Personal data protection charter

1. Who are we ?

Data Controller

1.1 The present Charter allows you to become aware of the commitments in terms of personal data protection of Smart Tribune (JCS Web,simplified joint stock company, located at 24 rue du prés Saint gervais, 93500 PANTIN), who is acting as data controller for any processing of personal data set forth in the present document.

1.2 Smart Tribune is concerned about the protection, respect and confidentiality of your personal data, and has set up an email box rgpd@smart-tribune.com for any request you may have on this subject.

 

 

2. The personal data that we process

2.1 In the context of processing of personal data whose purposes are set forth below, Smart Tribune collects and processes the following data:
– Civility data, contact details,
– Professional data as function, cv data,
– Logins

3. Purposes and legal basis of our data processing

 

Purposes of our processing

3.1 Smart Tribune processes data for the following purposes:
Customer relationship management
Lead and media relationship management
Management of extranet
Follow-up of tenders
Management of visitors on site (cookies)
Management of customers issues
Management at the administration interface logs
Management of webinars
Follow up of the commercial prospection
Management and follow-up of customer invoicing
Recruitment follow-up

 

The legal bases of our data processing

3.2 We implements data processing only if at least one of the following conditions is met: 

your consent to the processing operations has been obtained. 

the existence of Smart Tribune legitimate interest, or that of a third party, which justifies that we  implement this processing of personal data. 

the execution of a contract which is binding us to a you requires that we implement this processing of personal data.

statutory and regulatory obligations which require this processing of personal data.

 

The legitimate interests pursued

3.3 The legitimate interests which are pursued by Smart Tribune may consist in particular of commercial prospection.

 

 

4. Who are the recipients of your data?

4.1 The personal data we collect, and those we obtained subsequently, are intended for us in our capacity as controller.

4.2 We ensure that only authorised persons have access to this data. Our service providers can be recipients of this data to perform the services we entrust to them. Some personal data may be sent to third parties or to legally authorised authorities in order to meet our legal, regulatory or contractual obligations.

 

5. Transfer of your data

5.1 We transfer your personal data to partners in the following countries:

  • United States

5.2 We transfer your personal data to the followings company (when you are concerned):

  • Hubspot (service provider CRM)
  • Google (google analytics)

5.3 Each of these transfers is governed by legal instruments that comply with the applicable legal framework. The transfers are made to companies whose head office is registred in United Stated and who have joined the Privacy shield.

6. The duration for which we keep your personal data

6.1 The periods for which we keep your personal data are proportionate to the purposes for which your data were collected. Our data storage policy is organised as follows:

  • For the clients and providers : duration of the contract, increased by legal prescriptions ( 5 years)
  • Accounting documents : 10 years
  • For the leads and media : 3 years as from the last contact
  • Cookies : 13 months as from the consent
  • Newsletters : until the unsubscribing
  • Webinars : for the duration of the organization of the webinar + 3 years
  • Duration required to meet the legal or regulatory obligations to which Smart Tribune would be subject
  • For a candidate : 2 years after the refusal of application

7. What are you rights ?

 

How to exercise your rights

7.1 You can exercise your rights by e-mail at the following address: rgpd@smart-tribune.com or by post at the following address: 24 rue du prés Saint gervais 93500 PANTIN with a copy of your identity document.

7.2 To do so, you must clearly indicate your surname and given name, address to which you wish the reply to be sent and attach a photocopy of an identity document bearing your signature.

7.3 As a matter of principle, you can exercise all your rights free of charge. However, with respect to the right of access, you may be required to pay a reasonable fee based on administrative costs for any copy of the data you request.

7.4 With regard to the right of information, Smart Tribune will not be obliged to act on it when you already have the information you are requesting.

7.5 Smart Tribune will inform you if it is unable to respond to your requests. 

7.6 Smart Tribune would like to inform you that failure to provide information or modify your data may have consequences for the processing of certain requests in the context of the execution of contractual relations and that your request in respect of the exercise of your rights will be kept for follow-up purposes.

All your rights are set forth below:

 

Your right of information

7.7 You acknowledge that this privacy policy provides you with information about the purposes, legal framework, interests, recipients or categories of recipients with whom your personal data were shared, and the possibility of a data transfer to a third country or international organisation.

7.8 In addition to this information and with the aim of ensuring fair and transparent processing of your data, you further acknowledge that you have received additional information concerning:

  • the period for which your personal data will be kept;
  • the existence of the rights which are granted to you and the terms and conditions to exercise them.

7.9 If we decide to process data for purposes other than those indicated, all information relating to those new purposes will be communicated to you.

 

Your right of access to and rectification of your data

7.10 You have the right to access and rectify your personal data, which you can exercise at the following address: rgpd@smart-tribune.com or by letter at : 24 rue du prés Saint gervais 93500 PANTIN.

7.11 In this respect, you have the confirmation as to whether or not your personal data are being processed and where this is the case, access to your data and the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient as well as the international organisations to whom the personal data have been or will be disclosed, in particular recipients in third countries;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subjects, any available information s to their source;
the existence of automated decision-making, including profiling, and in this case, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

7.12 You can ask us to, as the case may be, rectify or complete your personal data that are inaccurate, incomplete, equivocal or expired.

 

Your right to erasure of your data

7.13 You can ask us to erase your personal data where one of the following grounds applies:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw the consent you have previously given;
  • you object to the processing of your personal data and there is no legal reason for such processing;
  • the processing of personal data does not comply with the provisions of the applicable legislation and regulations;
  • your personal data have been collected in relation to the offer of information society services to children under 16 years of age.

7.14 Nevertheless, the exercise of this right will not be possible when the retention of your personal data is necessary for compliance with statutory or regulatory provisions and in particular for example for the establishment, exercise or defence of legal claims.

 

Your right to restriction of processing

7.15 You may request restriction of processing of your personal data in the cases provided for by law and regulation.

 

Your right to object to data processing

7.16 You have the right to object to the processing of personal data concerning you when the processing is based on the legitimate interest of the controller or when the processing is necessary for the performance of a mission in public interest or subject to the exercise of public authority.

 

Your right to data portability

7.17 Since May, 25th 2018, you have the right to portability of your personal data.

7.18 The data on which this right can be exercised are:

  • only your personal data, which excludes anonymised personal data or data that does not concern you;
  • declarative personal data and personal data relating to our functioning, as mentioned above;
  • personal data which do not adversely affect the rights and freedoms of others such as those protected by trade secrets.

7.19 This right is limited to processing based on consent or contract as well as to personal data that you have personally generated.

7.20 This right does not include derived or inferred data, which are personal data created by Smart Tribune

 

Your right to withdraw your consent

7.21 When the data processing we carry out is based on your consent, you may withdraw it at any time. We will then stop processing your personal data but this will have no impact on the previous transactions to which you have consented.

 

Your right to lodge a complaint with a supervisory authority

7.22 You have the right to lodge a complaint with the French data protection authority (the Cnil) on the French territory without prejudice to any administrative or judicial remedy.

 

Your right to define post-mortem directives

7.23 You can give instructions in relation to the storage, erasure and communication of your personal data after your death to a certified trusted third party in charge of enforcing the wishes of the deceased in compliance with the applicable legal framework.

8. Why we receive your data

8.1 Your personal data are communicated to us:

  • to subscribe to a Smart Tribune solutions (Smart Tribune services)
  • to organise webinar
  • to send newsletters 

8.2 In this context, if you refuse to provide us with your personal data, we will inform you that this refusal will result in the impossibility to realize, provide Smart Tribune services, to participate to a webinar, to receive the newsletter.

 

Team Smart Tribune