Global Privacy Policy -  Personal data protection policy and cookies

Your privacy is important to us at Skaleet. We collect and process your data exclusively following the laws and regulations applicable in France as well as with the European General Data Protection Regulation (GDPR). This privacy policy explains the nature, scope, and purpose of the collecting and processing of your personal data.

     1. Data controller/contact

The data controller mentioned in this document is the software and fintech company Skaleet, a public limited company with a board of directors with a capital of € 1,167,029.31, whose head office is located at 88, rue du dôme, 92100 BOULOGNE-BILLANCOURT. Registered in the Nanterre Trade and Companies Register, under number 484 939 038 and of which Mr. Yves Eonnet, Chairman and Chief Executive Officer, is the legal representative.

As part of its business activity, the company Skaleet collects and processes information, some of which is qualified as "personal data". Skaleet imputes importance to privacy respect, and only uses data responsibly and confidentially and for a specific purpose.

The Data Protection Officer (DPO) at Skaleet is Hervé Manceron.

If you have any questions or suggestions regarding data protection, please do not hesitate to contact us:

• by email: data@skaleet.com
• by phone: +33 1 46 10 98 30

     2. Purpose of data protection 

The purpose of data protection is personal data. Personal data is described by the CNIL as "any information relating to an identified or identifiable natural person". When an or set of operations relating to personal data is carried out, it is considered to be the processing of personal data.

     3. The Legal basis 

The legal basis for processing is what legally authorizes its implementation, which gives an organization the right to process personal data. 

As part of Skaleet, personal data is collected after the mandatory consent of the user. This consent is adequately collected (buttons and checkboxes), free, clear, and unequivocal following the applicable conditions defined in Articles 4 and 7 of the GDPR.

     4. Collecting your personal data  

On this website, various personal data may be collected.

          4.1. The data you send us directly

During the various contacts we have with you, you may need to provide us with information that concerns you.

These data are:

• Names, first names, civility; 
• E-mail address, phone number;
• Information necessary for the delivery of an ordered product;
• Username and encrypted password used to identify you on our sites or our applications;
• Choice in business prospecting;
• Any other information that you wish to bring our attention.

          4.2. The data we collect during our business relationship

The data that we collect during our business relationship with you include the following:

• Information relating to the history of your business relationship;
• Your attendance in events;
• The request you have made to our customer service or the incidents you have reported to us;
• Information concerning the purchases of products and services that you have made from our partners. 

          4.3. The data we collect automatically 

During each of your visits to our sites and applications, we collect information about your connection and your browsing. Different technologies can be used to collect this data. We refer to them generically as a "cookie".

– Data collected by standard Internet technologies 

We are also likely to use standard Internet technologies, such as scripts, pixels, and redirects. Scripts (sometimes called tags), written in javascript, are programs that run in your browser or mobile application and perform various actions, such as sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs, or web bugs) are lines of code that allow a graphic image (usually invisible) to be displayed on a web page or in an email. Redirects are used to make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

The purpose of these technologies is to improve your experience on our sites and applications, including providing you personalized content. For example, when a user clicks a share button on an article, a script creates a pixel that counts the share. Thus, we can know the total number of shares of a new, and we can establish the ranking of the most shared articles.

These technologies give us access to the following information:

• Information relating to your use of our sites and applications; 
• Information identifying the presence of cookies on your device, the time and date of viewing a page, and a description of the page where the web beacon is placed; 
• Information on whether or not you read the e-mails we send you on the clicks you make on the links contained in these e-mails;

• Our sites and mobile applications may also include scripts, pixels, and redirects from third parties. These technologies allow third-party service providers to collect certain information such as your browser type and the web page that referred you to our websites or mobile applications. These third-party service providers process the information they collect for audit, research, and reporting purposes about our sites and applications and the advertisements viewed on them. We do not share your identification data with these third parties as part of their use of these technologies.

– Data provided by mobile devices 

Some mobile devices, depending on the permissions you have granted to the mobile application and which you can modify at any time (for example: "notification" or "Geolocation"), send information: your phone model, version its operating system, type of connectivity, name, and version of the application used.

This data are processed by our servers, and those of our partners (in particular Google Analytics), to be able to provide you a service and advertising adapted to the technical characteristics of your device and to measure the audience of our mobile applications.

 If you have accepted this feature (geolocation), we can identify the physical location of your device, especially to inform you about the content or offers that we think are in line with your expectations. Following applicable law, geolocation functions can be deactivated at any time in the settings of your device.

          4.4 The data we guess

We are likely to establish presuppositions about the content and services able to meet your expectations or your uses.

          4.5. Data relating to minors

In theory, our products and services are aimed at adults capable of entering into contractual obligations.

The minor user must obtain the consent of his legal guardian before communicating personal data concerning him.

For registration on our sites and some of our online services (eg newsletter), the age of 16 is accepted.

A user under the age of 18 at the time of publication or creation of an online account has a specific right to erase data concerning him.

          4.6. Data relating to a third party

Before entering the data of a third party on our sites or applications, you must ensure that the person concerned accepts that their data, including contact details, are communicated to us.

          4.7. Exclusion of any sensitive data

Skaleet does not collect any sensitive data about you. The following are considered sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, data relating to health or sexual orientation.

     5. Purposes of processing

At Skaleet, data is collected for a well-defined and legitimate purpose and is not processed in a manner incompatible with the initial goals. Data processing for the following purposes:

          5.1. Purposes necessary for the distribution of products or services

• Management of subscriptions to our newsletters and/or e-mail alerts;
• Management of deliveries and follow-up of orders;
• Customer relations: provision of a Customer Service accessible by mail, telephone, e-mail, or chat-type instant messaging, for any question or complaint;
• Carrying out satisfaction surveys;
• Sending of information on the modification or evolution of our services;
• Management of your rights over your data;
• Verification of compliance with applicable legislation, our contracts, and general conditions of use.

          5.2. Marketing and business prospecting purposes relating to Skaleet publications, products, and services

• Compliance with postal standards, updating, enrichment, and deduplication of your personal information in a dedicated database;
• Sending information about our press group, its publications, and its activity;
• Sending of marketing, advertising, and promotional offers relating to our products and services by post, asylum, e-mail, mobile notifications, on social networks or any other medium;
• Personalized customer loyalty or prospecting actions;
• Setting up of contests or other promotional operations;
• Collection of customer opinions;
• Development of business statistics.

          5.3. Purposes related to business partnerships 

• Sharing, exchange, or rental of files with business partners in compliance with current regulations and security requirements;
• Sending of marketing, advertising, and promotional messages relating to products and services of partners by post, silage, e-mails, mobile notifications, on social networks or any other medium;
• Setting up of contests or other promotional or event operations with business partners.

          5.4. Purposes associated with the deposit of cookies on your browser

– Operation and optimization of browsing on our sites and applications

• Adaptation of the layout of our sites and applications to the display preferences of your device (language used, display resolution, operating system, etc.) during your visits, depending on the hardware and software for viewing or reading that your device contains;
• Memorization of information relating to a form that you have completed on our site (registration or access to your account) or to products, services, or information that you have chosen on our site (subscribed service, content viewed, purchase made, etc. );
• Automatic connection to reserved or personal areas of our site, such as your account, using identifiers or data that you have previously entrusted to us;
• Provision of sharing tools on social networks;
• Management of our platforms and performance of internal technical operations in the context of problem-solving, data analysis, tests, research, analyzes, studies and surveys;
• Implementation of security measures;
• Quality measures to ensure that the display of our content is suitable for your device.

– Measurement of attendance and audience

• Establishment of statistics and volumes of visits and use of the various elements that make up our site (sections and content visited, routes) to improve the interest and ergonomics of our services;
• Accounting for the total number of advertisements displayed by us on our advertising spaces, ranking, and statistics;
• Analysis of audiences based on the results of advertising campaigns;
• Determination of interests and behaviors;
• Improved customer/user knowledge for personalization purposes.

– Personalization of the reader journey

• Personalize some of the featured editorial content so that it corresponds to the reader's supposed centers of interest;
• Personalize the offers of products and services offered;
• Measure the effectiveness of our personalization services.

     6. The data retention period

Your data are kept for a period following legal provisions, or proportional to the purposes for which they were recorded.

* All data from active customers is kept during the contractual relationship and can be kept for ten (10) years after the end of the contractual relationship to meet accounting and tax obligations.

 * The data of prospects who are natural persons may be kept for up to three (3) years after the last contact from the prospect.

* The data related to your browsing on our online services collected by the cookies that you have authorized have a specific retention period of thirteen (13) months.

* The assumed data is updated annually.

* The data is then anonymized and can be used for statistical purposes.

In any event, we regularly review the information we hold. When their retention is no longer justified by legal, commercial, or customer account management requirements, or if you have made use of a right of modification or erasure, we will delete them securely.

     7. Recipients of the data collected 

Your data are used by identified and authorized persons taking into account the purposes described in this personal data protection policy. Skaleet never undertakes to transmit your data to third parties for reasons unrelated to these purposes.

          7.1. Security and restricted access to data 

Skaleet implements the necessary means to protect the processing of personal data to avoid any access by an unauthorized third party and prevent any loss, alteration, or disclosure of data.

          7.2. Access to data within Skaleet

The following may have access to some of your data:

Employees of customer relations, administration, accounting and management control, IT and marketing & sales departments.

Access to your data is based on individual and limited access grants. The people who can access personal data are subject to an obligation of confidentiality (by a nominal and personal confidentiality commitment).

          7.3. Data transmission 

The following may have access to some of your data:

– The subcontractors

For the distribution of services, we depend on external contracted companies and external service providers ("processors"). In this case, the personal data will be transferred to these subcontractors to enable them to continue processing the data. These subcontractors are carefully selected and regularly checked by us to guarantee the protection of your privacy. Subcontractors may only use the data for the purposes we have specified and are also contractually obligated to process your data following this privacy policy and applicable French and European data protection laws.

They provide services on our behalf:

• Manage your subscription
• Carrying publications
• Managing phone calls, sending postal or digital mail
• Personalization of the content of websites and mobile applications
• Carrying out maintenance and technical development operations
• Collecting customer reviews
• Supply of analytical solutions or audience measurement statistics
• Access to your data by our subcontractors is based on signed contracts mentioning their obligations in terms of data security and confidentiality protection.

– Social media platforms

The use of social networks to interact with our sites and applications (especially the “share” and “connect via” buttons of Twitter, and LinkedIn) are indeed likely to lead to the collection of personal data by the social networks concerned.

For example, if you are connected to the social network LinkedIn and you visit a page of the website address, LinkedIn is likely to collect this information. Likewise, if you visit an article on the website address and click on the "tweet" button, Twitter will collect this information.

We invite you to be careful and to consult the personal data protection policies of these social networks to take precise knowledge of the information that is collected by its sites and applications, as well as the purposes of use of your data, in particular for advertising. You can sometimes set the access and confidentiality of your data directly on the social networks used.

The use of these "social network" buttons is done at your initiative and under your full accountability. Skaleet is not responsible for the processing of your data that will be done by these third party social networks.

– Our business partners

They promote products or services on their behalf or behalf of advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our business partners and you allow them to access some of your information. Cookies are opposable to you. We have no control over the collecting or processing of your data implemented by our business partners on their platform.

– Police authorities, legal or administrative authorities 

If it is necessary to discover or investigate the illegal use of our services, data will be transmitted to law enforcement authorities. However, this only happens if there are specific indications of illegal activity. We are also legally obliged to provide information to certain public authorities upon request. These are law enforcement authorities, authorities that prosecute administrative offenses punishable by a fine, and tax authorities. The transfer of this data is justified by our legitimate interest in preventing abuse, in prosecuting criminal offenses and in obtaining, asserting, and enforcing legal rights, and by the fact that your rights and interests in the protection of your data do not prevail.

          7.4. Transfer outside the European Union

We store your data in the European Union. However, it is marginally possible that the data we collect when you use our platforms or as part of our services may be transferred to subcontractors or business partners located in other countries, some of them, which may have less protective personal data protection legislation than that in force in the country where you reside. In the event of a transfer of this type, we ensure that the processing is carried out following this privacy policy and that it is framed by the standard contractual clauses of the European Commission that make it possible to guarantee a sufficient level of protection of privacy and fundamental rights of individuals.

     8. Cookies

Skaleet stores "cookies" to provide you with a full range of functions and to make the use of our websites more convenient. "Cookies" are small files that are stored on your computer using your Internet browser. If you do not wish to use "cookies", you can prevent "cookies" from being stored on your computer by making appropriate adjustments to your Internet browser. Cookies already stored can be deleted at any time, even automatically. These cookies cannot identify you as a person. 

On the website address, cookies from the following third-parties may be stored:

• Youtube
• Twitter
• LinkedIn
• Google Analytics

When loading our website, we appropriately inform the user about the use of cookies for analytical purposes and ask them to agree to the processing of their data in this regard. Also, we notify the user of this privacy policy and its application.

          8.1. Functional cookies 

Cookies are necessary for the website to operate.

Cookies are essential for the performance of Skaleet sites or applications and for users to navigate on them. They allow people to use the main features of sites or applications and secure their connection. They can also allow them direct access to spaces reserved for them, thanks to credentials or previously recorded data.

These cookies have a very short lifespan, while the session remains active.

Without these cookies, users will not be able to use the sites usually, and it is, therefore, not recommended to prevent their use or to delete them.

The use of these cookies is based on our legitimate statistical interest, evaluation, and efficient use of our website. 

          8.2. User experience optimization cookies

These cookies make it possible to optimize the operating of the Skaleet sites or applications. They also allow the site's presentation to be adapted to the display preferences of the device used by people during their visits. These cookies enable users to have a smooth and personalized navigation.

They have a maximum lifespan of thirteen months.

In case of denial of the implementation of these cookies, users will not be able to benefit from the features described above.

          8.3. Technical performance cookies  

Technical performance cookies allow Skaleet to monitor the technical performance of its sites or applications, to detect problems to reduce inconvenience to the user as much as possible, to activate and support security features, but also to help detect malicious activity and violations of these terms of use.

The lifespan of technical performance cookies is limited to thirteen months.

The fact of denying the implementation of such cookies or of deleting them has no impact on the navigation of people on the sites. It is likely to prevent Skaleet from ensuring the improvement of the quality of the services offered to visitors to its sites.

          8.4. Audience measurement cookies 

Audience measurement and statistical cookies allow Skaleet to know the use and performance of sites, to set statistics, volumes of visits, and use of various elements (content visited, routes, etc.) to improve the value and ergonomics of the services offered (the most frequently consulted pages or sections, the most read articles, etc.). These cookies are also used to measure website consultation traffic. 

– Google Analytics cookies 

Skaleet uses Google Analytics, a site analytics service provided by Google, Inc., headquartered in the United States, at 1600 Amphitheater Parkway, Mountain View, California 94043. Google Analytics is a Google web analytics tool enabling website and application owners to better understand the behavior of their users.

This tool may use cookies to collect information and generate reports on website usage statistics without individual users being personally identified by Google. Information is transmitted, processed, and stored by Google under the terms set by Google. Google can also transfer this information to third parties, due to the legal requirements or when these countries process the information on behalf of Google. The “__ga” cookie is the one most used by Google Analytics.

The collecting information by Google can be deactivated by using the Google module at the following address https://tools.google.com/dlpage/gaoptout?hl=en

Learn more about Analytics cookies and privacy.

The lifespan of audience measurement cookies is limited to thirteen months.

The fact of refusing the implementation of such cookies or deleting them does not affect the navigation of people on the sites. It is likely to prevent Skaleet from ensuring the improvement of the quality of the services offered to visitors to its sites.

          8.5. Advertising cookies 

As part of the navigation on all the pages of sites, Skaleet is likely to process navigation data and/or use advertising cookies to offer visitors advertising in line with their interests. These cookies help limit the number of times a visitor sees an advertisement and are also used by Skaleet to assess the effectiveness of its advertising campaigns.

The lifespan of advertising cookies is limited to thirteen months.

The denial of these advertising cookies does not have an impact on the use of the Skaleet sites.

          8.6. Sharing cookies (social networks)

Skaleet sites may include social media buttons or modules, such as LinkedIn and Twitter, which allow visitors to share content from Skaleet sites with other people or to let others know about your viewing or your opinion about content from our site.

When visitors use these sharing buttons, a third-party social network cookie is installed. If visitors are connected to the social network while browsing the sites, the sharing buttons allow the content viewed to be linked to their user account.

Visitors are invited to consult the privacy protection policies of these social networks to learn about the purposes of use, in particular advertising, the navigation information that they can collect using these application buttons and the duration life of associated cookies.

We use several share buttons on our site.

To manage your data on Twitter

https: //support.twitter.com/articles/20170518-emploi-des-cookies-et-des-technologies-similaires-par-twitter

To manage your data on LinkedIn

https: //www.linkedin.com/legal/cookie-policy? _l = fr_FR

Disabling these cookies, therefore, prevents any interaction with social networks.

          8.7. Managing cookies 

When you access the Skaleet website, we provide you with clear and complete information and ask for your permission regarding the use of cookies. You have the option of accepting or rejecting them.

For more information on the management of cookies, you can refer to this dedicated page of the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

The non-registration of certain cookies may affect the proper functioning of certain features of the site.

     9. Rights exercice 

Following the General Data Protection Regulation of April 27, 2016, each person has the right to access, change, delete and port their Personal Data, and a right to limit and to oppose to the processing of these data.

These rights can be applied by contacting us at the following address:

BY POST : Skaleet - 88 Rue du Dôme, 92100, BOULOGNE-BILLANCOURT

BY EMAIL : marketing@skaleet.com

People also have the right to complain with the CNIL.

Since Law No. 2016-1321 of October 7, 2016, people who have the possibility of organizing their data after their death. For more information on the subject: https://www.cnil.fr/.

     10. Changes to our policy

The current version of this data protection statement is available at any time at the website address. Please note that we may change or update this data protection statement from time to time. We will post the corresponding changes to the link mentioned above.