Privacy and Personal Data Protection Policy
We invite you to read this Data Protection Policy before using our website and/or our Application and more specifically the Services we offer you.
The Data Protection Policy is current as of 25 May 2018.
It is important to remember that in the context of the management and operation of the Site, in its capacity as data controller under the French Data Protection Act of 6 January 1978, as amended, ALOBEES may collect personal data from users (hereinafter the “Users”).
We want to respect and protect your privacy. To do so, we respect your privacy and take all necessary measures to ensure the confidentiality and security of Users’ personal data.
Therefore, the purpose of this Privacy and Data Protection Policy is to explain how the Company processes personal data in accordance with the principles set out in the General Data Protection Regulations (“GDPR”) which came into force on 25 May 2018.
That is why we insist that you should read this Data Protection Policy in order to be informed about how their personal data is processed and their rights.
You are reminded that this Privacy and Data Protection Policy is an integral part of the General Terms and Conditions of Sale (GTCS) and the General Terms and Conditions of Use (GTCU). Thus, all terms not defined herein are defined in the GTC and GTCU.
ALOBEES is a SAS with a capital of 9,012 Euros, whose registered office is located at 24 avenue du Repos, 94270 Le Kremlin Bicêtre, registered with the Créteil Trade and Companies Registry under number 824 811 186.
His telephone number is 01 84 23 74 96.
His e-mail address is: firstname.lastname@example.org
Data Protection Officer
We have appointed a personal data protection officer whose contact details are as follows: Erwan BAYNAUD, in his capacity as Co-founder of the ALOBEES Company.
Contact: sis 24 avenue du Repos, 94270 Le Kremlin Bicêtre.
E-mail address: email@example.com
The Data Protection Officer is responsible for advising, informing and monitoring compliance with data protection regulations.
Personal data (“Personal Data”) is information that directly or indirectly identifies a natural person. This information may consist of a surname, a first name, an e-mail address, a telephone number or a postal address.
The process of processing personal data consisting of identification, billing, information or improvement of the Services complies with the General Regulation on the Protection of Personal Data (RGPD).
Fair and transparent collection
In order to be as transparent as possible in our approach, we take care to inform our clients and prospects of each treatment that concerns them.
We collect the information that you voluntarily provide us, especially when you have to open an account on the registration form.
For the purposes of the services offered, we may need to collect the following data, by requesting your prior consent:
Identity: surname, first names, address, telephone number (landline or mobile), fax number, e-mail address, date of birth, internal processing code for customer identification;
Data relating to the means of payment: postal or bank details, transaction number, cheque number, credit card number;
Data relating to the business relationship: requests for documentation, trial requests, product purchased, service or subscription taken out, amount, frequency, purchase or order history, correspondence with the customer and after-sales service ;
Data relating to the payment of invoices: terms of payment, discounts granted, information relating to the credits subscribed (amount and duration, name of the lending organisation), receipts, unpaid invoices, reminders, balances, etc;
Contact data: messages sent to the site via contact forms, correspondence with customers.
The purpose principle
We process data for specific purposes: every data processing operation is carried out for a legitimate, specific and explicit purpose.
Proportionate data processing
All the processing we carry out requires appropriate and justified data collection. We therefore ensure that we only collect and use data that is adequate, relevant, limited and necessary for the purposes for which it is processed.
This data collection is regularly updated and inaccurate or incidental data can be deleted or corrected at any time.
How are your personal data protected?
ALOBEES takes into account the protection of your personal data and wishes to preserve your privacy as soon as you browse the website and/or the Application and extends to the provision of services.
We have therefore put in place an arsenal of appropriate measures to ensure that your rights are respected and properly exercised.
What personal data do we collect?
As we have previously indicated, the personal data that we collect and process consists of: your surname, first name, address, email address, telephone number, status (professional, private individual), service and/or civility, company, position, payment information, connection data (dates and times of connections, IP address) and navigation data, order history, preferences and commercial relations, information relating to the credits subscribed to, and your comments and messages via the contact form.
We would like to point out that at no time do we process personal data revealing racial or ethnic origin, or relating to political opinions, religious or philosophical beliefs or trade union membership. Similarly, we do not process genetic data, biometric data for the purpose of uniquely identifying a natural person, nor do we process data concerning the health, sex life or sexual orientation of a natural person.
When do we collect your personal data?
We collect the information that you voluntarily provide to us during your browsing of the Website and/or the Application, namely :
When you create or modify your customer account or user account in your dedicated space on our site or our application ;
When you place an order or take out a subscription ;
When you pay for an order or subscription ;
When you browse our site and/or Application, and view our products and use our services ;
When you subscribe to our newsletter ;
When you contact our customer service;
When you ask us for a demo;
When you participate in an event, trade show, conference or webinar that we organize.
Which personal data are mandatory?
The filling of certain boxes is mandatory and they will be indicated to you. This information is necessary to best meet your needs and allow us to fulfil our obligations to you and provide you with a service or allow you to purchase a product. If you do not wish to provide us with this information, called essential information, we will not be able to satisfy you.
We inform you that certain information, in particular technical information (IP address of your computer) or concerning the consultation of the site as well as its functionalities, is automatically collected because of your actions on our site by cookies.
What are the purposes of these data processing operations?
Most of the treatments we carry out are necessary for the execution of the services we offer you. These are treatments with the following purposes:
The management and follow-up of the commercial relationship: contracts, orders, subscriptions, management of your customer account, management of complaints ;
The sending of information and personalized newsletters on our products and services and their evolution, on our news;
The creation of a customer file.
Some processing is carried out in order to meet the legitimate interests of the ALOBEES company or by a third party in particular:
Conducting surveys, studies, satisfaction surveys and product tests ;
Improving your user experience on our site and to benefit from the features and services of the site;
The management of your participation in contests or promotional operations;
The development of trade statistics ;
The analysis and compilation of statistics relating to the consultation and use of the site (number of pages viewed, number of visits and activities) of our services (articles read) and advertisements displayed on the site, using Google Analytics ;
Sending information and personalised newsletters on our products and services and their evolution and on our news.
The characterization of customer profiles and the analysis of your purchasing preferences;
Finally, some processing operations meet legal and regulatory obligations, namely :
Invoicing and accounting management ;
The management of your rights as a data subject within the meaning of the applicable regulations on the protection of personal data (RGPD).
How do you manage your personal data?
In accordance with the provisions of Law No. 78-17 of 6 January 1978 and Regulation (EU) 2016/679 on data protection, you can contact us at any time to access your data in order to rectify them if they are no longer up to date; to delete them if you wish to remove them from the database; to limit them by requesting the suspension of processing, to oppose commercial communications or to ask us to retrieve them for the purpose of disposal.
You can contact us at the email address ” firstname.lastname@example.org ” or by post at this address ” 24 avenue du Repos, 94270 Le Kremlin Bicêtre “.
We offer you the possibility to personalize the sending of newsletters by indicating your preferences from any email we send you. Simply click on the unsubscribe link or contact customer service directly at email@example.com.
Regarding the management of transactional customer accounts, the Customer does not have the possibility to set up his account, so any request should be sent by e-mail to the following address: firstname.lastname@example.org.
The recipients of your personal data?
The personal data that we collect, as well as those that are collected subsequently, are intended for us in our capacity as data controller.
We therefore ensure that only authorised persons have access to this data.
The people who can access your data are :
The people working in the company ALOBEES ;
The partners of the company ALOBEES ;
The service providers we are used to working with to best meet your needs, manage your orders and subscriptions, as well as to carry out certain services we offer you (i.e. invoicing, payment, collection, customer satisfaction questionnaire, etc.).
Please note that some service providers may contact you directly from the contact information you have provided. We insist that all our service providers use your personal data only to administer the services we ask them to provide. In addition, they must act in accordance with the applicable regulations on the protection of personal data and ensure the confidentiality and security of your data.
Finally, your personal data may be communicated in application of a law, a regulation, a decision of a regulatory or judicial authority and finally by the company ALOBEES, in order to preserve its rights and interests.
Where are your personal data stored?
Your personal data is stored in databases and/or those of our service providers, which are located in the European Union.
What measures have been taken to secure your personal data?
All our technical and organisational measures that we deploy whether on the website and/or the Application are aimed at guaranteeing the security and confidentiality of your data so that it is not damaged, deleted or used by third parties without authorisation.
At all stages of the implementation of our project up to the proposal of our services to our Clients, we have endeavoured to ensure an optimal level of protection of the data processed.
Thus, we implement, on a daily basis, all appropriate measures to prevent, as far as possible, any alteration or loss of your data or any unauthorized access to it.
On the Website and on the Application, we manage your payment information (in accordance with the “PCI” Payment Card Industry rules), using methods that meet industry standards (“PCI DSS” / Payment Card Industry Data Security System).
Thus, we implement all measures that comply with the principles of protection from the design stage and default protection of the data processed.
When we use a service provider, we will only disclose personal data to them after obtaining a commitment and guarantees from the service provider about its ability to meet European security and confidentiality requirements.
We use sub-contractors in compliance with our legal and regulatory obligations and contracts that precisely define the conditions and methods of processing of personal data by the latter.
Finally, we regularly conduct audits of our own departments in order to verify the application of data security rules.
However, we insist on the fact that all users must verify and certify to the ALOBEES company that the personal data they disclose on the website and/or the Application are valid and up to date.
Indeed, each user is responsible for his or her personal data communicated to the Company.
Similarly, each user must undertake not to infringe on the privacy and protection of personal data of a third party.
Are personal data transferable outside the European Union?
ALOBEES carries out all processing of your Personal Data on the territory of the European Union (EU).
If, for specific services, we were to use subcontractors established outside the EU, we would require our subcontractors to provide the necessary guarantees for the supervision and security of these transfers, in accordance with the European provisions in force.
What are your rights regarding the processing of your personal data?
In accordance with the provisions of the French Data Protection Act dated 6 January 1978 as amended and the RGPD, Users have a right of access, rectification, deletion, limitation of data processing, data portability, as well as the right to object to all processing of their personal data.
All our processing, which protects your personal data, is fair and transparent, taking into account the particular circumstances and context in which your personal data is collected.
Your right of access
The Company undertakes to provide you, if you so request, with a copy of the personal data and information concerning you, namely :
All the purposes of the treatment;
The different categories of personal data concerned ;
Recipients or categories of recipients ;
The length of time the personal data will be kept and the criteria used to determine this length;
The existence of the right to ask the data controller for the correction or deletion of your personal data, the right to ask for a limitation of the processing of your personal data, the right to object to such processing ;
The right to lodge a complaint with a supervisory authority ;
Information relating to the source of the data when not collected directly from the data subjects ;
The existence of automated decision making, including profiling, and in the latter case, relevant information regarding the underlying logic, as well as the importance and intended consequences of such processing for data subjects.
Your right to have your data deleted
You can ask us, at any time and under certain conditions, to delete your personal data. However, this right to oblivion cannot be obtained for reasons of public interest, for archiving purposes or to comply with legal obligations governing the processing of our personal data.
For example, we may request the deletion of your personal data when :
the personal data are no longer necessary for the purposes for which they were collected or processed ;
you want to withdraw your previously given consent;
you object to the processing of your personal data where there is no overriding legitimate reason for the processing ;
the processing of personal data does not comply with the provisions of the applicable legislation and regulations.
The right to erasure of data is not a general right. Consequently, the Customer may only avail himself of this right if he can demonstrate the existence of a legitimate reason provided for in the applicable regulations.
We attach great importance to the data protection and privacy of our Clients. Therefore, every year we will proceed to an automatic deletion from our databases. Consequently, our Clients will be asked to create a new “company” on our website and/or Application in order to continue using our services.
It will be specified that the personal data collected, for the needs of certain services offered in conjunction with our Partners, will be deleted every six (6) months. Our Customers will be asked to create a new “company” at the end of the six (6) months in order to continue to use our services.
Your right to limit data processing
You may request the limitation of the processing of your personal data in the cases provided for by laws and regulations if you demonstrate that the data is inaccurate or is being used unlawfully.
Your right to object to data processing
You may object to the processing of your personal data by our Company. Indeed, you have the right to object at any time, for reasons relating to your particular situation, to the processing of your personal data on our platform.
As soon as you wish to exercise your right to object, we will ensure that we no longer process your personal data in the context of the processing in question unless we have legitimate and compelling reasons to continue such processing.
Note that you have the right to oppose commercial canvassing and profiling insofar as it is related to such canvassing.
Your right to portability of your data
Under certain conditions, you can request to receive all your personal data so that they can be transferred to another data controller without us being able to object.
We draw your attention to the fact that not all personal data resulting from processing are portable. The right to data portability only concerns automated processing to the exclusion of manual or paper processing.
Therefore, the data on which this right can be exercised are :
Only your personal data (i.e. anonymized personal data or data that does not concern you are excluded);
declarative personal data and personal operating data.
The right to portability may not infringe the rights and freedoms of third parties such as those protected by business secrecy.
Your right of rectification
You may at any time ask us to rectify the personal data you have communicated to us.
Your right to withdraw your consent
You can withdraw your personal data at any time. The processing of your personal data will cease, without prejudice to previous operations for which you have given your consent.
Your right to appeal
You may file a complaint with the CNIL on French territory, without prejudice to any other administrative or jurisdictional recourse.
How to exercise your rights
You may exercise your rights with the Company ALOBEES, by contacting us on the Site under the heading “Contact”, either by post at the following address: 24 avenue du Repos, 94270 Le Kremlin Bicêtre, France, or by e-mail at email@example.com.
All written requests must be made by post or e-mail. The request must be signed and accompanied by a photocopy of an identity document bearing your signature and specify the address to which the reply should be sent. We will reply within one month of receipt of the request.
Finally, we comply with the guidelines on the storage, deletion and disclosure of personal data after a death. In the absence of such directives, we will comply with the requests of heirs as set out in the applicable provisions of the French Data Protection Act (Loi Informatique et Libertés).
How are the bank details recorded?
To facilitate transactions and purchases, we may store your bank details so that you do not have to provide them with each order.
Bank details (card number, expiry date, name of the cardholder) are only stored if you give us your prior consent. We never store the visual cryptogram on the back of the bank card.
You can withdraw your consent to the storage of your bank data at any time. To do so, simply send an e-mail to the following address: firstname.lastname@example.org.
What is the shelf life?
The personal data of our Clients are kept for the time necessary to achieve the purpose of the processing.
Consequently, we undertake not to keep your data beyond the time necessary to provide the service.
Conservation periods shall be proportionate to the purposes for which they were collected.
The durations are variable and depend on the purpose for which they are collected, i.e. :
For an order of services, personal data is kept for the duration of the contractual relationship and this period can be extended for three years after the collection or the last commercial contact with the User with the latter’s express consent;
When a User participates in a promotional offer, personal data is kept for the duration of the promotional offer concerned (up to six months from the time of collection);
When a User makes a request to the ALOBEES Company, the personal data will be kept for as long as necessary to process the request;
When a User creates an account, his personal data is kept until he requests deletion of his account. Similarly, after a period of inactivity, within the limits of the legal requirements, personal data is deleted;
Each year, the Company undertakes to inform its Customers that it will proceed to the deletion of the personal data it has collected during the year. Also, each Client must remember that their client account will be updated each year and that they will have to create a “company” again on the website and/or the Application in order to take full advantage of the services offered by the Company.
Certain data collected for the purposes of services offered by the Company with its Partners will be erased every six (6) months.
Concerning cookies placed on the User’s computer, we keep personal data for the duration of a session (for cookies linked to the shopping cart) or for the entire period defined by the regulations applicable to identification cookies (13 months from collection) ;
The Company may retain certain data for 3 years after the end of the contractual relationship in order to fulfil its legal or regulatory obligations or to exercise its rights and/or for statistical or historical purposes.
In view of the regulations in force on the protection of personal data, these periods may be longer. Furthermore, personal data collected for several purposes will be kept until the longest retention or archiving period has elapsed.
At the end of the above-mentioned periods of time, personal data will be deleted or we will proceed to anonymize it.
How to contact us?
Users may contact the Company ALOBEES for any questions they may have about this Data Protection Policy by e-mail at the following address: email@example.com, or by post at the following address: 24 avenue du Repos, 94270 Le Kremlin Bicêtre.
You will be informed that any complaints relating to the processing of your personal data may also be addressed to the Commission Nationale de l’Informatique et des Libertés at the following address: 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex.
In particular, Users may contact the Company’s Data Protection Officer (“DPO”) by e-mail at the following address: firstname.lastname@example.org.
We may change this Privacy and Data Protection Policy at any time. We will inform our Users, by any means, of any changes made to this Policy.
As the Company is French and established in France, any dispute not resolved amicably will be subject to the jurisdiction of the French court, based on the Privacy and Personal Data Protection Policy in French.
Updated: June 2020