certain data are optional within the framework of this processing. These data are the following: professional information (company name).

Failure to provide the data could have some consequences:

• Impossibility to access certain functionalities of tools, services.

D. On what legal basis is the processing of your personal data carried out?

ATR is based on an appropriate legal basis, legitimizing the processing operation. This legal basis is as follows:

• Your consent for one or more defined purposes.

E. For how long does ATR keep your Data?

ATR processes and keeps your personal data for as long as necessary to achieve the purpose of the processing, in accordance with our contractual and regulatory obligations.

In the case of data collected via the contact form, the data is deleted from the website after 6 months. Regarding the newsletter, the user can unsubscribe at any time.

Recipients of your data

A. Who receives your personal data?

Within ATR, your data are processed by the following authorized persons:
– ATR staff in the following directorates and departments: Communication Directorate.

B. Transferring your data:

Are your personal data transferred to a third country
outside the European Union? ATR processes your data within the European Union. There are no data transfers outside the European Union.

Your rights regarding the processing of your data

A. What are your rights and how to exercise them?

You may at any time exercise your rights related to the protection of your personal data:

• Right of access to the details of the information held by ATR concerning you.
• Right to rectify your data: you may ask ATR to modify any inaccurate information concerning you.
• Right of oblivion: you have the right to request the deletion of your data, in particular when the data is no longer necessary for processing.
• Right to limit the processing of your data: you have the right to freeze the use of your data by ATR, i.e. ATR will no longer carry out the intended processing of your data but will
keep them. For example, if you contest the accuracy of the data used or if you object to the processing, ATR will verify and examine your request for a certain period of time. During this period, you have the possibility to ask ATR to limit the use of your data.
• Right to the portability of your data: you have the right to receive your data in a structured, commonly used and computer-readable format or to request the transmission of your data to another data controller.
• Right to object to the processing of your data: you may at any time object to the processing of your data for reasons relating to your particular situation (justifications to be sent to ATR).
• Right of withdrawal of consent: you may request that the processing of your personal data be stopped for reasons relating to your particular situation.

NOTA: The exercise of rights may be limited by regulation: illegitimate reasons, protection of the rights of another natural or legal person, etc. ATR reserves the right to assess your request in accordance with the regulations.

B. How to contact ATR regarding your personal data?

You may contact ATR to exercise your rights or for any question concerning the protection of personal data.
In order to exercise your rights, your request must include proof of your identity by any means. You may therefore be asked to provide a photocopy of an identity document bearing your signature.

ATR reserves the right to assess your request in accordance with the regulations.

You can contact the Data Protection Representative (ATR) at the following email address: or send a postal mail to the following address: ATR Service RH For the attention of Data Protection Representative 1 allée Pierre Nadot 31712 Blagnac

C. How can you contact the supervisory authorities?

If you consider, after contacting us and exchanging information, that your Computer Rights and Freedoms are not respected or that the treatment defined does not comply with the rules of data protection, you can make a complaint online to the CNIL or by post.

France :
Commission Nationale de l’Informatique et des Libertés (CNIL). 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 Tél : 01 53 73 22 22

Italy :
Garante per la Protezione dei Dati Personali (GPDP). Piazza Venezia n. 11 – 00187 Roma Tél : (+39) 06.696771