PRIVACY POLICY

1. PREAMBLE

The purpose of this privacy policy is to inform users of the site:

On how their personal data is collected.
On the rights they have regarding this data;
On the person responsible for processing the personal data collected and processed;
On the recipients of this personal data;
On the site's cookie policy.

2. DEFINITIONS

Personal data:

Any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity.

Treatment:

Any operation or set of operations carried out or not using automated processes and applied to data or sets of personal data, such as collection, recording, organization, structuring, conservation , adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, alignment or interconnection, limitation, erasure or destruction.

File:

Any structured set of personal data accessible according to determined criteria, whether this set is centralized, decentralized or distributed functionally or geographically.

Data controller:

The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing.

Subcontractor:

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient:

The natural or legal person, public authority, service or other body which receives communication of personal data, whether or not a third party.

Cookies:

Connection cookie which is the equivalent of a text file stored on the Internet user's terminal when consulting the site www.qommute.com. The cookie file can only be read by the issuer of the cookie. The cookie allows the terminal used to be identified.

3. ACCEPTANCE OF PRIVACY POLICY

The user must read this confidentiality policy.

4. IDENTITY OF THE CONTROLLER

The data controller is SAS QOMMUTE, whose registration number is 485 224 455 and whose address is located at 21 avenue de Mazargues, 13 008 Marseille – France.

The person responsible for processing personal data can be contacted as follows: by email at contact@qommute.com.

5. PERSONAL DATA COLLECTED AND PURPOSES OF THE PROCESSING

FINALITIES	PROCESSED DATA
Processing requests for applications by email	Email address and any personal data entered in the message or sent as attachments
Processing requests using the contact form	Name, email, and any personal data entered in the message
Management of requests to exercise rights over personal data	Name, first name, gender, email address, telephone number, content of the request, identity document if necessary
Audience analysis, statistics	IP address, type of terminal used…

6. LEGAL BASIS FOR DATA PROCESSING

6.1. Processing based on consent

Processing relating to requests sent by email or via the contact form is based on consent, including all those relating to applications.

6.2. Processing based on compliance with legal obligations

The management of requests to exercise personal data is based on law.

6.3. Processing based on consent

The installation of cookies for audience analysis purposes and advertising cookies is based on consent.

7. DATA RETENTION DURATION

Data concerning identity documents relating to the exercise of the rights of access, rectification, deletion, limitation, erasure and portability are kept for ONE (1) year from their receipt.

The data whose purpose is to process users' requests to exercise their rights are kept for FIVE (5) years from the processing of the request.

Concerning applications responding to a position offer, with the candidate's agreement and in the event of a negative response, QOMMUTE will retain personal data for a maximum period of two (2) years in order to possibly recontact them.

Concerning spontaneous applications, with the candidate's agreement, personal data is kept for a period of six (6) months in order to possibly recontact them.

The retention period for information collected via trackers/cookies is 25 months.

The retention period for consent to the installation of cookies is 13 months.

8. RECIPIENTS OF PERSONAL DATA

The recipients of personal data are:

The QOMMUTE company and regarding CVs, only the people in charge of recruitment within QOMMUTE;
The host of the site qommute.com;
QOMMUTE service providers such as webmaster, web communication agency, etc.

QOMMUTE may be required to communicate your data to the legal authorities upon injunction.

Apart from the cases mentioned above, no personal data is shared or communicated without the user's consent.

9. TREATMENT LOCALITY

The host of the website www.qommute.com is the company AMEN AGENCE DES MEDIAS NUMERIQUES in France.

With your consent, the use of cookies (Google analytics, YouTube) may result in a transfer of personal data to the USA in accordance with the adequacy decision of July 10, 2023 of the European Commission and the data privacy framework program.

10. YOUR RIGHTS

10.1. Right of access – Article 15 of the GDPR

You have the right to obtain confirmation that personal data concerning you are or are not being processed. In the event that the data is processed, you have a right of access to this data and the following information:

The purposes of the processing;
The categories of personal data concerned;
The recipients or categories of recipients to whom the data have been communicated or will be communicated;
If possible, the planned retention period of the data or, when this is not possible, the criteria used to determine this period;
The existence of the right to request rectification or erasure of data, or limitation of processing or the right to object to processing;
The right to lodge a complaint with the CNIL;
Where personal data is not collected from you directly, any information available at the source;
The existence of automated decision-making, including profiling and, at least in such cases, meaningful information regarding the underlying logic, as well as the significance and intended consequences of such processing for you.

A copy of the data being processed will be provided to you.

You may be required to pay a reasonable fee based on administrative costs for any additional copies you request.

If you request a copy of the data digitally, it will be provided to you in commonly used digital form unless you request otherwise.

Finally, the right to obtain a copy of personal data must not infringe the rights and freedoms of others.

10.2. Right of rectification – Article 16 of the GDPR

You have the right to request the rectification of your data which is inaccurate, as soon as possible. You also have the option of having incomplete personal data concerning you completed, including by providing an additional declaration.

10.3. Right to erasure – Article 17 of the GDPR

You have the right to erasure of your personal data as soon as possible when one of the following reasons applies:

The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
You withdraw your consent on which the processing is based and there is no other legal basis for the processing concerned. Withdrawal of consent applies for the future;
You exercise your right to object and there is no overriding legitimate reason for the processing;
Personal data has been the subject of unlawful processing;
Personal data must be erased to comply with a legal obligation.

You are informed that the right to erasure may not apply if processing is necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

10.4. Right to restriction of processing – Article 18 of the GDPR

You have the right to request the limitation of the processing of your personal data when one of the following applies:

Verification of your data after a dispute on your part regarding the accuracy of your personal data;
The processing is unlawful and you object to the erasure of your personal data and demand the limitation of their use;
QOMMUTE no longer needs the personal data concerning you for processing but the data is necessary for the establishment, exercise or defense of legal rights;
You have objected to the processing and QOMMUTE verifies whether the legitimate reasons pursued by QOMMUTE prevail over your legitimate reasons.

10.5. Right to portability of personal data – Article 20 of the GDPR

At your request, you have the option of receiving your personal data in a structured, commonly used and machine-readable format when:

The processing is based on consent or a contract;
And the processing is carried out using automated processes.

As part of exercising this right, you have the right to have your personal data transmitted directly to another data controller when technically possible.

The right to portability must not infringe the rights and freedoms of third parties.

10.6. Right to object – Article 21 of the GDPR

Pursuant to the right to object, you have the right to object at any time to the processing of your personal data based on legitimate interests.

Personal data will no longer be processed unless it is demonstrated that compelling legitimate grounds for processing exist and override your interests and rights and freedoms or for the establishment, exercise or defense of legal claims.

10.7. Fate of personal data post mortem

In application of the law, you have the right to define your directives relating to the conservation, erasure and communication of your personal data in the event of death.

You can communicate your specific instructions to us or register them with a certified digital trusted third party.

You can therefore designate the person of your choice who will be responsible for carrying out your instructions. Otherwise, it will be your heirs.

You have the option to modify or revoke your instructions at any time.

10.8. Right to contact the CNIL

You have the right to lodge a complaint with the CNIL, the supervisory authority (www.cnil.fr).

11. HOW TO EXERCISE YOUR RIGHTS

11.1. Conditions for exercising rights

For all requests concerning personal data processed by QOMMUTE, you can send your requests to the following addresses:

By mail: QOMMUTE – 21 avenue de Mazargues, 13008 Marseille
By email: contact@qommute.com

11.2. Response time

QOMMUTE has one (1) month to respond to you from receipt of your request. This deadline may be extended by two months taking into account the complexity and number of requests. QOMMUTE will inform the person concerned within one month of their request.

In the event of exercising your right of deletion or your right to erasure, you are informed that QOMMUTE may be required to keep the personal data concerning you in the form of archiving before deletion of the data.

12. SOCIAL NETWORKS

By clicking on the icons dedicated to social networks such as Linked In on the site www.qommute.com, the user is redirected to third-party websites.

These social networks help promote the site www.qommute.com.

When the user clicks on one of the icons, QOMMUTE does not collect personal data concerning them. The same applies to shares made by the user on different social networks.

These links are only used to send the user to these social networks.

When the latter is sent to social networks, the user's information and/or interactions collected by these social networks depend on the confidentiality settings defined by the user with each of the social networks concerned.

13. COOKIES

13.1. Cookies used

→ Cookies issued by third parties

Analysis and personalization cookies

These are cookies used to measure attendance, use of the site as well as the audience of the QOMMUTE site to improve the operation of the site as well as its ergonomics. This allows you to understand which pages are most interesting to users.

Advertising cookies

These cookies make it possible to recognize the user's terminal when subsequently browsing another site on which the third-party company issuing these cookies also issues cookies.

This also makes it possible to adapt these other sites, to broadcast and/or the advertisements broadcast on these sites to the navigation of the user's terminal of which they may be aware.

13.2. Cookie management

On the site www.qommute.com during your first visit, a cookie banner appears allowing you:

Either to accept everything;
Either refuse everything;
Either choose your preferences and manage your cookies.

Concerning cookies for which consent is required, the Internet user is informed that he can modify his choices whenever he wishes.

Managing cookies through the choices offered by your browser software:

You can configure your navigation software in order to:

To accept all cookies;
To refuse all cookies;
To refuse certain cookies depending on the issuers.

1. Acceptance of all cookies

If you have accepted in your navigation software of each Terminal the recording of Cookies on each Terminal, the Cookies integrated into the pages and content that you have consulted may be stored temporarily – without being able to exceed thirteen (13) months – in a space dedicated to your Terminal. They will be readable only by their issuer.

2. Refusal of all cookies or certain cookies

If you withdraw your consent, please note that a cookie will be installed to deactivate the storage of other cookies on your terminal.

3. Ways to make your choices depending on your browser

In order to configure your navigation software, you must refer to the help menu of your browser.

Configuring your smartphone :

To find out the cookie management policy on your smartphone, you can consult the following pages:

Android : https://support.google.com/chrome/topic/3434352
iOS : https://support.apple.com/fr-fr/HT201265

You are informed that depending on the settings you make, you may no longer be able to use the application's functionalities.

14. CHANGES TO THE PRIVACY POLICY

The confidentiality policy may be modified at any time, in particular due to legislative or regulatory changes or due to new processing implemented by QOMMUTE.

The date of modification of the confidentiality policy will appear on said document and the new confidentiality policy will apply to any connection subsequent to the modification thereof.