COMMOPRICES acts as a subcontractor and as such, collects, uses and processes on behalf of the Subscriber the data entrusted to it by and on the instructions of the Subscriber.
The personal data (hereinafter referred to as the "Personal Data") that COMMOPRICES collects on behalf of the Subscriber relates to the authorized persons of the Subscriber's staff using the Platform (hereinafter referred to as the "Users").
COMMOPRICES also acts as a data controller and as such, collect, use and process data on its own behalf, in particular to provide a service adapted to the Subscriber and ensure the proper functioning of the Platform.
COMMOPRICES undertakes to comply with the applicable regulations on the protection of Personal Data and in particular the obligations arising from the European Regulation No. 2016/679 on the Protection of Personal Data (hereinafter referred to as the "GDPR").
The communication of the Personal Data is mandatory and strictly necessary for the proper functioning of the Platform and the Services. Otherwise, the Services cannot be provided.
1.1 Throughout the use of the Platform and the Services, COMMOPRICES may collect on behalf of the Subscriber and according to his/her instructions, any information, directly or indirectly identifying the Users.
1.2 Personal Data can be collected directly when the User communicates them to COMMOPRICES through the User account creation forms on the Platform. When connecting at the first time, the User expressly consents to the processing of his/her Personal Data within the limits of a processing strictly necessary for the proper functioning of the Platform and the Services. The communication of nominative information is mandatory in order to provide the User with an identifier and password for access to the Platform.
This includes Personal Data relating to the identity of the User and in particular: surname, first name, email address, telephone number.
COMMOPRICES (including its technical service providers) may also automatically collect:
COMMOPRICES uses, stores and processes Personal Data for the following purposes:
|Purpose||Controller||Legal basis of the processing|
|Creation and management of an account on the Platform||Subscriber||The processing is necessary for the execution of the contract between the User and the Subscriber and the contract between the Subscriber and COMMOPRICES.|
|Access and use of the Services on the Platform by the User||Subscriber||The processing is necessary for the performance of the contract between the User and the Subscriber and the contract between the Subscriber and COMMOPRICES.|
|Answer to possible questions/complaints from Users - Assistance||Subscriber||The processing is necessary for the performance of the contract between the User and the Subscriber and the contract between the Subscriber and COMMOPRICES.|
|Management of requests for access, portability, deletion, rectification and opposition rights||Subscriber and COMMOPRICES||User Data: The processing is necessary for the performance of the contract between the User and the Subscriber and the contract between the Subscriber and COMMOPRICES.|
|Dispute Management||COMMOPRICES||The processing is necessary for the performance of the contract between the User and the Subscriber and the contract between the Subscriber and COMMOPRICES.|
|Development, improvement of the Platform, creation of an environment of trust||COMMOPRICES||The processing is necessary for the legitimate interests pursued by COMMOPRICES.|
|Commercial prospecting||COMMOPRICES||The processing is carried out on the basis of the User's|
|Audience rating||COMMOPRICES||The processing is necessary for the purposes of the legitimate interests pursued by COMMOPRICES.|
Lastly, COMMOPRICES reserves the right to review, browse or analyze Personal Data, including communications exchanged between COMMOPRICES and Users through the Platform, to comply with its legal obligations and in particular for fraud prevention, risk assessment, regulatory compliance and investigation purposes.
Personal Data is kept only as long as necessary to fulfill the purpose for which COMMOPRICES holds the data, to meet the Subscriber's needs or to fulfill its legal obligations.
At the end of the applicable periods and no later than six (6) months after the end of the use of the Services by the User or after the end of the commercial relationship between the Subscriber and COMMOPRICES, the Personal Data will be destroyed or COMMOPRICES will proceed to their anonymization.
However, COMMOPRICES may keep certain Personal Data collected on separate storage spaces in order to comply with its legal or regulatory obligations. The data stored in this way will be limited to what is strictly necessary.
4.1 COMMOPRICES may disclose Personal Data to administrative and judicial authorities, or to authorized third parties, if required or permitted by law, or if such disclosure is reasonably deemed necessary: (i) to comply with COMMOPRICES' legal obligations, (ii) to comply with legal procedure and in response to claims against COMMOPRICES or the Subscriber, (iii) to respond to verified requests in connection with a legal investigation or alleged or suspected illegal activity or any other activity that may expose COMMOPRICES or Subscriber to legal liability.
4.2 Subject to the Subscriber's authorization, COMMOPRICES may subcontract all or part of the execution of the Services in accordance with the legal provisions in force.
In this context, COMMOPRICES will not transfer Personal Data to third parties established outside the European Union that do not offer an adequate level of protection with regard to legal requirements for the protection of Personal Data.
This includes COMMOPRICES' service providers that support COMMOPRICES' business such as:
Any subcontractor of COMMOPRICES (hereinafter referred to as the "Subsequent Subcontractor") will be permitted to process on behalf of COMMOPRICES the Personal Data necessary to provide the Services to the Subscriber.
COMMOPRICES affirms to:
COMMOPRICES undertakes to ensure that the Subcontractor will:
Only with the express consent of the Subscriber, COMMOPRICES may reuse Personal Information or transmit it to partner companies for the purpose of sending commercial information by e-mail.
COMMOPRICES affirms that it will receive from the Subsequent Contractor all documentation necessary to demonstrate compliance with its obligations and to allow for audits, including inspections, by COMMOPRICES or another auditor it has appointed, and to contribute to such audits.
COMMOPRICES shall remain solely responsible for the provision of the Services entrusted to a Subsequent Contractor.
5.1 REUSSIR ensures that Personal Data is adequately and appropriately secured and has taken all necessary precautions to preserve the security and confidentiality of the data and in particular to prevent it from being distorted, damaged or communicated to unauthorized persons.
The Personal Data collected is captured and processed in computer systems under the responsibility of REUSSIR. REUSSIR's concern is to preserve the confidentiality, quality and integrity of the data. The technical means implemented respect the best security practices in force. The technologies and security policies used protect Personal Data from unauthorized access or improper use.
Only authorized REUSSIR employees have access to data and are subject to confidentiality obligations imposed by our internal policy. REUSSIR only transfers Personal Data to authorized subcontractors.
When REUSSIR becomes aware of a breach of rights in the processing of Personal Data, it will notify the CNIL within a period of no more than seventy-two (72) hours after becoming aware of the breach.
Any violation relating to the processing of Personal Data will be notified by e-mail, within one (1) month, by COMMOPRICES to the Subscriber and the User involved.
5.2 In all cases, the persons involved have the right to access, rectify, modify, oppose, portability and delete Personal Data. These rights must be exercised directly by the Subscriber who will contact COMMOPRICES by email at email@example.com, or by post at 1 rue Léopold Sédar Senghor 14460 Colombelles, France, for the attention of the Data Protection Officer (DPO), indicating the surname, first name and/or company name, home address or registered office, email address and telephone number of the person concerned.
In accordance with the regulations in force, all requests must be signed and accompanied by a photocopy of an identity document bearing the User's signature, upon request by COMMOPRICES.
The person involved will be able to retrieve his/her Personal Data in an open and readable format. The right to portability is limited to the data provided by the Subscriber. It applies on the basis of the prior consent of the person involved. COMMOPRICES undertakes to transfer, upon request, within one (1) month, any document collecting Personal Data to the Subscriber in order to implement the right to portability. The costs related to the recovery of the data are the responsibility of the Subscriber.
6.2 Some cookies are essential for the User to take advantage of all the features of the Platform and do not collect confidential information about the Users.
In accordance with the CNIL deliberation n° 2013-378 of December 5, 2013, COMMOPRICES informs Users that cookies record certain information that is stored in the memory of their computer hardware/equipment. This information is used to improve the use and operation of the Platform, but also to understand how the Platform is used by Users, as well as the tools and Services that COMMOPRICES makes available to them. An alert message informs each person visiting the Platform of the presence of these essential cookies.
6.3 The Platform also uses third party cookies for non-essential purposes to understand how the Platform works and how the User interacts with the Platform, to provide advertisements that are relevant to the User and overall to provide a better and improved User experience and to speed up future User interactions with the Platform.
6.4 To ensure the User's free, informed, and unequivocal consent, the User visiting the home page or another page of the Platform directly from a search engine will be informed of:
Unless the User gives his/her prior consent, cookies will not be deposited or read.
6.5 The User may at any time choose to deactivate cookies and other tracers. The User's browser can be configured to notify him/her of cookies that are deposited in his/her terminal and to ask him/her to accept them or not.
The configuration of each browser is different. It is described in the browser's help menu, which will allow the User to know how to modify his/her wishes regarding cookies.