This draft for France has not yet been reviewed by a lawyer and is not in force. Passages marked TO CONFIRM: … are to be clarified by the operator or by the lawyer.
This page provides the information required by Article 14 GDPR (in French), which applies where personal data have not been obtained from the data subject.
The company database contains information on businesses established in France. Some of them are sole traders (entrepreneurs individuels): their details relate to a natural person and are personal data. The same applies to a named email address. A business’s general contact details, such as a generic email address or the switchboard number, are not in themselves personal data (Entreprendre Service Public, in French). Public availability does not, however, permit unrestricted reuse.
Martin Adamec, a sole trader established in the Czech Republic, is the controller for the company database. Contact details are given at the bottom of the page.
Depending on the source and the agreed export: company or trading name, legal form, SIREN, SIRET, intra-EU VAT number (only if published by the business), business address, postcode, municipality, département and region, industry and NAF code, published business phone number, published business email address and website. A sole trader’s business address may be their home address. The database has no column for names of executives (a sole trader’s business name may still be their own name), and we process no special categories of data under Article 9 GDPR.
The data come from publicly accessible sources:
Units that have exercised their right to object with INSEE and are partially disseminated in the Sirene database (status “P”, see the INSEE press release of 21 March 2023, in French) are excluded from matching. The sources and methodology page gives details; on request, we will tell you the origin of your record.
The purpose is to structure information on businesses and to provide agreed exports to business customers for market analysis, sales territory planning, maintaining customer files, postal mailings and business-to-business prospecting. An export is neither consent to marketing nor proof of reachability. According to the CNIL (in French), electronic prospecting of professionals is only possible if the subject of the approach relates to their profession and the people have been informed and can object; we point this out to our customers.
For personal data, the intended legal basis is legitimate interests (Article 6(1)(f) GDPR, in French): the interest of the publisher and its customers in reliable information on businesses and in contacting them in a business context. Safeguards are the restriction to business data, no matching of partially disseminated units with Sirene, no reconstructed email addresses, the exclusion of addresses shared by many businesses, rectification, objection and an objection list that prevents records from being added again. TO CONFIRM: balancing of interests, in particular for sole traders, in light of the sources, fields and uses. TO CONFIRM: handling of the objection to prospecting recorded in the national business register (Article R.123-320 of the French Commercial Code, field “opposition_diffusion_commerciale” of the Recherche d’entreprises API); this flag is not yet included in exports.
Recipients may be business customers receiving the agreed fields, necessary hosting and IT providers, professional advisers and competent authorities. Customers are responsible for their own processing and have their own information and data subject obligations.
A personal-data export or access outside the European Economic Area requires a case-by-case assessment and a transfer mechanism under Chapter V GDPR. A purchase alone does not justify disclosure.
Records are kept only as long as necessary and lawful, taking into account how current the sources are, changes, objections and legal obligations. Outdated details are corrected or removed. Minimal identifiers are kept on an objection list so that a record is not added again after an objection. TO CONFIRM: storage period for records and for the objection list.
You can request access to your data, including their origin, rectification, erasure, restriction of processing and, where applicable, data portability (Articles 15 to 20 GDPR). You can object, on grounds relating to your particular situation, to processing based on legitimate interests, and at any time, without giving reasons, to the use of your data for prospecting (Article 21 GDPR, in French); that use then ends. Use the objection form or write to info@basedecontacts.fr. We generally reply within one month.
You can lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), which offers an online complaints service, with the Czech data protection authority (uoou.gov.cz) or with any other competent supervisory authority (Article 77 GDPR, in French).
Where Article 14 GDPR applies, data subjects must be informed individually and in good time: within a reasonable period not exceeding one month, at the latest at the first communication if the data are used to contact them, or when the data are first disclosed to another recipient. This page supplements that obligation and does not automatically replace individual information. TO CONFIRM: whether the exemption under Article 14(5) GDPR can be relied on for certain records, and how individual information is otherwise provided.
This information is updated when sources, purposes or processing change significantly. The version date is shown at the top of the page.
Martin Adamec
Mírová 1541, 516 01 Rychnov nad Kněžnou, Czech Republic
IČO: 19552319
info@basedecontacts.fr
Legal notice · Terms of sale · Privacy policy · Objection · Sources and methodology
