PRIVACY POLICY & GDPR
Updated January 8th, 2024
Bleu Silveris a digital marketing agency B2B 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 clients.
These data are exclusively intended to be used for prospecting purposes and commercial approaches based on the principle of "legitimate interest" in relations between professionals.
We are strongly committed to the process of complying 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 data of a personal nature aims to provide the persons concerned with the information necessary to fully comply with the regulations in force.
1. How is 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 data collection. These legal bases are explained and/or recalled as part of the collections carried out by Bleu Silver. As such, Bleu Silver may collect personal data based on the consent of the person concerned.
In France, the CNIL recognizes two exceptions to prior consent regarding electronic prospecting detailed in a fact sheet on electronic prospecting dating from October 2016:
- in relationships between professionals, the prior consent of the person concerned is not required for commercial solicitations sent to the professional email address as long as these solicitations are related to the profession of the person in question.
- This tolerance is called the “BtoB exception”. As Bleu Silver's activities are exclusively implemented 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 would have 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 themselves. 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 subscribing to the service concerned or by purchasing the intended product,
- any other uses envisaged and the legal basis for the collection carried out;
- a reference to the relevant pages of this charter on the terms of exercise of rights by natural persons, the contact details of the DPO, the rules concerning the duration of data retention, the terms of complaint to the supervisory authority, etc. …
1.2.2. collection by telephone
Bleu Silver carries out certain services by telephone and on this occasion may collect personal data. When possible, telephone contact is confirmed by sending an email, allowing the person concerned 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 hypothesis, Bleu Silver:
- establishes a contract with this third party in accordance with the provisions of the Regulations;
- notifies individuals 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 traceability;
- informs the persons concerned of the procedures for exercising their rights.
2. What types of information are collected?
Some of the information collected constitutes “Personal Data”, namely data concerning individuals allowing them to be identified.
Note that this is exclusively “non-sensitive” personal data which cannot, under any circumstances, endanger the individual freedoms of the people concerned (see About/GDPR) .
In accordance with current legislation, Bleu Silver has adopted the principle of minimization in collection and only collects the data strictly necessary for the objective pursued and explained to the natural persons concerned, leaving them with 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 email address,
- Your function,
- Your telephone and fax numbers,
We do not use cookies and do not collect or process any of the following data:
- Nature of computer equipment used during navigation,
- Location information and data
- Connection and browsing information (IP addresses, logs)
3. What is the data collected used 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 an identified “legitimate” interest consistent with the professional activity of the person concerned or that of the organization to which she belongs;
- This personal data will be used as part 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. Methods for sending information
- Phone
- Postal mail
- Sending email (legitimate right)
4. How and for how long is the data stored?
Processing actions are carried out on the data contained in the Bleu Silver databases, applying strict control rules, in accordance with the state of the technological art and the 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 it from being distorted, damaged or from unauthorized third parties having access to it.
The recommendations of the CNIL (National Commission for Information Technology and Liberty) are taken into account in the management of security for all resources and our organization.
4.2. data retention period and archiving
The retention period depends on the activity concerned, the nature of the contact (customer or prospect) and the practices 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 with access to the personal data collected?
May transfer the personal data it collects to various third parties, such as:
- customers/partners who have subscribed to a service that may involve the collection of users' personal data, particularly as part of a connection request or as part of the creation of a prospecting file.
- service providers, subcontractors in order to carry out technical services of qualification, enrichment of exclusively professional information falling within 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 a prominent message on the Group's website(s) of any change in ownership or regarding 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 carried out for a client), Bleu Silver applies the conditions defined by the legislation in force, in particular the informing the persons concerned of this transfer.
Bleu Silver ensures that appropriate contractual stipulations are defined and entered into with the third party concerned to guarantee that the latter:
- Will 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 appropriate security measures to prevent unauthorized or unlawful processing of personal data, accidental loss or destruction of personal data, or damage thereto.
6. Who should I contact for information?
Bleu Silver has adapted meets the requirements of the general data protection regulations (GDPR) and provides any person with all information on the personal data collected about them and on the processing carried out on this data.
6.1 exercising the rights of access, opposition, rectification and deletion
Any request related to the exercise of your rights must 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 respond to the feasibility of such a request.
6.3 The appointment of a Data Protection Officer (DPO) and recourse to the supervisory authority
In order to complete this system, Bleu Silver has appointed a Data Protection Officer who can be reached at the following address:
DPO - Mr Patrick JOLY - Email: dpo@bleusilver.eu for any questions or difficulties relating to the processing of personal data. Anyone can contact the National Commission for Information Technology and Freedom (CNIL) directly.
7. Is 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 governed by the standard contractual clauses of the European Commission which 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 search for the most suitable profiles for the positions to be filled while respecting the law as well as the rights and freedoms of individuals. Bleu Silver is prohibited from transmitting a person's CV with contact details to a third party without their consent.
Candidates who wish to modify or delete their personal data from our databases can at any time send an email
to DPO ( Data Protection Officer) Mr Patrick JOLY - Email: dpo@bleusilver.eu indicating “personal data” in the subject line.
Bleu Silver may modify or update this Personal Data Charter.
Any updates will be posted in places deemed appropriate, so that any user will be notified of the date of the last update.