Applicable to customers, prospects and internet users
Logora ("We"), in the context of its activity of providing services for the management of contributions from internet users on press publishers' websites, is required to process Personal Data of its press publishers (the "Customers"), prospects (the "Prospects") and internet users who visit its website www.logora.fr (the "Site") (together, the "Data Subjects" or "You").
We are committed to processing your Personal Data in accordance with the applicable regulations, namely Regulation (EU) 2016/679 of April 27, 2016 (the "GDPR") and the French Data Protection Act of January 6, 1978 in its updated version (the "DPL") (together, the "GDPR Regulation").
Terms beginning with a capital letter, such as "Personal Data", "Processing", "Data Subjects", "Data Controller", "Processor", "Recipient", "Data Breach", without this list being exhaustive, have the meaning given to them by the GDPR Regulation.
In particular, the terms "Personal Data" or "Data" refer to all data that can identify an individual, which includes your name, first name, postal and email addresses, telephone numbers, name of the company to which you belong, without this list being exhaustive.
The data controller for the Personal Data of Customers, Prospects and Internet users is LOGORA, SAS, registered in the Paris Trade and Companies Register under number 850171695, with its head office at 31 avenue Théophile Gautier, 75016 Paris.
The Processing of the Data of the users of the debate platforms that we make available to our Customers is carried out by us as a Processor, knowing that our Customers act as Data Controllers. These Processings are not therefore treated in this Policy.
Your Personal Data is collected:
We may process the following Data about you:
Your Personal Data is collected in order to meet one or more of the following purposes:
We inform you, when collecting your Personal Data, if certain data must be provided or if they are optional.
We also indicate what the possible consequences of a lack of response are.
The Processing we carry out is based on one or more of the following legal bases:
We may disclose your Personal Data to authorized and subject to an appropriate obligation of confidentiality, which may be internal or external depending on the case.
External Recipients are on the other hand:
We retain your Personal Data for a determined and proportionate period to the aforementioned Processing purposes, knowing that at the end of the retention periods, your Data is either deleted or anonymized for statistical purposes, the deletion and anonymization operations being irreversible operations that make it impossible to restore the data later.
We use the following retention periods:
We inform you to take all necessary precautions, appropriate organizational and technical measures to protect the security, integrity and confidentiality of your Personal Data and in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We will also use or may use secure payment systems in accordance with the state of the art and applicable regulations.
Among these measures are:
We carry out regular monitoring of our systems to detect any vulnerability or security incident and we regularly review our data processing practices in order to update the security measures implemented to protect and secure your data if necessary.
When we use subcontractors, i.e. service providers to whom we have delegated all or part of a Processing and who process your Personal Data in accordance with our instructions, we undertake to contractually impose on them similar security guarantees as those we put in place to protect your Personal Data and we reserve the right to audit them to ensure compliance with their obligations.
In the event of a Data Breach, we undertake to notify the CNIL in the conditions prescribed by the GDPR and, if such breach poses a high risk to you, to notify you and to provide you with the necessary information and recommendations if necessary.
Cookies are text files, often encrypted, stored in your browser. They are created when a user's browser loads a given website: the site sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website's server.
Two types of cookies can be distinguished, which do not have the same purposes: technical cookies and advertising cookies:
Technical cookies are used throughout your browsing experience to facilitate it and perform certain functions. For example, a technical cookie can be used to remember the responses entered in a form or the user's preferences regarding the language or presentation of a website, when such options are available.
Advertising cookies can be created not only by the website on which the user is browsing, but also by other websites displaying ads, announcements, widgets or other elements on the displayed page. These cookies may be used, in particular, to display targeted advertising, i.e. advertising determined according to the user's browsing.
We use technical cookies. These are stored in your browser for a period not exceeding two years.
We do not use advertising cookies. However, if we were to use them in the future, we would inform you beforehand and you would have the option to disable these cookies if necessary.
We remind you that it is possible to refuse the deposit of cookies by configuring your browser. Such a refusal could, however, prevent the proper functioning of the site.
In accordance with the GDPR Regulation, you have the following rights over your Personal Data:
When you wish to exercise one of the aforementioned rights or for any other question relating to the processing of your Data, you can contact us by e-mail at the address: firstname.lastname@example.org or by postal mail at the address: 31 avenue Théophile Gautier, 75016 Paris.
The request to exercise rights must come exclusively from you (unless a mandate is given to a third party in due form) and be as clear and comprehensive as possible in order to enable us to respond to it as quickly as possible, between one and three months depending on its level of complexity.
We may ask you to complete your request if it is not sufficiently precise, if the right you wish to exercise is not easily identifiable or if we are unable to establish your identity, in which case we may ask you to provide additional information, including proof of identity, which we will delete once your identity is verified.
In addition, we will not be required to respond to your request if it is manifestly unfounded or excessive, and in particular if you make repetitive requests that have the effect of destabilizing our activities.
In certain circumstances, particularly when some of the Subcontractors we use are located abroad, your Personal Data may be transferred outside the European Economic Area ("EEA").
Any transfer of Personal Data outside the EEA, in particular to a country for which there is no adequacy decision from the European Commission, is made with appropriate safeguards, including contractual safeguards, in accordance with GDPR Regulation.
You may obtain a copy of the appropriate safeguards by contacting us at the address listed in Article 10.
We reserve the right, in our sole discretion, to modify this Policy at any time, in whole or in part, to take into account legal, regulatory and/or jurisprudential developments, changes in the characteristics of processing, or the implementation of a new processing. These modifications will come into effect upon online publication of the new Policy.
This policy came into effect on 13/04/2023.