Privacy policy
What is the purpose of this policy?
We take the protection and confidentiality of your personal data very seriously. It is, for us, a fundamental matter of integrity and trust.
This privacy policy sets out our commitment to complying with applicable data protection legislation, including the General Data Protection Regulation ("GDPR").
It explains, in particular, what personal data we collect, why we collect it, and how we use it in connection with the services we provide.
Who is this policy for?
This policy applies to you, regardless of your place of residence, provided you are at least 15 years old, whether you are a customer, a job applicant, or a visitor to www.anaba.fr.
If you are under 15, you may not use our services without the prior and explicit consent of a parent or guardian, which must be submitted in writing to dpo@anaba.fr. If you believe we may hold information about a child under 15 without your consent, you may request its deletion at dpo@anaba.fr.
This policy only covers the processing we carry out ourselves. It does not apply to any processing performed by Anaba users through the features of our service. For information about data processed by Anaba users, please contact them directly.
Why do we process your data?
As part of the services we offer, we process your personal data for the following purposes and legal bases:
- To allow you to browse our website www.anaba.fr, access and use our services (e.g. managing campaigns, importing leads, managing your appointments) and to respond to your requests (e.g. requests for information, complaints), based on our terms and conditions and our legitimate interest in providing you with the best possible service.
- To keep you informed of our latest offers and events by phone and email, based on our legitimate interest in retaining existing customers and reaching new ones.
- To give you access to our loyalty programme, based on our terms and conditions of sale.
- To allow you to follow us and engage with our publications on social media, based on the terms of use of the relevant platform (e.g. Facebook) and our legitimate interest in maintaining an active social media presence.
- To provide you with access to our instant messaging, based on the publisher's terms of use and our legitimate interest in communicating with you easily.
- To process your job application at Anaba, based on our discussions during the recruitment process and our legitimate interest in recruiting and selecting candidates.
- To allow you to book an appointment with our teams, based on the publisher's terms of use and our legitimate interest in providing you with a simple and effective booking tool.
- To ensure the security and quality of our services on an ongoing basis (e.g. analytics, data security), based on our legal obligations, our terms and conditions, and our legitimate interest in maintaining the proper functioning of our services.
- Finally, we may also place Cookies on your device. For more information, please refer to our Cookie Policy.
Your data is collected directly from you when you access our website and use our services.
We are committed to processing your data solely for the purposes described above, and we guarantee that your data will never be sold to any partner or third party.
When you voluntarily publish content on our social media pages, you acknowledge that you are solely responsible for any personal information you share, regardless of its nature or origin.
What data do we process and for how long?
The table below summarises the categories of personal data we collect and their respective retention periods.
For further details about the retention periods applicable to your data, please contact us at: dpo@anaba.fr.
- For Anaba users and prospects targeted through Anaba: professional identification data (e.g. name, job title, company) and contact details (e.g. professional email address, LinkedIn profile) retained for the duration of the service.
Please note that Anaba acts as a data processor within the meaning of Article 28 of the GDPR. As such, Anaba does not process prospect data directly, as campaigns are managed by Anaba users. If you are a prospect and wish to obtain information about the data processed by Anaba users, please contact them directly. In the exceptional case where you are unable to identify them, you may submit a request to Anaba at dpo@anaba.fr, and we will endeavour to respond within a reasonable timeframe.
- Where your business name coincides with your personal name (e.g. sole trader, freelancer): financial and banking data (e.g. bank account number, verification code) retained for the duration of the transaction and for invoicing and payment management purposes, plus applicable statutory limitation periods, generally between 5 and 10 years.
- Data processed for commercial and marketing purposes (e.g. email address) retained for a maximum of 3 years from the date of our last interaction with you.
- Data contained in your CV and cover letter retained for the duration of the recruitment process, then for 2 years from the date of your application.
- Connection data (e.g. logs, IP address) retained for a period of 1 year.
- Cookies, generally retained for a maximum of 13 months. For further details on how we use cookies, please refer to our Cookie Policy, available at any time on our website.
Upon expiry of the retention periods set out above, we will permanently delete all your personal data in order to protect your privacy going forward.
Deletion of your personal data is irreversible and we will no longer be able to provide it to you thereafter. We may only retain anonymised data for statistical purposes.
Please also note that in the event of litigation, we are required to retain all data relating to you for the entire duration of the proceedings, even after the expiry of the standard retention periods set out above.
What rights do you have to control the use of your data?
Applicable data protection legislation grants you specific rights that you may exercise at any time and free of charge to control how we use your data.
- Right of access and copy of your personal data, provided such a request does not conflict with business secrecy, confidentiality obligations, or professional privilege.
- Right to rectification of personal data that is inaccurate, outdated, or incomplete.
- Right to object to the processing of your personal data for commercial prospecting purposes.
- Right to request erasure ("right to be forgotten") of your personal data that is not essential to the proper functioning of our services.
- Right to restriction of processing, which allows you to suspend the use of your data in the event of a dispute as to the lawfulness of the processing.
- Right to portability of your data, which allows you to retrieve part of your personal data in order to store or transfer it from one system to another.
- Right to give instructions regarding the handling of your data in the event of your death, either directly, through a trusted third party, or through a designated beneficiary.
For a request to be considered, it must be submitted directly by you to dpo@anaba.fr. Any request submitted by another means cannot be processed.
Requests may only be submitted by you personally. We may therefore ask you to provide proof of identity if there is any doubt as to the identity of the person making the request.
We will endeavour to respond to your request as promptly as possible, and in any event within three months of receipt, where the request is technically complex or where we receive a high volume of requests simultaneously.
Please note that we reserve the right to refuse any request that is manifestly unfounded or excessive, in particular where it is repetitive in nature.
Who can access your data?
We only share your data with individuals duly authorised to process it in connection with the delivery of our services. This may include our staff responsible for service operations, accounting, marketing, and premises security.
How do we protect your data?
We implement all appropriate technical and organisational measures to ensure the security of your data on an ongoing basis, and in particular to protect against any risk of destruction, loss, alteration, or unauthorised disclosure (e.g. staff training, access controls, password policies, antivirus software, backup servers, HTTPS encryption, etc.).
Can your data be transferred outside of the European Union?
Unless strictly necessary and in exceptional circumstances, we never transfer your data outside the European Union. Your data is always hosted on European soil and we endeavour to work exclusively with service providers who store your data within the European Union.
In the event that any of our service providers are nonetheless required to transfer your personal data outside the European Union, we ensure that they have in place appropriate safeguards to guarantee the confidentiality and protection of your data.
Who can you contact for more information?
Our Data Protection Officer ("DPO") is always available to provide further information on how we handle your data and to answer any questions you may have at the following address: dpo@anaba.fr.
How can you contact the CNIL?
You may contact the French data protection supervisory authority (the "Commission Nationale de l'Informatique et des Libertés" or "CNIL") at any time at the following address: CNIL Complaints Department, 3 place de Fontenoy, TSA 80751, 75334 Paris Cedex 07, or by telephone at +33 1 53 73 22 22.
Can the policy be changed?
We may update this privacy policy at any time to reflect changes in applicable legal requirements or new processing activities we may implement in the future. You will of course be notified of any such changes.
Posted on 25/11/2022
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