IBehavior Privacy Policy

This section explains the rules for implementing personal data processing operations carried out by Conexance in the course of its business.

In the interest of adhering to rules on individual privacy, Conexance undertakes to comply with the provisions of Act 78-17 of 6 January 1978 on Information Technology and Civil Liberties, and with Regulation 679/2016 of 27 April 2016 on data protection.

1 WHAT IS PERSONAL DATA?

Personal data is defined as any information relating to a directly or indirectly identified or identifiable data subject by reference to an identifier, such as a name, an identification number, location data, an online identifier or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

2 WHAT IS THE STATUS OF CONEXANCE?

As part of the data collection directly through the "Contact" form, CONEXANCE is data controller. As controller, CONEXANCE undertakes to take the necessary measures to ensure the security and confidentiality of the personal data collected. CONEXANCE also undertakes to collect and process data in a lawful, fair and transparent manner.

As part of its marketing activities, CONEXANCE is a data processor. As a data processor, CONEXANCE undertakes to pursue the necessary measures to ensure the security and confidentiality of the personal data gathered by its clients. CONEXANCE processes the personal data of data subjects only when instructed to do so and on behalf of its clients.

3 WHO IS THE DATA PROTECTION OFFICER?


The Data Protection Officer designated by CONEXANCE is the law firm BRM Avocats, which can be contacted at the following address:

  • Postal address :
    DPO Conexance
    28 Place de la Gare
    59000 Lille

  • E-mail address: dpo@conexancemd.com

4 CONEXANCE AS A DATA CONTROLLER

-> How does Conexance obtain the data?

CONEXANCE collects data directly from individuals via the “Contact” form. This data is necessary to process the contact request.

-> For how long does Conexance store the data?

Pursuant to Article 5e of Regulation 2016/679 of 27 April 2016, personal data are only stored in a form which enables identification for a period not to exceed the duration necessary for the purposes for which they are collected and processed. The data collected through the contact form will be kept for 3 years following the last contact with CONEXANCE.

5 CONEXANCE AS A DATA PROCESSOR

-> How does Conexance obtain the data?

CONEXANCE, as a data processor, does not collect data from data subject. Database owners collect the data from individuals and then submit their databases to CONEXANCE.

The personal data that Conexance processes come from the owners of databases relating to the following business sectors:

  • Apparel
  • home and garden
  • collectables
  • food and wine
  • gadgets and gifts
  • entertainment
  • health and beauty
  • travel and leisure

-> Why does Conexance use personal data?

As a data processor, CONEXANCE helps its clients optimise their marketing campaigns by conducting statistical analyses with the goals of:

  • targeting the most promising prospective customers for an advertising campaign promoting a product or service
  • identifying those individuals in the customer database who are likely to make repeat purchases from the client.

Marketing campaigns may, at the client's request, be carried out by post, by email, by SMS or by advertising on Internet sites.

To execute these processing operations, CONEXANCE acts exclusively at the request of its clients and on their behalf. CONEXANCE never has any contact with the individuals. After CONEXANCE has completed its selection of individuals, their contact information is forwarded to post and/or email routers or to the online targeting platforms designated by the client.

-> For how long does Conexance store the data?

Pursuant to Article 5e of Regulation 2016/679 of 27 April 2016, personal data are only stored in a form which enables identification for a period not to exceed the duration necessary for the purposes for which they are collected and processed.

As such, the data are only stored by CONEXANCE for the period indicated by its client. In the absence of specific instructions from the client, CONEXANCE has established strict rules to respect the rights and privacy of individuals and, consequently, any individual whose last transaction with a client dates to over 5 years ago shall not be retained by CONEXANCE for its analyses.

6 HOW DOES CONEXANCE SECURE THE DATA?

Pursuant to Article 32 of Regulation 2016/679 of 27 April 2016, CONEXANCE undertakes to maintain data security and confidentiality.

To do this, CONEXANCE has defined a strict security policy for personal data. In particular, this policy makes it possible to:

  • implement data encryption procedures to protect any database containing personal information which enters or exists the CONEXANCE information system.
  • secure work stations with unique user ids and strong passwords
  • limit the number of employees who have access to databases containing personal information
  • ensure that its own subcontractors comply with personal data regulations
  • regularly test the information system to check that it has a high level of security.

7 HOW DOES DATA SUBJECTS EXERCISE THEIR RIGHTS ?

7.1 General rules

All data subjects whose personal data is subject to processing have the ability to exercise their rights to access, correct, erase and object to the processing of their data in accordance with Articles 15 and seq of Regulation 2016/679 of 27 April 2016. Data subjects may also exercise their right to the portability of their personal data. Any data subject can also transmit post-mortem instructions. Data subjects can also lodge a complaint with a supervisory authority (ICO).

These rights may be exercised directly by contacting the CONEXANCE client which gathered the personal data or the entity organising the advertising campaign. A response must be issued within 1 month.

You may also contact CONEXANCE in writing at the following address: Conexance, 28 Place de la Gare, 59000 Lille or by email at: dpo@conexancemd.com

In order to comply with the aforementioned regulation, CONEXANCE has established a no-call database which makes it possible not to contact the data subject who do not wish it.

If you do not wish to be contacted by a Client of CONEXANCE, you may contact us at the address provided and tell us which contact details you wish to register in this no-call database.

7.2 Rules pertaining to emails

When instructed by the owner of a database, CONEXANCE may be called on to send email addresses to its clients.

As a result, a natural person included in the database of a database owner may be contacted by a CONEXANCE client for commercial prospecting.

CONEXANCE 's clients work in several business sectors, including:

  • Apparel
  • home and garden
  • collectables
  • food and wine
  • gadgets and gifts
  • entertainment
  • health and beauty
  • travel and leisure

CONEXANCE never has direct contact with the data subject, such that CONEXANCE neither collects the email address from the person nor sends emails to said person.

However, in order to comply with the aforementioned regulation, CONEXANCE has established a no-call database which makes it possible not to contact data subjects who do not wish it.

If you do not wish to be contacted by a Client of CONEXANCE, you may contact us at the address provided in 7.1 and tell us which email addresses you wish to register in this no-call database.

Cookie Policy

1 WHY DOES CONEXANCE USES COOKIES?

As a data processor, Conexance may use cookies in two scenarios:

  • to enable a client to gather browsing data about the individuals who visit its website;
  • to enable a client to display targeted advertisements on the websites visited by individuals;

When you visit Conexance website, cookies may be placed on your device. These are technical cookies placed by our host. These cookies do not collect any data about your browsing.

2 HOW LONG COOKIES ARE STORED?

The period of validity of consent to the deposit of cookie be extended to 13 months maximum. At the end of this period, consent will be obtained again.

As a result, cookies have a limited lifetime of 13 months after they are first stored in your terminal equipment.

3 WHAT ARE YOUR CHOICES REGARDING COOKIES?

3.1 Configuring the website visited

When browsing websites, you must have the ability to setup your cookie preferences by clicking on the cookie banner and consulting the website's cookie policy.

3.2 Configuring the web browsing software

You can configure your web browsing software so that cookies are saved in your device or, on the contrary, are blocked ‒ either systematically or depending on their source. You may also configure your web browsing software so that you are prompted each time to allow or block cookies before a cookie can be saved to your device.

How do you implement your preference based on the browser you use?To manage cookies and your preferences, each browser is configured in a different way. It is described in your browser's help menu, which will explain to you how to modify your cookies preferences.

For Internet Explorer™ : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
For Safari™ : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
For Chrome™ : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
For Firefox™ : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html etc.

3.3 Declining online cookies

When instructed by its clients, Conexance may send information to online targeting platforms to display targeted advertisements to individuals.

You have the option to object to the storing of cookies by visiting the website http://www.youronlinechoices.com/fr/controler-ses-cookies/.

Conexance may use, on behalf of its clients, Liveramp services for online advertising targeting. You have the right to object to this processing by visiting the following website: https://liveramp.com/opt_out/

For more information about cookies, you may consult the CNIL website: https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/

Last Update: September, 2018