Data Policy

Last updated: 15th April 2026

This Privacy Policy describes how Kahler Communication Europe (“KCE”, “we”, “us”, or “our”), a company established in France at Le Moulin du Béchet – 27120 Croisy-sur Eure which can be contacted at info@processcommunication.com, collects, uses, stores, and protects the personal data of visitors and users of the website processcommunicationmodel.com.

This policy applies to all individuals located in the European Economic Area (EEA) who interact with our Website. If you are located outside the EEA, your data is processed by Kahler Communications (“KCI”) Inc. 7619 Hwy 70 S #210555 Nashville, Tennessee 37221, our US-based partner which operates the Website on our behalf.

It has been established in accordance with the following provisions:
The Data Protection Act of 6 January 1978;
– The European General Data Protection Regulation (known as the “GDPR”) of 23 May 2018;
– The Law transposing the European Regulation on the Protection of Personal Data (GDPR) of 20 June 2018;
– Recommendations from the CNIL.

The Data Controller reserves the right to modify this Data Policy in order to comply with the obligations provided for by privacy protection legislation or in order to adapt it to its practices.

For any questions concerning the processing of their Personal Data and the exercise of their rights, Users may contact the dedicated service by specifying in the subject of their request by email to the following address: gdpr@kahlercommunications.com

By browsing this Website, the User must, on several occasions, provide some of his personal data.

By providing his/her data, the User therefore consents to the collection and processing of the personal data provided by the Data Controller for the exclusive purposes as detailed in Article 3 of the Policy. This consent, as well as other reasons, serve as the legal basis for the processing of the data collected.

The Data Controller collects and processes data that is strictly necessary for the purposes for which they are processed. The Data Controller undertakes to the Users not to process the data for purposes other than those mentioned below. If the Data Controller were to offer a new service on the Website, or any other feature of the Website, requiring the collection and processing of data, the Data Controller undertakes to obtain the Users’ consent once again before offering the new service in question.

Whenever the Website processes personal data, the Data Controller takes all reasonable steps to ensure the accuracy and relevance of the personal data to the purposes for which it is processed.

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data. Users under the age of fifteen (15) are invited to seek the consent of a legal representative – required by the Data Controller – in order for their personal data to be collected and to be able to use the services of the Website.

The Data Controller may not be held liable in the event that any user provides personal data concerning a minor under the age of fifteen (15).

We collect Users’ data only for the following processing purposes:

When you visit our Website, we automatically collect technical data through analytics tools suche as Google Analytics, including: IP address, Browser type and version, Pages visited, time spent, referring URLs, Device type and operating system.

Data is processed for the purposes of Analysing Website traffic to improve user experience.

The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller, in particular to offer Users a smooth and improved browsing experience.

When you register for a PCM training, we collect the following personal data: First name and last name, Date of birth, Company name, Email address, Phone number, Postal address, Name of the person who referred you to PCM (if applicable).

Personal data is processed for the purposes of:
– Managing your registration and administrative file for training participation
– Communicating with you regarding your enrolment, schedule, or training content
– Issuing invoices and managing payment records

The legal basis is the User’s consent for their PCM training’s registration.

When you submit a contact enquiry, we collect: First name and last name, Email address, Phone number, Country, the content of your message.

Personal data is processed for the purposes of:
– Responding to your contact enquiries.
– Giving you informations about PCM Trainings,
– Sending you followup commercial communications,
The legal basis is the User’s consent to be contacted.

The Data Controller does not exceed the legal data retention periods and Users’ data is kept only for the time necessary to process the purposes for which they were collected.

The retention periods are as follows:
– Analytics data (3.1) : no longer than 26 months after your visit.
– PCM Registration data (3.2): for the duration of your participation in PCM training sessions and for 5 years thereafter, in accordance with applicable French accounting and contractual obligations.
– Contact form data (3.3): for the time necessary to respond to your enquiry and for a period of 3 years from your last consented interaction with us (e.g. last click on a commercial email, last contact with our team).

The Data Controller may retain certain personal data in order to fulfil its legal or regulatory obligations, to allow the exercise of users’ rights, or for statistical purposes. At the end of the retention period of personal data, it will be deleted or anonymized.

The Controller rely on certain third-party services to provide certain functionalities. The latter have limited access to the Users’ data, in the context of the performance of these services and have a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.

The host has access to the data within the limits of its respective attributions, for the hosting of the Website. It has limited access to Users’ data in the context of the performance of these services and has a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.

The data collected via the Website is intended exclusively for the following recipients.

Users’ statistical data (cookies) are used to improve the user experience and to improve the functionalities of the Website. The user is invited to refer to the Website’s cookie policy.

The data may also be transmitted by the Data Controller to third parties and competent authorities to meet legal, judicial, tax or regulatory obligations. The Data Controller guarantees Users that no transfer of personal data will be carried out to an unauthorized third party, without the prior, voluntary, informed, express and written consent of the User.

Your personal data may be transferred to and processed in the United States, specifically by Zoho Corporation B.V and KCI. The United States does not benefit from an adequacy decision from the European Commission under GDPR.

These transfers are governed by Standard Contractual Clauses (SCCs) as approved by the European Commission under Article 46 of GDPR, incorporated into our agreements with Zoho Corporation B.V and KCI.

The Data Controller has taken all the necessary precautions, in view of the state of the art in this area, to protect your information in a secure environment in order to prevent any destruction, loss, alteration, dissemination or unauthorized access. No matter how hard you try, no method of transmission over the Internet and no method of electronic storage is completely secure. As a result, we cannot guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether they are at national or European level.

In the event that the integrity and confidentiality of your data are compromised, the data controller undertakes to comply with the procedures put in place under the Data Protection Act of 6 January 1978 and the European Data Protection Regulation (“GDPR”).

The Data Controller does not resell or outsource Users’ data.

With regard to the legal provisions of the Data Protection Act of 6 January 1978 and the European General Data Protection Regulation (“GDPR”), Users of the Website have the following rights:

The User may review, update, modify or request the deletion of data concerning him/her, by sending an email to the person responsible for the processing of personal data, specifying the subject of his/her request and using the contact email address: gdpr@kahlercommunications.com in accordance with Articles 15, 16, 17 and 19 of the GDPR

The User has the right to request the portability of his/her personal data, held by the Website or by the Data Controller, to another site, by making a request for the portability of his/her personal data to the Data Controller, by sending an email to the address provided above in accordance with Article 20 of the GDPR.

The User has the right to request the limitation or to oppose the processing of their data by the Data Controller, without the Data Controller being able to refuse, unless it can demonstrate the existence of legitimate and compelling reasons, which may prevail over the interests and rights and freedoms of the User.

The User must make a request to the Data Controller to limit the processing of his/her personal data, by sending an email to the address provided above in accordance with Articles 18 and 21 of the GDPR.

In accordance with the provisions of Regulation 2016/679, the User has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him/her, or similarly significantly affects him/her.

The User is reminded that he can organize what should happen to his data collected and processed if he dies, in accordance with Law No. 2016-1321 of October 7, 2016.

To exercise the rights of access, rectification, erasure, limitation, withdrawal of consent, portability and opposition referred to above, the User simply needs to send his request:
– By email at the following address: gdpr@kahlercommunications.com
– By indicating your surname, first name, address and attaching proof of identity.

The data controller is Mrs. Céline PELLETIER, and can be contacted by email at
celine.pelletier@kahlercommunications.com

Requests will be processed within one month, unless there is a compelling reason put forward and justified by the Data Controller justifying an extension of the deadline.

The User may also contact KAHLER’s Data Protection Officer (DPO) at the following address: Sarah Ben Hammou sarah.ben@emerya-avocats.com.

If the Data Controller does not comply with the User’s request, the User is entitled to refer the matter to the CNIL (Commission Nationale de l’Informatique et des Libertés, https://www.cnil.fr) in order to assert his rights.

The Data Controller reserves the right to modify this Policy at any time. If a change is made to this Policy, the new version will be published immediately on the website, and the User’s consent will be obtained again. If the User does not agree with the terms of the revised Policy, they may cease using the website’s Services and stop browsing the website.

By browsing this Website, the User certifies that he/she has read and understood this privacy policy and accepts its conditions, particularly with regard to the collection and processing of his/her personal data, as well as the use of “cookie” files.

This Data Protection Policy is governed by French law and is – in the event of a dispute – subject to the exclusive jurisdiction of the competent courts of common law, subject to a specific attribution of jurisdiction resulting from a particular legal or regulatory text.