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Privacy Policy

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1. Purpose and Scope

This Privacy Policy explains how Oliverland Consulting collects, uses, retains, protects and, where applicable, transfers personal data through its website and professional activities.

It applies in particular to:

  • visitors to www.oliverlandconsulting.com;

  • individuals who contact Oliverland Consulting or request information;

  • individual clients using personal footwear-fit consultation services (B2C);

  • representatives, employees, participants and contacts of client or prospective organisations (B2B);

  • companies and footwear-industry professionals supported in their projects;

  • participants in training sessions, conferences, surveys, assessments or pilot projects.

Additional privacy notices may be provided for a particular form, consultation, organisational assessment or project. Where there is any inconsistency, the specific notice will clarify the processing applicable to the activity concerned.

2. Data Controller

The data controller is:

  • Oliverland Consulting – Wing Fa Chan, a sole trader operating under the business name Oliverland Consulting;

  • Legal status: sole trader under the French micro-enterprise regime;

  • Business address: ESPACE MERCURE, 11 rue Albert Einstein, 77420 Champs-sur-Marne, France;

  • SIRET number: 52076761700076;

  • Email: contact@oliverlandconsulting.com;

  • Website: www.oliverlandconsulting.com.

Oliverland Consulting has not appointed a Data Protection Officer at this time. Any questions concerning the protection of personal data may be sent to the email address above.

3. Personal Data That May Be Collected

3.1 Data Common to B2B and B2C Activities

Oliverland Consulting may collect:

  • identity, contact details and preferred language of communication;

  • the content of requests, exchanges and correspondence;

  • information relating to appointments, contracts, services and payments;

  • invoicing information and references required for administrative follow-up;

  • communication preferences and records of consent or objection;

  • technical data relating to the use of the website, where such data are collected.

3.2 Individual B2C Consultations

Depending on the information voluntarily provided, Oliverland Consulting may process:

  • age range, declared sex and, where relevant, professional activity;

  • the type of footwear concerned, its intended use, shoe size, fit difficulties and the selected consultation topic;

  • observations concerning length, width, internal volume and the wearer’s experience;

  • optional information concerning orthoses, therapeutic footwear, declared conditions or previous injuries, as well as pain, discomfort or loss of sensation;

  • responses to the preparation questionnaire and comments provided during or after the consultation.

Information concerning a condition, injury, pain, loss of sensation or orthopaedic device may constitute health data. Providing this information is optional, and it is used only to prepare and adapt non-clinical footwear-fit guidance.

Oliverland Consulting does not make medical diagnoses and does not request medical records, prescriptions, medical photographs or medical reports.

3.3 B2B Activities

For services provided to organisations and footwear-industry businesses, the data processed may include:

  • professional contact details, roles and information concerning the organisation;

  • requirements, specifications, proposals, contracts, deliverables and project communications;

  • information required to organise training sessions, conferences and meetings;

  • for certain footwear-fit assessments, shoe-size data, foot or footwear measurements, footwear type, user experience and participant feedback;

  • aggregated or anonymised data relating to footwear fit, conditions of use, reported incidents or organisational performance.

Oliverland Consulting prioritises anonymisation or aggregation where identifying individual participants is unnecessary. The arrangements governing the processing of employee or participant data are specified in the relevant contract and project-specific privacy notice.

4. Purposes and Legal Bases of Processing

Oliverland Consulting determines an appropriate legal basis for each processing purpose. Consent is used only where it constitutes the appropriate legal basis and may be withdrawn at any time.

The legal basis applicable to a particular processing activity depends on the nature of the service, the relationship with the person concerned and, where applicable, the information provided.

4.1 Responding to Enquiries and Preparing a Proposal

People concerned: professional contacts and individuals (B2B and B2C).

Legal basis: depending on the project, legitimate interests or the performance of a contract with the client organisation for non-sensitive personal data. Explicit consent is obtained for optional health-related information. The applicable legal basis is specified in the privacy notice for the relevant project.

4.2 Managing Appointments and Providing an Individual Consultation

People concerned: individual clients (B2C).

Legal basis: performance of a contract.

4.3 Using General Responses to the Preparation Questionnaire

People concerned: individual clients (B2C).

Legal basis: performance of a contract.

4.4 Using Optional Health-Related Information

People concerned: individual clients (B2C).

Legal basis: explicit consent in accordance with Article 6(1)(a) and Article 9(2)(a) of the GDPR.

4.5 Managing Contracts and Consulting, Training or Conference Engagements

People concerned: professional clients and contacts (B2B).

Legal basis: performance of a contract or legitimate interests in relation to professional contacts.

4.6 Conducting an Assessment Involving Employees or Participants

People concerned: employees or participants involved in a project with a client organisation (B2B).

Legal basis: the legal basis specified in the contract with the client organisation and in the project-specific privacy notice.

4.7 Managing Payments, Invoices and Accounting Obligations

People concerned: professional and individual clients (B2B and B2C).

Legal basis: performance of a contract and compliance with legal obligations.

4.8 Ensuring the Security of the Website, Accounts and Systems

People concerned: users, clients and professional or individual contacts (B2B and B2C).

Legal basis: Oliverland Consulting’s legitimate interest in protecting its website, accounts, systems and the data processed through them.

4.9 Contacting Someone for a Satisfaction Survey

People concerned: professional or individual clients and participants (B2B and B2C).

Legal basis: consent.

4.10 Contacting Someone About a Future Trial or Project

People concerned: professional or individual contacts, clients or participants (B2B and B2C).

Legal basis: separate consent.

4.11 Sending Relevant Professional Communications

People concerned: professional contacts (B2B).

Legal basis: legitimate interests, with the right to object to receiving these communications at any time.

4.12 Placing Non-Essential Cookies

People concerned: website visitors.

Legal basis: consent obtained through the website’s cookie-management tool.

5. Mandatory and Optional Information

Information identified as mandatory is required to respond to an enquiry, arrange an appointment, provide a service, process a payment or comply with administrative obligations. Failure to provide this information may prevent Oliverland Consulting from providing the requested service.

Questions concerning orthoses, declared conditions, previous injuries, pain or discomfort are optional. Choosing not to answer them does not prevent the consultation from taking place, although it may limit the personalisation of the footwear-fit explanations provided.

Choices concerning satisfaction surveys and future projects are also optional and have no effect on the service booked.

6. Data Concerning B2B Employees or Participants

For each engagement involving employees, personnel, wearers of occupational footwear or other participants, the respective roles and responsibilities are determined before data are collected:

  • the client organisation may act as the data controller and Oliverland Consulting as the data processor;

  • Oliverland Consulting may act as an independent data controller for processing activities that it determines itself;

  • the parties may act as joint controllers where the purposes and essential means of processing are jointly determined.

Where Oliverland Consulting acts exclusively on behalf of and in accordance with the instructions of the client organisation, a data-processing agreement compliant with Article 28 of the GDPR is concluded.

Where the purposes and essential means of processing are jointly determined, the parties’ respective responsibilities are defined in an arrangement compliant with Article 26 of the GDPR.

Before any data are collected, employees or participants receive a specific privacy notice. This notice explains the data collected, the purpose and legal basis of processing, the recipients, the retention period, the rights of individuals and the nature of the results communicated to the client organisation.

Results are presented in aggregated or anonymised form when individual identification is unnecessary.

7. Recipients and Service Providers

Depending on their responsibilities and need for access, personal data may be accessible to:

  • Wing Fa Chan, acting on behalf of Oliverland Consulting;

  • technical service providers used for the website, email, forms, appointment scheduling, videoconferencing and data storage;

  • the payment service provider, which processes payment-card data according to its own terms and security measures;

  • the accountant, professional advisers or legally authorised public authorities, where necessary;

  • the client organisation, only in accordance with its role, the relevant contract and the information provided to participants in a B2B project.

The service providers currently used include:

  • Google Workspace, including Gmail, Google Forms and Google Calendar, for email, forms and appointment management;

  • Stripe for payments;

  • Wix for hosting and operating the website;

  • Zoom and Google Meet for online consultations and meetings.

8. Transfers Outside the European Economic Area

Some service providers may process personal data from countries outside the European Economic Area. Such processing may involve Wix, Google, Stripe or Zoom and their respective subprocessors.

Depending on the destination and service provider concerned, these transfers are based on an adequacy decision issued by the European Commission, Standard Contractual Clauses or another safeguard recognised under the GDPR.

The relevant service providers maintain their own lists of subprocessors and information concerning the safeguards applied. Further information may be requested from Oliverland Consulting at contact@oliverlandconsulting.com.

9. Data-Retention Periods

Personal data are retained for a period proportionate to their purpose. They are subsequently deleted or archived with restricted access where a legal obligation or evidentiary requirement justifies continued retention.

The applicable retention periods are set out below.

9.1 Enquiries That Do Not Result in a Contractual Relationship

Data relating to enquiries that do not result in a contractual relationship are retained for three years from the last contact initiated by the person concerned.

9.2 Client Data Used for the Commercial Relationship

Data are retained throughout the commercial relationship and subsequently for three years for commercial management and follow-up purposes. A separate evidentiary archive may be maintained where necessary.

9.3 Contracts and Commercial Correspondence

Contracts and commercial correspondence are retained for five years from the end of the contractual relationship, unless a different period is required under the applicable legislation.

9.4 Invoices and Accounting Documents

Invoices and other accounting documents are retained for ten years in accordance with applicable legal and accounting obligations.

9.5 B2C Preparation Questionnaire — General Data

General responses to the preparation questionnaire are retained for twelve months following the consultation, unless an erasure request is received or a dispute requires their continued retention.

9.6 B2C Preparation Questionnaire — Optional Health-Related Information

Optional information concerning orthoses, declared conditions, pain or discomfort is retained for twelve months from the date of the consultation or the last exchange directly related to it. It is subsequently deleted or anonymised.

9.7 Identifying Data Collected as Part of a B2B Project

Identifying data collected as part of a B2B project are retained for the duration of the project and subsequently for the period specified in the relevant contract. They are anonymised or deleted as soon as identifying individuals is no longer necessary.

9.8 Consent to Be Contacted About a Survey or Future Project

Information relating to this consent is retained until consent is withdrawn or for three years from the last contact.

9.9 Evidence of Consent or Objection

Evidence of consent is retained for as long as necessary to demonstrate that the individual’s choice has been respected.

Where an individual objects to receiving certain communications, the information required to respect that objection is retained for at least three years.

9.10 Cookie Choices

Choices concerning cookies are generally retained for six months, subject to the retention period actually configured in the cookie-management tool used on the website.

10. Security

Oliverland Consulting implements technical and organisational measures proportionate to the relevant risks. These include restricting access, protecting accounts using appropriate authentication methods, keeping equipment and services up to date, creating backups where necessary, and implementing data-retention and deletion procedures.

No internet transmission or storage system can guarantee absolute security. Any incidents are documented, assessed and managed in accordance with applicable obligations.

11. Cookies and Similar Technologies

The website may use cookies that are strictly necessary for its operation. Depending on the selected settings, it may also use audience-measurement tools or other technologies.

Non-essential cookies are placed only after consent has been obtained where such consent is required.

Visitors must be able to accept or refuse non-essential cookies with equal ease and may change their choices at any time through the website’s cookie-management tool. The list of cookies used, their purposes, providers and retention periods is available through that tool.

12. Individual Rights

Depending on the legal basis and the conditions established by the GDPR, individuals may request:

  • access to their personal data;

  • correction of inaccurate or incomplete data;

  • erasure of their data;

  • restriction of processing;

  • data portability where this right applies;

  • the right to object to processing based on legitimate interests or to direct marketing;

  • withdrawal of consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.

Requests may be sent to contact@oliverlandconsulting.com. Oliverland Consulting will respond as soon as reasonably possible and, in principle, within one month.

Proof of identity may be requested only where there is reasonable doubt concerning the identity of the person making the request.

Individuals may also lodge a complaint with the French Data Protection Authority, the Commission nationale de l’informatique et des libertés (CNIL): www.cnil.fr.

13. Adults Only

Individual B2C consultations are exclusively intended for people aged 18 or over. Oliverland Consulting does not accept bookings or preparation questionnaires concerning minors.

This restriction applies only to individual B2C consultations. It does not prevent Oliverland Consulting from providing collective educational activities for minors under the responsibility and supervision of the host organisation.

Unless a specific procedure has been established in advance, no personal data concerning participating minors are collected in this context.

14. Automated Decision-Making

Oliverland Consulting does not make decisions that produce legal effects or similarly significantly affect an individual solely on the basis of automated processing.

Footwear-fit assessment tools provide information to support analysis and do not replace human judgement.

15. Personal Data Breaches

Any personal data breach is documented and assessed.

Where a breach is likely to result in a risk to individuals’ rights and freedoms, it is reported to the CNIL in accordance with the conditions and time limits established by the GDPR.

Where the risk is high, the individuals concerned are also informed as soon as reasonably possible, unless an exception under the applicable legislation applies.

16. Updates to This Policy

Oliverland Consulting may amend this Privacy Policy to reflect changes in its activities, tools or legal obligations.

The date of the latest update is shown at the beginning of the policy. Where a material change is made, appropriate information will be provided to the individuals concerned.

17. Contact

For any question or request concerning the protection of personal data:

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