Privacy Policy - Privacy Policy

Last updated and effective date: 05/25/2018

1. Importance of protecting your privacy

Thank you for trusting us with your personal information, we know how unpredictable the web can be and we appreciate your trust. This Privacy Policy tells you about our practices regarding the collection, use and sharing of information that you provide to us through our platform (the "Platform") and applies whenever you use our Platform. It also includes procedures to ensure that the processing of your information complies with applicable data protection and privacy laws. We thank you for your trust and we will continue to act accordingly.

2. Purposes and legal basis of data processing

Insofar as we obtain the consent of the data subject for the processing of personal data, the legal basis for the processing of personal data is given by Art. 6 (1) (a) of the EU General Data Protection Regulation (GDPR). In the context of the processing of personal data necessary for the performance of a contract to which the data subject is a party, the legal basis is given by Art. 6 (1) (b) GDPR. Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, the legal basis is given by Art. 6, para 1, point c of the GDPR. If the processing is necessary to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the primary interest, the legal basis for the processing is given by Art. 6 para 1 point f of the GDPR.

2.1. information you provide to us

By using our Platform, you are led to transmit information to us, some of which are likely to identify you ("Personal Data"). This is particularly the case when you fill in forms (for example the registration form), when you participate in games, competitions, job offers, studies or surveys, comments, when you contact us by telephone, email or any other means of communication.

In order to secure your registration, i.e. to prevent unauthorized registration by third parties, we will send you a confirmation e-mail after your initial registration using the double Opt-In method, in which we ask you to confirm your registration. The legal basis is your consent in accordance with Art. 6, para. 1, point a of the GDPR.

Personal information includes the following data:

2.2. information we collect when you use our platform

Whenever our platforms are accessed, we automatically collect data and information from the calling device and store this data and information in server log files.

3. Duration of data retention

We retain your personal data for as long as is necessary to provide the agreed service. The personal data you have stored in your account remains available to you for as long as the purpose for which it was collected and will be stored by us for that duration. Personal data will be deleted if you do so yourself.

Please note that we may retain certain information about you when required to do so by law or when we have a legitimate reason to do so. For example, if we believe that you have committed fraud or violated our Terms of Service and we want to prevent you from circumventing the rules applicable to our community.

4. Use of collected data

The data we collect allows us to provide, manage, protect and improve our services, develop new services, and protect both our users and ourselves. This data also allows us to provide you with tailored content, such as more relevant ads, information and search results.

5. Destination of the data collected

6. Data moderation

7. E-mails and promotional SMS

In accordance with applicable law and with your consent where required, we may use the data you provide on our Platform for marketing purposes (for example to (i) send you our newsletters, (ii) send you invitations to our events or any other communication that may be of interest to you).

You may withdraw your consent at any time by (i) unchecking the relevant box in your account, (ii) clicking on the unsubscribe link provided in each of our communications, or (iii) contacting us as described in Section 13 below.

8. Location of your data and data security

We store your Personal Data in the European Union and more specifically in France, on an ISO 9001 and ISO 20000-1 site.

However, it is possible that the data we collect when you use our Platform or our services may be transferred to other countries, some of which may have less protective legislation on the protection of personal data than that in force in the country where you reside. This is particularly the case for data transmitted to our subcontractors located outside the European Union, notably in the United States. We may use their services to respond to your requests, to moderate the photographs published on our Platform, to provide online payment tools, to provide us with commercial and advertising services or emailing, SMS or statistics services. In the event of such transfers, we ensure that the processing is carried out in accordance with this policy and that it is governed by the European Commission's standard contractual clauses, which ensure an adequate level of protection of the privacy and fundamental rights of individuals.

9. Rights of the person concerned

If you process personal data, you are affected under the terms of the GDPR and have the following rights against the controller:

9.1 Right to information

You can ask us to confirm whether your personal data will be processed by us.

If such processing has taken place, you may request the following information from us:

(1) the purposes for which personal data are processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom your personal data has been or is being disclosed;
(4) how long you are expected to keep your personal data or, if no specific information is available, the criteria for determining the retention period;
(5) the existence of a right to rectify or delete your personal data, a right to restrict processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data if the personal data is not collected from the data subject;
(8) the existence of an automated decision-making process, including profiling in accordance with Art. 22 (1) and (4) GDPR and at least in these cases useful information about the logic involved and the scope and intended effects of such processing for the data subject.
You are entitled to ask whether your personal data is transferred to a third country or international organization. In this context, you may request to be informed of the appropriate safeguards in accordance with Art. 46 GDPR in connection with the transfer. This right to information may be restricted insofar as it is likely to make the achievement of statistical purposes impossible or seriously hindered and the restriction is necessary for the achievement of statistical purposes.

9.2 Right of rectification

You have the right to rectify and/or complete your personal data vis-à-vis the data controller if they are incorrect or incomplete. The person in charge will proceed to the rectification without delay.
Your right to rectification may be restricted insofar as it is likely to make the achievement of statistical objectives impossible or seriously impede their achievement and the restriction is necessary for the achievement of statistical objectives.

9.3 Right to limit processing

You may request that the processing of your personal data be restricted, under the following conditions:

(1) if you challenge the accuracy of your personal data for a period of time that allows us to verify the accuracy of the personal data;
(2) if the processing is unlawful and you object to the deletion of the personal data and instead request that the use of the personal data be restricted;
(3) if we no longer need the personal data for processing purposes, but you need it to assert, exercise or defend legal claims, or
(4) if you have objected to the processing in accordance with Art. 21, para. 1 GDPR and it has not yet been established whether our justified reasons outweigh yours.
If the processing of your personal data has been restricted, such data may only be processed outside of storage with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on important public interest grounds of the Union or of a Member State.
If the restriction on processing has been limited in accordance with the above conditions, we will notify you before the restriction is lifted.
Your right to restrict may be limited insofar as it is likely to make the achievement of statistical objectives impossible or seriously impede them and the restriction is necessary for the achievement of statistical objectives.

9.4 Obligation to suppress

You may request us to delete your personal data immediately and we are obliged to delete such data immediately if any of the following reasons apply:

(1) Your personal data is no longer required for the purposes for which it was collected or processed.
(2) You revoke your consent, on which the processing was based according to the terms of Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and the processing has no other legal basis.
(3) You object to the processing in accordance with Art. 21, para. 1 of the GDPR and there are no compelling and legitimate reasons for the processing, or you object to the processing in accordance with Art. 21, para. 2 of the GDPR.
(4) Your personal data has been processed unlawfully.
(5) The deletion of your personal data is necessary to comply with a legal obligation under European Community law or the law of the Member States to which we are subject.
(6) Your personal data was collected in the context of the information society services provided in accordance with Art. 8, para. 1 of the GDPR.

Information to third parties.

If we have made your personal data public and are required to delete it in accordance with Art. 17, para. 1 GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the costs of implementation, to inform the data controllers processing the personal data that you, as the data subject, have requested the deletion of all links to such personal data or copies or replications of such personal data.

Exceptions.

The right of deletion does not exist as long as the processing is necessary

(1) to allow for the exercise of freedom of expression and information;
(2) to enable the performance of a legal obligation required for the processing under European Community or Member State law to which the controller is subject or the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health, in accordance with Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
(4) for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the law referred to in (a) is likely to make it impossible or seriously jeopardize the achievement of the objectives of such processing, or
(5) to assert, exercise or defend legal rights.

9.5 Right to data portability

You have the right to receive the personal data you have provided to us in a structured, common and machine-readable format. You also have the right to transfer that data to another controller without our involvement, provided that
(1) the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR
(2) the processing is carried out using automated methods.
By exercising this right, you also have the right to request that your personal data be transferred directly from one controller to another, insofar as this is technically possible. The rights and freedoms of other persons must not be affected. The right to transferability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of public authority conferred on us.

9.6 Right to object

You may exercise your right to object, for reasons arising from your particular situation, to the processing of your personal data at any time, pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling on the basis of these provisions.
We will no longer process your personal data unless we can demonstrate compelling reasons worthy of protection for the processing that outweigh your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims.
If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for advertising purposes; this also applies to profiling, insofar as it is associated with such direct marketing.
If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
You have the possibility to exercise your right to object to the use of information society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.
You also have the right to object to the processing of your personal data for statistical purposes in accordance with Article 89(1) GDPR on grounds arising from your particular situation. Your right to object may be restricted insofar as it is likely to make the achievement of statistical purposes impossible or seriously hindered and the restriction is necessary for the achievement of statistical purposes.

9.7 Right to revoke the data protection declaration of consent

You have the right to revoke your declaration of consent to data protection at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9.8 Automated decision in individual cases, including profiling

You have the right not to be subject to a decision based exclusively on automated processing, including profiling, which has legal effects against you or which affects you in a significant and similar way. This provision does not apply where the decision
(1) is necessary for the conclusion or performance of a contract between you and the responsible person, (2) is permissible under European Community law or the law of the Member State to which the responsible person is subject and where that law provides for appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
(3) is taken with your express consent.
However, such decisions may not be based on particular categories of personal data under the terms of Art. 9(1) GDPR, except in cases where Art. 9(2)(a) or (g) applies and appropriate measures have been taken to safeguard your rights and freedoms and your legitimate interests. With regard to the cases referred to in points (1) and (3), we will take appropriate measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain the intervention of a person by the responsible person, to denounce his own position and to challenge the decision.

9.9 Right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have a right of appeal to a supervisory authority, including in the Member State in which you reside, work or suspect an infringement, if you believe that the processing of your personal data is contrary to the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of judicial review under Article 78 of the GDPR.

10. Cookies and similar technologies

Our policy on cookies and similar technologies is available here .

11. Your password privacy

You are responsible for maintaining the confidentiality of the password that you have chosen to access your account on our Platform. You agree to keep this password secret and not to disclose it to anyone.

12. Links to other websites

Our Platform may contain links to the websites of our partners, third party companies or other members' shares. Please note that these websites have their own privacy policies and that we are not responsible for how these websites use the information collected when you click on these links. We encourage you to review the privacy policies of these sites before submitting your Personal Information to them.

13. Changes to our privacy policy

We may change this privacy policy from time to time. When necessary, we will notify you and/or ask for your consent. You should check this page periodically for any changes or updates to our privacy policy.

14. Data access and deletion procedures

You have all the features to access, modify, export or delete your data. Log in to your account under "Account settings".

15. Contact

If you have any questions about this privacy policy or any requests relating to your personal data, you can contact us by :

Before responding to your request, we may (i) verify your identity and (ii) ask you to provide additional information to fulfill your request.

16. Identity of the Data Controller and Responsibility for Processing

The responsible person (hereinafter referred to as "Infodustrie" or "we") within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection regulations is Infodustrie, SAS with a capital of 100 300 €, registered in the Evry Trade and Companies Register under number 790393359, whose registered office is located in Étampes - 6 ter, rue Van Loo - 91150 - France.