Privacy Policy confluent-digital

CONFLUENT DIGITAL PERSONAL DATA PROTECTION POLICY – Last updated on December 15, 2022

Personal data :

This Personal Data Protection Policy is part of a transparency approach by the database manager (hereinafter referred to as Confluent Digital). This document describes Confluent Digital's practices regarding the collection, sharing, database management and confidentiality of user data of Confluent Digital services.

This Personal Data Protection Policy may apply concurrently (i) to the general conditions of use of the sites published by Confluent Digital (ii) to the regulations for surveys and competitions with prizes published by Confluent Digital (no games published by Confluent Digital is not subject to approval by the Online Gaming Regulatory Authority).

If you have any questions about this document or about how Confluent Digital protects your data, In accordance with articles 39 et seq. of law no. 78-17 of January 6, 1978 amended in 2004 relating to computing, files and freedoms, any person may obtain communication and, where applicable, rectification or deletion of information concerning them, by contacting us at the following address: contact@confluent-digital.com or dpo@confluent-digital.Com

WHAT IS PERSONAL DATA?

According to the General Data Protection Regulation, “personal data” means any information relating to an identified or identifiable natural person; is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity.

WHAT DATA IS COLLECTED BY CONFLUENT DIGITAL?

Confluent Digital offers free services which allow you either to subscribe to newsletters to receive commercial communications on different themes (by email / sms / tel / Push / postal addresses / teleprospecting), or to participate in polls, surveys and online competitions and draws to receive the prizes offered (hereinafter the “Services”) or to request quotes online.

In certain cases, confluent digital is an external service provider for database management. Confluent Digital partners manage databases through a contractual agreement. Confluent Digital has a right to use the data. Confluent Digital may send advertising campaigns by email and/or SMS or/and enrich databases or/and telemarketing operations.

Therefore, You have given your consent to your data being transmitted to its commercial partners of which Confluent Digital is a part. Consequently Confluent Digital, as data controller, processes your personal data for the purposes of commercial prospecting, commercial operations, communication operations.

Confluent Digital also processes your data, as part of its legitimate interest, to ensure the correct receipt of this email, measure the interest in its content, update its mailing list, and carry out internal technical operations. in particular reconciliation, standardization, enrichment and deduplication, to enable us to justify the origin of the data collected, to manage the exercise of your rights (management of requests for rights of access, rectification and opposition, etc. ), for the development of statistics, and for operations relating to the prevention and detection of fraud and the resolution of disputes.

When using the Services, the following data may be collected and processed by Confluent Digital:

Declarative data:
- mandatory data when registering for one of our Services: title, surname, first name, email address, date of birth, postal code.

mandatory data when participating in our surveys: family, economic and financial situation, optional data when participating in our Services: telephone number, your tastes and interests.

Technical data:

data related to the terminal you are using.
data on your browsing and your behavior on the websites offering our Services: browsing URL, date and time of connection and/or browsing, browser type, browser language, IP address, etc.
data related to the use of our Services: date of registration for a Service, date of last connection to a Service.
and more generally the data collected by cookies.

Following the collection of this data, Confluent Digital may carry out marketing and commercial prospecting campaigns relating to its Services and the products and services of its commercial partners. In this case, the categories of data processed by Confluent Digital are as follows:

Declarative data relating to identity:

civility
name
first name
email
date of birth
zip code
Telephone

Possibly certain technical data notably linked to cookies:

such as receiving or rejecting the email
the opening IP
the origin of the registration
the date of last opening
clicking on a link contained in the email
the browser
the operating system
the type of terminal used
etc.

Confluent Digital may also be the recipient of personal data from its commercial partners who entrust it with their databases for the purposes of carrying out marketing and commercial prospecting campaigns. In this case, Confluent Digital operates these databases as data controller, and the categories of data processed by Confluent Digital are the same as those above.

Confluent Digital does not collect or process personal data revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, as well as genetic data, data concerning health or data concerning sexual life or data relating to criminal convictions and offenses or related security measures.

WHAT HAPPENS IF YOU DO NOT SELL US YOUR DATA?

When using Confluent Digital services or the services of Confluent Digital partners, you are informed whether certain data must be provided or whether it is optional. If you do not provide the data mentioned as mandatory, you will not be able to access all of the Services.

WHY DOES CONFLUENT DIGITAL COLLECT YOUR DATA OR PROCESS YOUR DATA AS PART OF ITS COMMERCIAL AGREEMENTS?

Confluent Digital processes your data as part of the execution of a contract for this purpose, the purposes pursued by Confluent Digital are as follows:

Manage user identity and authenticate

Manage incoming mail

Manage data subject rights requests

Store user data

Offer authentication services

Manage database management monitoring as part of its commercial agreement with its partners

Manage the monitoring of database management in the context where Confluent Digital would have collected the data on its behalf

The data is kept for the duration necessary to achieve the purposes mentioned above. With regard to processing relating to the execution of the contract, the data may be kept for a maximum period of 36 months from the end of the relationship.

Confluent Digital also carries out data processing for purposes other than the strict execution of contracts. In this case, Confluent Digital ensures that it has a legitimate interest in carrying out the processing. Furthermore, processing may be subject, as necessary, to obtaining your consent, which you can withdraw at any time. To this end, the purposes pursued by Confluent Digital are as follows:

Organize direct marketing operations (email, SMS, push notification, teleprospecting, postal mail, enrichment)

Organize commercial events

Organize competitions

Analyze the uses of offers and services to make proposals to the customer

Survey customers or users

Improve offers and customer relations

Ensuring the security of platforms and services

Your data is kept for the duration necessary to achieve the purposes mentioned above. Confluent Digital also processes data to meet legal or regulatory obligations. To this end, the purposes pursued by Confluent Digital are as follows:

Retain the data required to be able to meet legal obligations

Manage data communication requests from authorized authorities

The data may be retained for as long as necessary to enable Confluent Digital to meet its legal obligations. Confluent Digital may also process data for statistical purposes, including by marketing the statistics obtained. In this case all data is previously made anonymous.

They may also be used to pursue the legitimate interests of Confluent Digital:

To send you communications by email for products and services similar to those of the company Confluent Digital which collected your data when using one or more of our Services.
To carry out technical prospecting operations, in particular reconciliation, standardization, enrichment and deduplication, and allow us to justify the origin of the data collected.
To manage the exercise of your rights (management of requests for rights of access, rectification and opposition, etc.).
For the development of statistics and measurements of attendance of our Services.
For operations relating to the prevention and detection of fraud and dispute resolution.
Carry out operations relating to the management of our commercial partners (contracts, orders, deliveries, invoices, accounting, management of complaints, unpaid debts, etc.).
For litigation management.

Among these legitimate interests, we can cite the development of our activities, the improvement of the performance and functionalities of the Services offered, the search for new services and new customers, the knowledge of your preferences to be able to better personalize our offers and, ultimately, to offer products and services that better suit your needs and desires, prevention of fraud and misuse of services, etc. These processing operations are carried out under conditions which allow us to preserve your rights by informing you and allowing you to oppose them.

When your data has been communicated to Confluent Digital by one of its commercial partners who entrusts it with its database for commercial prospecting purposes, Confluent Digital contractually ensures that you have given your consent to this partner so that your data can be used by us. be transmitted for this purpose. In this case, your data is processed by Confluent Digital to enable us to offer you offers from Confluent Digital and our commercial partners, to carry out studies, surveys and product tests, as well as loyalty, prospecting and promotion actions. . When Confluent Digital first communicates with you, you will receive an email informing you in particular of the partner who communicated your data to us and you can always object to receiving commercial communications from Confluent Digital.

WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

It was published either as part of a commercial agreement between Confluent Digital and its clients (data providers / management) or as part of the collection of data directly on behalf of Confluent Digital (collection of data through lead generation operations via different levers: Cosponsoring or/and coregistration or/and via GDPR-compliant forms) that Confluent Digital could benefit from the management of the database and thus address marketing campaigns (from advertisers) to “the database” (via emails / postal addresses / sms / push / telephone in the context of teleprospecting / enrichment).

In the context where Confluent Digital monetizes and manages the database on behalf of its partners: The partners contractually undertake to have proof of consent. In the context where Confluent Digital is the collector of the database: Confluent Digital undertakes to have proof of consent.

When you have accepted that your data is transmitted for commercial prospecting purposes to Confluent Digital partners, each of these companies becomes responsible for the processing it does of your data. Each company that sends you commercial prospecting must identify itself during any communication with you, which allows you to contact it directly and exercise your rights with it.

If you wish to unsubscribe from the databases you can contact us by email dpo@confluent-digital.com or mail to 15 rue des cuirassiers 69003 Lyon France

WHO ARE YOUR DATA SHARED TO?

The Confluent Digital company responsible for processing may sometimes transmit all or part of your data to other companies which are then recipients of it:

Within Confluent Digital: services in charge of the administrative, commercial or technical management of the Services, services in charge of the management of marketing and commercial prospecting campaigns.

Outside of Confluent Digital: the bailiff in charge of the draw in the context of surveys and competitions with prizes, the subcontractors to whom Confluent Digital entrusts certain operations such as: hosting and management providers hosting, management and routing providers for our marketing and commercial prospecting campaigns, monitoring and audience measurement providers for our marketing and commercial prospecting campaigns. Confluent digital ensures that it selects subcontractors providing sufficient guarantees in terms of the protection of personal data.

And in the event of your consent when collecting your data, to receive commercial communications relating to products and/or services provided by our commercial partners, including other Confluent Digital companies, we transmit your data to those -this. They then become responsible for processing your data themselves.

We may also communicate information that does not personally identify you to our business partners about the effectiveness and scope of operation of marketing campaigns and commercial prospecting, for example the number of people who clicked on the advertising link content in an email, the date and time of the click, the URL, the internet service provider used, etc.

WHAT ARE YOUR RIGHTS ?

You have many rights regarding your data. These rights can be exercised by sending a letter accompanied by proof of identity to:

DIGITAL CONFLUENT

For the attention of the Data Protection Officer

15 Rue des Cuirassiers

69003 Lyon

France

Or by email to: dpo@confluent-digital.com

If Confluent Digital has reasonable doubts as to the identity of the natural person making the request under the rights described below, Confluent Digital may request that it be provided with additional information necessary to confirm the identity of the person.

We inform you that no payment is required to take any action in respect of your rights as described below. However, when a person's requests are manifestly unfounded or excessive, in particular because of their repetitive nature, Confluent Digital may:

require the payment of a reasonable fee that takes into account the administrative costs incurred in providing the information, making the communications or taking the requested action; Or

refuse to comply with these requests.

Right to object to the processing of your data and right to withdraw your consent Confluent Digital ensures that you can always use our Services without this use being conditioned (i) on the receipt of commercial communications from the data controller or its partners, (ii) profiling (iii) the purchase of a good, the benefit of a reduction or the provision of a service.

This possibility is offered to you on all our Services and by setting cookies, and if you have agreed to receive commercial prospecting messages from Confluent Digital and/or its partners, you can always change your mind by following, and object or withdraw your consent, free of charge and without reason. If you have accepted the storage of cookies on your terminal, you can also object subsequently, always free of charge and without reason.

If you exercise your right to object or withdraw your consent for commercial prospecting purposes including profiling, Confluent Digital will no longer process your data for this purpose.

In addition, you can register for free on the BLOCTEL telephone canvassing opposition list. For more information, you can visit the website www.bloctel.gouv.fr

How can you object or withdraw your consent? You have the right, at any time, free of charge and without reason, to (i) withdraw your consent when the processing of your data is based on it, (ii) object : to receive marketing messages from us, and/or profiling carried out, and/or for us to stop transmitting your data to our commercial partners. Simply click on the “unsubscribe” link in any email sent by Confluent Digital, manage your cookie settings, or write to us at dpo@confluent-digital.com. In the event of prospecting by SMS or MMS, you can unsubscribe at any time by sending STOP by SMS response to the sender.

To stop receiving commercial offers from our current partners, we suggest that, for more information, you refer to their conditions. You will in all cases be able to exercise your various rights directly with them, in particular rights of access, rectification and opposition. In case of difficulty, you can write to us at any time at dpo@confluent-digital.com

Right of access to your data You can ask Confluent Digital if we process data about you and when this is the case, you can obtain access to said data as well as information related to the processing thereof ( purposes, categories of data, categories of recipients, retention period or criteria for determining the duration, existence of transfer outside the EU, source in the event of indirect collection and associated guarantees, reminders of your rights).

Right to have your data rectified You can request the rectification of information concerning you if that held by Confluent Digital is inaccurate. You also have the right to have incomplete personal data completed, including by providing a supplementary statement.

In the event of exercising this right, Confluent Digital will notify each recipient to whom your data has been communicated of any rectification of data, unless such communication proves impossible or requires disproportionate effort.

Right to have your data erased (right to be forgotten) You have the right to obtain from Confluent Digital the erasure of your data when there is a reason provided for by law, such as for example: the uselessness of the data or the withdrawal of your consent for processing based on the latter, if you object to the processing for commercial prospecting purposes, or if you object to processing for another purpose and there is no reason legitimate imperative for processing.

In the event of exercising this right, Confluent Digital will notify each recipient to whom your data has been communicated of any erasure of data, unless such communication proves impossible or requires disproportionate effort.

Right to limit the processing of your data

You have the right to obtain restriction of processing by Confluent digital where one of the following applies:

If you dispute the accuracy of your data, for a period allowing us to verify it.

If the processing is unlawful and you object to their erasure and instead demand restriction of their use.

If Confluent Digital no longer needs your data for the purposes of processing but you still need it for the establishment, exercise or defense of legal claims.

If you have objected to processing based on the legitimate interests of the controller, during the verification whether the legitimate grounds pursued by the controller override yours.

In the event of exercising this right, Confluent Digital will notify each recipient to whom your data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate effort.

Right to portability of your data You have the right to request portability of your data. This allows you to receive the data in a digital format. This right only concerns the case where the processing is carried out using automated processes and on the basis of your consent or the performance of a contract.

Automated decisions and profiling Confluent Digital does not make any decisions about you, based solely on automated processing, which produces legal effects concerning you, or which may significantly affect you.

The “profiling” carried out by Confluent Digital consists of the analysis of your data concerning your personal preferences or interests, your behavior when receiving an email, your online browsing, your location. This information may be taken into account in order to send you personalized commercial communications, based for example on your tastes, your gender, your age group or your postal code. You can always object to this profiling (see above).

Right to give instructions on the fate of your data in the event of death You have the right to define general or specific instructions relating to the conservation, erasure and communication of your data after your death, specifying the manner which you intend to exercise these rights.

These directives may designate a person responsible for their execution, failing which, your heirs will be designated. You can communicate specific instructions to Confluent digital. In the absence of any directive, your heirs can contact the DPO of Confluent Digital at dpo@confluent-digital.com

These directives, when they are general and concern all personal data concerning you, may be recorded with a trusted digital third party certified by the National Commission for Information Technology and Liberties.

Right to lodge a complaint with a supervisory authority You have the right to lodge a complaint with a supervisory authority, such as the National Commission for Informatics and Liberties (CNIL).

ARE YOUR DATA TRANSFERRED TO A THIRD COUNTRY TO THE EUROPEAN UNION?

The majority of Confluent Digital's processing takes place within the territory of the European Union. Thus all your data is hosted within the territory of the European Union.

Certain subcontractors, acting as technical service providers to Confluent Digital, may be located outside the European Union, such as platforms for sending or monitoring our marketing and commercial prospecting campaigns. In this case, the transfers of your data are governed by appropriate guarantees in order to protect your rights, such as the regularization of specific contracts incorporating the standard contractual clauses of the European Commission and you can read them here, or the use of companies located in the United States and certified “Privacy Shield”.

HOW LONG IS YOUR DATA KEPT?

Your data will not be kept beyond the period strictly necessary for the purposes pursued as stated above, in accordance with the law. Your data is deleted or anonymized when the retention periods expire.

Your data is kept for three years from your last activity on our Services or on one of our electronic communication media (in particular clicking on a hyperlink contained in one of our emails).

Personal data relating to a prospect who has not registered for our Services is kept for a maximum of three years from their communication to Confluent Digital by one of its partners or the last contact from this person (in particular clicking on a hyperlink contained in one of our emails).

At the end of this three-year period, Confluent Digital may contact you to find out if you wish to continue to receive our commercial communications. In the absence of a positive and explicit response from you, we will delete or archive your data.

However, data making it possible to establish proof of a right or a contract, or kept for compliance with a legal obligation, may be the subject of an intermediate archiving policy for a period of only not exceeding the duration necessary for the purposes for which they are kept, in accordance with the legal provisions in force (in particular but not exclusively those provided for by the commercial code, the civil code and the consumer code).

Thus, in the event of contentious proceedings, including those relating solely to Confluent Digital, for example with regard to the administration or one of its commercial partners, the data as well as any information, documents and documents containing data tending to establish the facts likely to be alleged or concerning the identification of the accused, the victims, the witnesses and the judicial officers may be kept for the duration of the procedure, including for a duration greater than that indicated above.

Likewise, in the event of withdrawal of your consent or if you have exercised your right to object to receiving commercial prospecting from Confluent Digital, the information allowing your choice to be taken into account will be kept for a minimum of three years from the date of receipt. exercise of law. These data will in no case be used for purposes other than the management of the withdrawal of consent or the right of opposition and only the data necessary to take into account the withdrawal of consent or the right of opposition will be kept.

COOKIE POLICY?

The term “Cookie” designates, in the broad sense, any tracer deposited and/or read when consulting a website or an email. A cookie may contain information such as the name of the server that placed it, an identifier in the form of a unique number, and an expiration date.

Cookies are notably necessary to allow you to benefit from certain features of our Services. If you have chosen to deactivate Cookies via your internet browser, access to the Services may then be impaired.

Confluent Digital uses its own Cookies, as well as the use of third-party Cookies. Only the issuer of a Cookie is likely to read or modify the information contained therein.

The Cookies set up are of several types and serve different purposes. They are installed on your receiving terminal (computer, tablet, smartphone, etc.) or on your browser subject to the choice you have expressed regarding Cookies, this choice may be modified at any time. You can find out about the nature of the Cookies placed, accept or refuse them either globally for an entire site and all Services, or site by site or service by service.

Data collected using Cookies is kept for a maximum of thirteen months. Beyond this period, the data is deleted or anonymized.

Cookies Confluent digital

“Session ID” cookies

“Session ID” Cookies are used by the websites on which Confluent Digital offers its Services in order to (i) memorize information relating to a form that you have completed on this site (e.g.: registration forms for the Services, non-finalized participation in a survey or competition), (ii) allow you to access reserved and personal areas of the website, such as a “User Space”, using identifiers or data that you have previously transmitted to Confluent Digital, (iii) log in again to content or a Service after a certain period of time.

“Technical” cookies

Technical Cookies are used by Confluent Digital to enable the editorial content of the websites published by Confluent Digital that you have visited to be adapted to the technical configuration of a computer/tablet.

“Security” cookies

“Security” Cookies are used by Confluent Digital to improve the security of the services/sections/spaces made available to you (e.g. connection to a “User Space”).

Audience measurement cookies

Audience measurement Cookies are used by Confluent Digital in order to develop traffic statistics for the websites on which Confluent Digital offers its Services (e.g. concerning their sections, their content) in order to (i) calculate any sums due to our commercial partners (communication agency, advertising agency, site/broadcast medium) and to establish statistics and reporting on the performance of the promotional operations implemented; (ii) allow Confluent Digital to improve the interest and ergonomics of its sites.

Behavioral analysis cookies

Behavioral Analysis Cookies are used by Confluent Digital to send you targeted advertising. The emails we send may set a Cookie when you open it and download the images. You can prevent such installation by opening only the text of the email and closing it without downloading an image, or by modifying your browser/email software to block cookies. The data collected is: IP address, email, device, date and time of connection, browser type, browser language, browser version. We share information about the use of our sites, such as navigation and/or geolocation data, with our advertising partners and analytics, which may combine this with other information that you have provided to them or that they have collected from your use of their services.

Third-party cookies Due to third-party applications integrated into websites or emails offering our Services, certain Cookies may be issued by our commercial partners and the issue and use of Cookies by these partners are subject to privacy protection policies. private lives of the latter. Confluent Digital informs you of the purpose of the Cookies of which we are aware and the means available to you to make choices with regard to these Cookies.

Below you will find the list of our partners authorized to place cookies on our site and emails, as well as a link to their confidentiality policies offering and explaining the terms of opposition to their services.

Name of cookies Type of cookies Purpose of cookies Publisher Lifespan of cookies Data recipients Type of raw data collected Link to the partner's cookie policy

How to authorize/deactivate Cookies? You can, at any time, modify your choices regarding cookies, in particular by the means described below.

You can configure your browser software so that cookies are saved on your terminal or, on the contrary, that they are rejected, either systematically or depending on their issuer. You can also configure your browser software so that you are offered the acceptance or refusal of Cookies from time to time, before a cookie is likely to be stored in your terminal.

For that :

You are browsing the Internet with the Internet Explorer browser, click here to find out the procedure to follow

You are browsing the Internet with the Mozilla Firefox browser, click here to find out the procedure to follow

You are browsing the Internet with the Google Chrome browser, click here to find out the procedure to follow

You are browsing the Internet with the Safari browser, click here to find out the procedure to follow

If you are not using any browser from this list, you can consult your browser's help menu to configure it.

You can go to the Youronlinechoices site, offered by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance).

You will thus be able to know the companies registered on this platform and which offer the possibility of refusing or accepting the Cookies used by these companies to adapt the cookies likely to be placed on your terminal.

In addition, we invite you to consult the “Cookies: tools to control them” section of the CNIL website: https://www.cnil.fr/en/home

If you have difficulty exercising your right to access or oppose Cookies, you can contact Confluent Digital: dpo@confluent-digital.com

DATA SECURITY

Confluent Digital implements appropriate technical and organizational measures, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the degree of probability and severity of risks for the rights and freedoms of natural persons.

Confluent Digital also takes measures to ensure that its staff, its subcontractors and their staff, who have access to your data, do not process it, except on the instructions of the data controller, unless obliged to do so by the right to do so. the Union or the law of a Member State.

Confluent Digital ensures that its subcontractors provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures so that the processing best respects the protection of the rights of the person concerned.

CHANGES TO OUR PRIVACY POLICY

We regularly review our Personal Data Protection Policy and will publish any updates on this web page.

This processing is based on consent and you can change your mind later, at any time, simply and free of charge. You can find out about all of your rights and how we process your data in the Personal Data Protection Policy.

Enquête de deal also processes your data as part of its legitimate interest, to manage your registration, ensure the correct receipt of the emails we send to you, measure the interest of their content, constitute a list of our subscribers and carry out internal technical operations, in particular reconciliation, standardization, enrichment and deduplication, to enable us to justify the origin of the data collected, to manage the exercise of your rights (management of requests for rights of access, rectification and opposition, etc.), for the preparation of statistics, and for operations relating to the prevention and detection of fraud and the resolution of disputes. Unless you have expressly consented, we do not communicate your data to third parties. Your data, or part of them, may be transmitted to our subcontractors, technical service providers, to whom we entrust the hosting of your data, and/or the management, monitoring and measurement of audience of our emailing campaigns. The Optinplus, Peps Digital and Cap Decision databases are managed by the company Confluent Digital as agent. If you have any questions, you can contact the Data Protection Officer (DPO) of the Confluent Digital Company at the following address: dpo@confluent-digital.com

Confluent Digital – 15 Rue des Cuirassiers 69003 Lyon – France – Individual identification number (VAT): FR93 840 203 939.