ARTICLE 1 : PREAMBLE
- The way in which their personal data are collected and processed. All data that can identify a user must be considered as personal data. These include first and last name, age, postal address, e-mail address, user's location or IP address ;
- What are the users' rights regarding this data ;
- Who is responsible for the processing of personal data collected and processed ;
- To whom this data is transmitted ;
- Possibly, the site's cookie file policy.
ARTICLE 2: GENERAL PRINCIPLES IN DATA COLLECTION AND PROCESSING
In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of data from users of the site complies with the following principles:
- Liability, loyalty and transparency: data may only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his data is being collected, and for what purposes his data is being collected ;
- Minimisation of data collection and processing: only the data necessary for the proper execution of the objectives pursued by the site are collected ;
- Storage of data reduced in time: the data are stored for a limited period of time, of which the user is informed. If the storage period cannot be communicated to the user ;
- Integrity and privacy of the data collected and processed: the data controller undertakes to guarantee the integrity and privacy of the data collected.
In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the following conditions listed below:
- The user has expressly consented to the processing ;
- Processing is necessary for the proper performance of a contract ;
- The processing is in accordance with a legal obligation ;
- The processing is necessary in order to safeguard the vital interests of the data subject or another natural person ;
- The processing may be explained by a necessity linked to the performance of a task in the public interest or in the exercise of public authority
- The processing and collection of personal data is necessary for the legitimate and private interests pursued by the controller or by a third party.
ARTICLE 3: COLLECTED AND PROCESSED PERSONAL DATA IN THE FRAMEWORK OF SITE NAVIGATION
A. COLLECTED AND PROCESSED DATA AND COLLECTIVE MODE
The personal data collected on the ManaTime, ManaCost, ManaCount, ManaSoft sites are as follows:
- First name and last name
- Business and home address
- Business and personal email address
- Business and personal phone number
- Social Security Number
- Date and place of birth
- Geolocation Absence and presence of the workplace
- Absence and presence of the workplace
- Time of departure and arrival at work
This data is collected during the following operations on the site:
- When the user completes his own data
- When the user's administrator completes this data
- Geolocation is enabled when the user adds TimeTracking.
In addition, when making a payment on the site, proof of the transaction, including the order form and invoice, will be kept in the site publisher's computer systems. The controller will store in his computer systems on the site and under reasonable security conditions all the data collected for a period equal to the duration of the user of our software. The collection and processing of data is intended for the following purposes:
- Geolocation data allows the team leader to ensure that the user is at the right place of work to do his job.
- The social security number is used to automatically split and associate pay slips with the right user ;
- Business address, email address and telephone number are required for employees to be able to be in contact as part of their profession
- Personal address, email address and telephone number are required for the HRD who collects employee data to ensure legal follow-up.
B. TRANSMISSION OF DATA TO THIRD PARTIES
The personal data collected by the site are not transmitted to any third party, and are only processed by the site editor.
C. DATA HOSTING
The ManaTime, ManaCost, ManaCount, ManaSoft and ManaSoft sites are hosted by: Gandi, whose headquarters are located at the following address: 63 boulevard Massena 75013 Paris The host can be contacted at the following email address: firstname.lastname@example.org The data collected and processed by the site are transferred to the following country(ies): Ireland, Germany and England.
ARTICLE 4: RESPONSIBLE FOR DATA PROCESSING AND DELEGATED TO DATA PROTECTION
A. THE DATA PROCESSING RESPONSIBILITY
The controller of the processing of personal data is: Hicham HMICHE. He can be contacted as follows: By email to the address email@example.com The data controller is responsible for determining the purposes and means used to process personal data.
B. OBLIGATIONS OF THE RESPONSIBLE FOR DATA PROCESSING
The controller undertakes to protect the personal data collected, not to transmit them to third parties without the user having been informed and to respect the purposes for which the data were collected. The site has an SSL certificate to ensure that the information and data transfer through the site is secure. An SSL certificate ("Secure Socket Layer" Certificate) is used to secure the data exchanged between the user and the site. In addition, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this would entail disproportionate formalities, costs and procedures for him. In the event that the integrity, privacy or security of the user's personal data is compromised, the controller undertakes to inform the user by any means.
C. THE DELEGATE FOR DATA PROTECTION
In addition, the user is informed that the following person has been appointed Data Protection Officer: Hicham HMICHE. The role of the Data Protection Officer and to ensure the proper implementation of national and supranational provisions relating to the collection and processing of personal data. It is sometimes called DPO (Data Protection Officer). The Data Protection Officer can be reached as follows: By email to the address firstname.lastname@example.org
ARTICLE 5: USER'S RIGHTS
In accordance with the regulations concerning the processing of personal data, the user has the following rights. In order for the data controller to comply with his request, the user is required to provide him/her with: his/her first and last name and e-mail address, and if relevant, his/her account or personal or subscriber space number. The data controller is required to reply to the user within a maximum of 30 (thirty) days.
A. PRESENTATION OF USER'S RIGHTS IN DATA COLLECTION AND PROCESSING
a. Right of access, rectification and deletion
The user may review, update, modify or request the deletion of data concerning him/her, in accordance with the procedure set out below: Either directly on the site, or by sending an e-mail to ManaSoft customer service, specifying the subject of his request and using the contact e-mail address provided above or email@example.com If he has one, the user has the right to request the deletion of his personal space by following the following procedure: Either directly on the site, or by sending an e-mail to ManaSoft customer service, specifying the subject of his request and using the contact e-mail address provided above or firstname.lastname@example.org
b. Right to data portability
> The user has the right to request the portability of his or her personal data, held by the site, to another site, in accordance with the following procedure: The user must send an email to ManaSoft Customer Service, specifying the subject of the request and using the contact email address provided above or email@example.com
c. Right to limit and object to the processing of data
The user has the right to request the limitation or to oppose the processing of his data by the site, without the site being able to refuse, unless it can demonstrate the existence of legitimate and compelling reasons, which may prevail over the user's interests and rights and freedoms. In order to request the limitation of the processing of his data or to formulate an objection to the processing of his data, the user must follow the following procedure: The user must send an email to ManaSoft Customer Service, specifying the subject of the request and using the contact email address provided above or firstname.lastname@example.org
d. Right not to be the subject of a decision based exclusively on an automated process
In accordance with the provisions of Regulation 2016/679, the user has the right not to be the subject of a decision based exclusively on an automated process if the decision produces legal effects concerning him, or significantly affects him in a similar way.
e. Right to determine the fate of data after death
Users are reminded that they can organise the future of their data collected and processed if they die, in accordance with law n°2016-1321 of 7 October 2016.
f. Right to have recourse to the competent control authority
In the event that the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or, if he believes that one of the rights listed above is being infringed, he is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent judge.
ARTICLE 6: USE OF "COOKIES" FILES
The site may use "cookie" techniques. A "cookie" is a small file (less than 4 kb), stored by the site on the user's hard disk, containing information about the user's browsing habits. These files allow it to process statistics and traffic information, facilitate navigation and improve service for the user's comfort. For the use of "cookie" files involving the storage and analysis of personal data, the user's consent is necessarily required. This user's consent is considered valid for a maximum period of 13 (thirteen) months. At the end of this period, the site will again request the user's authorization to save "cookie" files on his hard disk.
a. Opposition of the user to the use of "cookies" files by the site
The user is informed that he or she may oppose the recording of these "cookies" files by configuring his or her browser software. For information, the user can find at the following addresses the steps to follow in order to configure his browser software to prevent the recording of "cookies" files:
- Chrome : https://support.google.com/accounts/answer/61416?hl=en
- Firefox : https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences
- Safari : https://www.apple.com/legal/privacy/fr-ww/
- Internet Explorer:: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
- Opera : https://www.opera.com/help/tutorials/security/cookies/
In the event that the user decides to deactivate the "cookies" files, he/she will be able to continue browsing the site. However, any malfunction of the site caused by this manipulation could not be considered as being due to the publisher of the site.
b. Description of the "cookie" files used by the site
The site editor draws the user's attention to the fact that the following cookies are used when browsing the site:
- Google Analytic (most viewed pages anonymously)
- MixPanel (most used features)
- HotJar (recording of a user's movements and mouse clicks anonymously)