Last updated on May 10, 2019
1. Objectives and Scope
- to be aware of the reasons we are collecting data concerning them;
- understand how their data will be processed;
- and ensure the control of their data, by facilitating the exercise of their rights.
The Data Protection Policy applies to all Users of the Services.
The Data Protection Policy does not apply to the sites of our network partners, nor to the practices of legal and physical persons, third parties to SPARKNEWS SAS and over which SPARKNEWS SAS has no control.
2. Who is responsible for processing personal data collected as part of SPARKNEWS SAS services?
SPARKNEWS SAS is responsible for processing the Personal Data of Users of our Services. Our contact details are: SPARKNEWS SAS, 5 RUE GUICHARD 75016 PARIS, Email firstname.lastname@example.org, Siret 53380708700028.
We define “Personal Data” as any information relating to a physically identified or identifiable person, directly or indirectly, notably by reference to an identifier, such as a name, an identification number, an online identifier, etc.
We define “User” as any physical person accessing the Services, Sites and / or Applications.
We define “Service(s)” as all services made available by SPARKNEWS including through its website and newsletter with the goal of raising awareness about innovative initiatives that have a positive impact on the major challenges of our world by creating content, programs and events around these initiatives to inspire and encourage individuals to take action, within companies and civil society.
We define “Site” as the SPARKNEWS online public communications service, accessible at www.sparknews.com.
3. On what legal basis do we collect your Personal Data?
You will find below the different legal bases which each justify our data processing:
- The contract, notably at the time of subscription to our SPARKNEWS SAS Newsletter.
- The explicit consent given during the collection of personal data notably through a checkbox to show your consent.
- The lawful interest of SPARKNEWS SAS. We have a lawful interest in processing your personal data when it is justified, balanced and does not interfere with your privacy, as part of our market research and external communication concerning our Services, the fight against fraud and for cyber security.
- The law: the processing of your personal data may be mandatory by a legal obligation, a mission of public interest.
4. Why are we collecting your data?
We may collect your personal data for the following purposes:
4.1 For any external communication about our Services, only in connection with the profession of the Users (BtoB) in order to:
- Organize and publish some of your Professional Personal Data within our network (professional directory), only with your explicit and prior consent and the ability to unsubscribe or modify the data communicated as soon as possible, simply and for free.
- Perform all external communication operations concerning our Services to the public, notably through the distribution of our newsletter. When collecting your Personal Data for external communication purposes, you are clearly informed of the identity of SPARKNEWS SAS as responsible for the processing. You are also informed that your e-mail address may be used for external communication purposes, and that you are able to oppose it in a simple and free manner.
We do not transmit your data to third parties without your prior, explicit, specific and informed consent, notably on the collection form.
4.2 To follow your relationship with SPARKNEWS:
- Monitoring of contracts and the implementation of services;
- Billing follow-up, management of outstanding payments and litigations;
- User relationship follow-up such as carrying out satisfaction surveys, managing claims and collecting feedback about services or content;
- Management of loyalty market research operations, studies (selection, standardization, enrichment and deduplication of databases);
- Analysis of visits on our website and our social networks.
4.3 As part of our relationship with our suppliers.
The processing of personal data relating to the management of supplier files may have the purpose of performing administrative operations related to contracts, orders, invoices, accounting with regard to the management of accounts payable, to establish financial statistics and turnover by supplier, to provide selections of suppliers; to maintain supplier documentation.
4.4 In the context of operations relating to the security and proper functioning of our website and our information system.
We collect certain browsing data, including IP addresses to ensure the security and proper functioning of our services and to detect, avoid or trace any attempt of cyberattack or computer intrusion or violation of the user conditions of our services or the law. In this context we are also likely to implement cookies on your device to allow the proper functioning of our site and to measure its audience.
4.5 For the control of your personal data with SPARKNEWS SAS.
When you assert your rights with SPARKNEWS SAS regarding the management of your rights of access, rectification, deletion, opposition, limitation and portability.
4.6 The use of social networks to disseminate information:
In addition to the points detailed below, we invite you to consult the personal data management policies of the various social networks to learn about the collection and processing they perform on your data.
4.6.1 Share button on social networks.
You will find on our site share buttons offered by the main social platforms (Facebook, Twitter, YouTube, Linkedin.com, Medium.com). These buttons utilise cookies to trace the browsing of users, notably in the context of digital marketing operations, whether or not they use these buttons. We invite you to consult the personal data management policies of the various social networks to learn more about the collection and processing they perform on your data.
4.6.2 SPARKNEWS pages on social networks.
By connecting to our Facebook page (https://www.facebook.com/sparksnews/ ) as well as other social networks, you are likely to share your personal data with these social networks. Other networks collect information about your identity, the persons, pages, accounts, hashtags, and groups with whom you have contact, as well as how you interact with them, for example, the persons with whom you communicate most or groups you belong to. They also collect contact information if you choose to download, sync, or import them from a device (for example, an address book, call log, or SMS history), that social networks are likely to use for the benefit of third parties, notably in the context of digital marketing operations.
To learn more about Facebook: https://www.facebook.com/privacy/explanation
4.6.3 Cookies on our site
Subject to the points mentioned above, the cookies used on our site are intended to enable or facilitate communication by electronic means.
Thus, our website is likely to use:
- « session identifiers » cookies (for the duration of a session, or for a few hours);
- « authentication cookies » of users
- cookies enabling the analysis of audience measurement;
- persistent cookies customizing the user interface (for example for the choice of a interface appearance).
Cookies are not kept beyond 13 months.
5. What information do we collect?
- Data relating to your identity: title, surname, first names, address, telephone number (landline and / or mobile), nationality, business address, e-mail addresses, a copy of an identification document may be kept for the purpose of proof of the exercise of a right of access, rectification or opposition or to fulfill a legal obligation;
- Data relating to your professional life: resume, skills, terms and conditions of work;
- Data relating to the means of payment, transaction, and invoices such as the transaction number; RIB; for payment by card retrieval of time-stamp (date, type of payment); check number, transaction reference, debtor name, bank; transfer; terms of payment, discounts, receipts, balances and monitoring of outstanding payments.
- Data relating to User relationship management: requests for documentation, correspondence and comments; implementation of loyalty actions and the organization of any external communication operation;
- Navigation data and your IP address on the website and social networks.
6. How long is your Personal Data kept?
6.1 The personal data relating to our services is only kept for the period strictly necessary for the management of the relationship with SPARKNEWS SAS or with the offer of Services, except legal obligation of conservation identified (to learn more about the legal durations of data conservation).
6.2 Personal data used for prospecting operations relating to your professional activity are kept for a maximum of three years from their collection or our last contact.
6.3 In the case of exercise of the right of access or rectification, the data relating to identification documents may be kept for a maximum of one year. In case of exercise of the right of opposition, this data is archived for three years.
6.4 The information stored in the user’s terminal, for example Cookies, or any other element used to identify the users and allowing the traceability of the users are not kept beyond thirteen months. Beyond this period, the data is either deleted or anonymized.
7. Who has access to your Personal Data?
In addition to the members of our network in a strictly defined framework (see point 5.1 above), may have access to your Personal Data in the context of a strict obligation of confidentiality and computer security:
- The SPARKNEWS SAS staff. Within SPARKNEWS SAS, only some of our employees have access to your Personal Data in the framework of their assignments.
- The potential subcontractors we use for IT, accounting and administrative services;
- Third parties, in limited cases governed by the law, such as the judicial and / or administrative authorities.
- Social networks when:
– You share information on these networks regarding SPARKNEWS SAS (share button);
– and when social networks implement cookies on your device through our site;
– or when you visit a page dedicated to SPARKNEWS SAS on these social networks.
8. Transfer of your Personal Data outside the European Union
There will be no transfer of Personal Data outside the European Union without your explicit, prior and specific agreement.
In the context of Social Networks, we inform you that your personal data may be transferred to the United States. They have joined the “Privacy Shield” agreement between the United States and the European Union to supervise transatlantic transfers of personal data.
9. How to exercise your rights on your Personal Data?
9.1 In accordance with the regulations on the protection of personal data, you may withdraw your consent and exercise your rights of access, rectification, deletion, opposition, limitation and portability by sending your request to email@example.com or by post to SPARKNEWS SAS, 5 RUE GUICHARD 75016 PARIS.
It is necessary to include your surname, first names, e-mail address, and mailing address and to indicate the reason for your request and / or the right that you wish to exercise. As part of this request to exercise your rights, we may ask you for a photocopy of an identification document with your signature to verify your identity and specify the address to which you must receive the response. An answer will be sent to you within 1 month of receiving the request.
9.2 You also have the right to lodge a complaint with the ‘Commission nationale de l’informatique et des libertés (CNIL)’, notably on their website www.cnil.fr.
9.3 Finally, you have the right to define instructions regarding the utilisation of your Personal Data after your death. To exercise this right, we invite you to send an email to firstname.lastname@example.org. In the event that a User dies without having left instructions on the utilisation of their Personal Data after their death, the heirs of the latter may ask to close the User Account of the deceased, by contacting us by email.