PRIVACY POLICY & GDPR
Updated January 8th, 2024
Bleu Silver
is a B2B digital marketing agency which offers its services exclusively to professionals in France
and internationally.
As such, we collect and process personal data on our behalf and that of our customers.
These data are exclusively intended to be used for prospecting and commercial purposes based on the principle of "legitimate interest" in relations between professionals accordingly to GDPR
We are strongly committed to the process of compliance with the GDPR (General Data Protection Regulation).
The purpose of this charter is to describe the principles implemented in order to comply with the regulations and protect the privacy of individuals and their personal data.
The general framework for the processing of professional personal data aims to provide data subjects with the information necessary for full compliance with the regulations in force.
1. How is the data collected?
Bleu Silver collects, through its activities, data, some of which makes it possible to identify or make identifiable individuals.
1.1. The legal basis for the collection
The legislation lists the legal bases for collecting personal data, otherwise the legitimate justifications for collecting data. These legal bases are explained and / or recalled in the context of collections carried out by Bleu Silver.As such, Bleu Silver may collect personal data on the basis ofthe consent of the person concerned
In France, the CNIL recognizes two exceptions to prior consent in matters of electronic prospecting detailed in a sheet on electronic prospecting dating from October 2016:
- in relations between professionals, the prior consent of the person concerned is not required for commercial solicitations sent to the professional e-mail address as soon as these requests are related to the profession of the person in question.
- This tolerance is called a “BtoB exception”. As Bleu Silver's activities are carried out exclusively between professionals, collections are often carried out following prior information during targeted events, trade fairs, webinars and other professional events.
- prior consent is also not required for any solicitation sent to a data subject for services / products similar to those that this person has already acquired from Bleu Silver.
1.2. Collection methods:
1.2.1. collection through forms
When filling out paper and electronic forms, people transmit information about them. These forms systematically specify:
- the name of the data controller,
- the purposes associated with the collection carried out,
- if the collection is made necessary by the subscription of the service concerned or by the purchase of the envisaged product,
- any other operations envisaged and the legal basis for the collection carried out;
- a reference to the relevant pages of this charter on the procedures for exercising rights by natural persons, the contact details of the DPO, the rules concerning the retention period of data, the procedures for making a complaint to the supervisory authority, etc. ...
1.2.2. collection by phone
Bleu Silver provides certain services by telephone and on this occasion may collect personal data. When possible, telephone contact is confirmed by sending an email, allowing the data subject to keep a written record of the conversation and to be able to exercise their rights at any time.
1.2.3. Indirect collection
Bleu Silver may obtain personal data from third parties.In such a case, Bleu Silver:
- establishes a contract with this third party in accordance with the provisions of the Regulations
- notify people of the transfer of their data to Bleu Silver under the conditions defined by the regulations.
- indicates in its files the source of the data in order to ensure its traceability.
- informs the persons concerned of the procedures for exercising their rights.
2. What kind of information is collected ?
Some of the information collected constitutes “Personal Data”, ie data concerning individuals enabling them to be identified.Note that this is exclusively "non-sensitive" personal data which cannot, under any circumstances, endanger the individual freedoms of the persons concerned. (see About / GDPR) .
In accordance with the legislation in force, Bleu Silver has adopted the principle of minimization in the collection and only collects the data strictly necessary for the objective pursued and explained from the natural persons concerned, leaving them full capacity to exercise their rights.
The personal data that may be requested, depending on the nature of the services or products provided, are as follows:
Mainly and exclusively:
- Your name and contact details and your professional and postal e-mail address,
- Your function,
- Your telephone and fax numbers,
We do not use cookies and do not collect or process any of the following data:
- Type of computer equipment used during navigation,
- Location information and data
- Connection and browsing information (IP addresses, logs)
3. What is the data collected for?
3.1. Use of collected data
Bleu Silver may use the personal data in its possession in order to:
- send commercial information relating to its products, promotions, offers, as well as other information relating to its products or services adapted to the interests of the persons concerned;
- transmit information on the products and offers of third parties - customers or partners in relation to the function and / or with regard to a "legitimate" interest identified coherent in connection with the professional activity of the person concerned or that of the organization to which it belongs;
- These personal data will be used in the context of its activities relating to the promotion of its own products and services as well as prospecting on behalf of third parties. They are only used within the strict limits defined by the legislation in force.
3.2. How to send information
- Telephone
- Postal mail
- Sending electronic mail (based on legitimate interest)
4. How and for how long is the data stored?
Processing actions are carried out on the data appearing in the Bleu Silver databases, by applying strict control rules, in accordance with the state of the technological art and with specific recommendations specific to each client.
4.1. Storage of personal data
Bleu Silver takes all necessary precautions to preserve the security and confidentiality of Personal Data and in particular to prevent them from being distorted, damaged or accessed by unauthorized third parties.
CNIL recommendations (National Commission for Information Technology and Freedom) are taken into account in the management of security for all resources and our organization.
4.2. the duration of data retention and archiving
The retention period depends on the activity concerned, the nature of the contact (customer or prospect) and the uses of the sector and is determined in the general conditions of a framework contract established between the two parties.
5. Who are the third parties having access to the personal data collected?
Is likely to transfer the personal data that it collects to different third parties such as:
- customers / partners who have subscribed to a service that may involve the collection of users' personal data, in particular as part of a contact request or as part of the creation of a prospecting file.
- service providers, subcontractors in order to provide technical qualification services, enrichment of exclusively professional information relating to the notion of "legitimate interest"
- in the event of merger, acquisition, dissolution or sale of all or part of its assets. Data subjects will be informed by email and / or by a prominent message on the Group's website (s) of any change in ownership or concerning the uses of personal data and the choices available to them.
5.3. working arrangements with third parties
In the event that personal data is transmitted to a third party for any reason (for example: a subcontracting service, services provided for a client), Bleu Silver applies the conditions defined by the legislation in force, in particular the information of the persons concerned of this transfer.
Bleu Silver ensures that appropriate contractual provisions are defined and contracted with the third party concerned to guarantee that the latter:
- Only use personal data for the purpose specified by it and in accordance with the objectives defined within the framework of this charter,
- And will have taken the appropriate security measures to prevent unauthorized or unlawful processing of personal data, accidental loss or destruction of such personal data, or damage thereto.
6. Who to contact for information?
Bleu Silver has adapted meets the requirements of the general data protection regulations (RGDP) and provides any person with all information on the personal data concerning them collected and on the processing carried out on this data.
6.1 exercise of the rights of access, opposition, rectification and deletion
Any request relating to the exercise of your rights should be sent to cnil@infopro-digital.com. This request must include as much information as possible so that it can be processed upon receipt within a maximum of two months: for example, people must specify the email address requested and for which they are sending the request in order to facilitate research.6.2 data portability
Any request related to data portability must be sent to Bleu Silver's Data Protection Officer (DPO) who will answer you on the feasibility of such a request.
6.3 Appointment of a Data Protection Officer (DPO) and recourse to the supervisory authority
To complete this system, Bleu Silver has appointed a Data Protection Officer who can be contacted at the following address: DPO - Mr Patrick JOLY- Email: dpo@bleusilver.eufor any question or difficulty relating to the processing of personal data.
Anyone can directly contact the National Commission for Information Technology and Freedom (CNIL).
7. Are the data transferred outside the EU?
If Bleu Silver communicates Personal Data to a third party located outside the European Union, measures are taken to ensure that said data will benefit from the same level of protection as that imposed by the European Union in terms of Data protection.
As such, Bleu Silver will ensure that the processing is carried out in accordance with this charter and that it is framed by the standard contractual clauses of the European Commission which make it possible to guarantee a sufficient level of protection of privacy and rights. fundamentals of people.
8. Recruitment
As part of its recruitment policy, Bleu Silver collects and stores personal data relating to potential candidates.
Bleu Silver collects the information necessary to find the most suitable profiles for the positions to be filled in compliance with the law as well as the rights and freedoms of individuals. Bleu Silver refrains from transmitting to a third party the CV with the contact details of a person, without their consent.
Candidates who wish to modify or delete their personal data from our databases can at any time send an emailto DPO (Data Protection Officer)Mr Patrick JOLY- Email: dpo@bleusilver.eu by indicating in the subject line "personal data".
Bleu Silver may modify or update this Personal Data Policy.Any updates will be posted where deemed appropriate, so that any user will be notified of the date of the last update.