Security and Protection of Personal Data
This Privacy Policy applies to Personal Information that KLH collects with your consent or automatically when you visit our Platform or use our Services. Below, we explain why and how we process your Personal Information. This Privacy Policy is effective as of 06/05/2020. We may update this Privacy Policy at any time and will inform you of these changes via email or any other electronic notification method shortly before they take effect.
Definitions
The Publisher: The person, whether physical or legal, who publishes online public communication services.
The Site: All sites, web pages, and online services provided by the Publisher.
The User: The person using the Site and services.
How to Contact Us?
You can contact us in several ways:
- By sending a letter to the following address: 62 rue Jacques Rousseau 75001 Paris.
- By emailing our data protection officer at: contact@klh-agency.com.
- By using our contact form.
Nature of the Data Collected
In the context of using the Sites, the Publisher may collect the following categories of data about its Users:
- Civil status, identity, identification data…
- Economic and financial information (income, financial situation, tax situation…)
Communication to Authorities Based on Legal Obligations
Based on legal obligations, your personal data may be disclosed pursuant to a law, regulation, or decision from a competent regulatory or judicial authority. In general, we commit to complying with all legal rules that may prevent, limit, or regulate the dissemination of information or data, particularly in accordance with the Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms.
Personal Data Reuse Conditions
No commitment on the viral nature of personal data reuse conditions.
In the event of sharing your personal data with a third party, the third party’s privacy policy applies.
Collection of Prior Opt-In (Consent) for Data Transmission After a Merger/Acquisition
In the event we participate in a merger, acquisition, or any other form of asset transfer, we commit to obtaining your prior consent for the transmission of your personal data and maintaining the level of confidentiality of your data that you have consented to.
Purpose of Reusing Collected Personal Data
- Performing client management operations related to contracts, orders, deliveries, invoices, accounting, and particularly client account management
- Loyalty programs within one or more legal entities
- Managing client relationships, such as satisfaction surveys, complaint handling, after-sales service
- Selection of clients for studies, surveys, and product testing (unless consent from the individuals concerned is collected in accordance with Article 6; these operations should not result in creating profiles that may reveal sensitive data such as racial or ethnic origins, philosophical, political, union, religious opinions, sexual life, or health information)
Performing Prospecting Operations
- Managing technical prospecting operations (including standardization, enrichment, and deduplication)
- Selecting individuals for loyalty, prospecting, survey, product testing, and promotional actions. (Unless consent is obtained from individuals as per Article 6, these operations should not lead to creating profiles revealing sensitive data)
- Soliciting operations
Managing feedback from individuals on products, services, or content
Aggregation with Non-Personal Data
We may publish, disclose, and use aggregated information (information related to all our Users or specific groups of Users that we combine in such a way that an individual User cannot be identified) and non-personal information for industry analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.
Aggregation with Personal Data Available from the User’s Social Accounts
If you link your account to another service’s account for cross-posting, that service may provide us with your profile information, login data, and any other information you have authorized for disclosure. We may aggregate information about all our Users, groups, accounts, and personal data available about the User.
Collection of Identity Data
Free Consultation
Consultation of the Site does not require prior registration or identification. It can be done without providing any personal data (name, surname, address, etc.). We do not collect any personal data for simple consultation of the Site.
Use of User Identifier Only for Service Access
We use your electronic identifiers solely for and during the execution of the contract.
Collection of Profiling and Technical Data for Service Provision
Some technical data from your device is automatically collected by the Site. This includes, in particular, your IP address, Internet service provider, hardware configuration, software configuration, browser type and language… Collecting this data is necessary for providing services.
Collection of Technical Data for Advertising, Commercial, and Statistical Purposes
The technical data from your device is automatically collected and recorded by the Site for advertising, commercial, and statistical purposes. This information helps us personalize and continually improve your experience on our Site. We do not collect or store any personal data (name, surname, address, etc.) attached to technical data. The data collected may be resold to third parties.
Cookies
Cookie Retention Period
In accordance with CNIL recommendations, the maximum retention period for cookies is 13 months after their first placement on the User’s device, just as the validity period of the User’s consent to the use of these cookies. The cookie’s lifespan is not extended with each visit. The User’s consent must be renewed at the end of this period.
Cookie Purpose
Cookies may be used for statistical purposes, particularly to optimize services for the User, based on processing information about access frequency, page personalization, and operations performed.
User’s Right to Refuse Cookies
You are informed that the Publisher may use cookies. If you do not wish to use cookies on your device, most browsers allow you to disable cookies through settings options.
Retention of Technical Data
Technical Data Retention Period
- Technical data is retained for the time strictly necessary to achieve the purposes mentioned above.
Personal Data Retention and Anonymization Period
In accordance with Article 5, section e, of Regulation 2016/679 of April 27, 2016, KLH retains data in a form that allows identification of the individuals concerned for no longer than necessary to achieve the purposes for which it is processed.
- Prospective data (including newsletters) is kept for a maximum of 3 years from the last contact date.
- Client data is retained for 3 years after the end of the contractual relationship.
- Legally required data is kept in accordance with applicable laws.
User Notification in Case of Security Breach
We commit to implementing all appropriate technical and organizational measures to ensure a security level adapted to the risks of accidental, unauthorized, or illegal access, disclosure, alteration, loss, or destruction of your personal data. In the event we become aware of illegal access to your personal data stored on our servers or those of our providers, we commit to:
- Notifying you of the incident as soon as possible;
- Examining the causes of the incident and informing you;
- Taking necessary measures within reasonable limits to mitigate the negative effects and damages resulting from the incident.
Limitation of Liability
The commitments above regarding the notification of a security breach cannot be interpreted as any admission of fault or responsibility regarding the occurrence of the incident.
Transfer of Personal Data Abroad
No Transfer Outside the European Union: The Publisher commits not to transfer Users’ personal data outside the European Union.
Modification of the Terms of Use and Privacy Policy
In case of modification of these Terms of Use, we commit to not lowering the level of confidentiality substantially without prior information to the concerned individuals. We commit to informing you in case of a significant modification of these Terms of Use and to not lowering the confidentiality level of your data substantially without notifying you and obtaining your consent.