We wish to answer the questions you may ask with regard to the management of your personal data and to set out for you the measures we have taken in this regard, in order to ensure you the best level of protection over this data. To this end, we have drawn up this policy.
Its purpose is to inform you of the processing we perform on the personal data with which you entrust us, the reasons why we collect it and the security we accord it.
Firstly, we would inform you that this Confidentiality Policy has been drawn up in accordance with applicable law. In order to offer you the greatest transparency and best protection, we have arranged provisions that prove to be compatible with the principles of the European General Data Protection Regulation No. 2016-679 of 27 April 2016, which entered into force on 25 May 2018 (or “GDPR”).
All the terms in capital letters that are not defined in this document have the meaning accorded to them either in the General Terms and Conditions of Use for Talents or in the General Terms and Conditions of Use for Businesses.
1. GENERAL PRESENTATION
We would point out that zoulloo (“we/us”) is a simplified joint-stock company with a share capital of EUR 59.147, and with head office at 30 Rue Montrosier, 92200 Neuilly-sur-Seine (FRANCE), entered in the Nanterre Business Register under number 911 838 670.
Within the framework of the zoulloo Service described in the General Terms and Conditions of Use, we are, within the meaning of the GDPR, the “controller” for the personal data with which you provide us when using this Service.
As a reminder, zoulloo offers a platform introducing freelance data professionals (the “Talents”) to the companies who wish to use their services (the “Businesses”), available at the following address: https://en.zoulloo.com
(the “Website”). This Confidentiality Policy shall apply to both the Talents and the Businesses (the “Users” or “you”).
2. SCOPE OF THIS CONFIDENTIALITY POLICY
This Confidentiality Policy shall apply to the information we are called on to collect from Talents and Businesses within the framework of their use of the Service.
Its acceptance is required for access to the Service.
3. INFORMATION DURING COLLECTION
In order to be able to provide you with the best Service possible, we are called on to ask you to provide us with your personal information.
When your personal data is collected on zoulloo, we will show you the data that must be entered by an asterisk (*) and that which remains purely optional.
We will then inform you of any consequences from a lack of response.
Furthermore, when you choose to send us your personal information, by completing our ad-hoc forms or by ticking boxes, or selecting the buttons proposed to you, you do so by giving your express consent to the collection and use of this information in accordance with the legal rules and with this confidentiality policy.
4. TYPES OF DATA COLLECTED
The personal information that we are called on to collect means the information identifying you personally, such as that relating to:
For all Users:
- your identity: surname, forename, profile photo, for Businesses, the position of the person representing the Company, etc.;
- your contact details: e-mail address, telephone number, address, etc.;
- the scores and reviews you publish on other Users and on zoulloo;
- your views of other Users’ profiles, your interactions with these, and your interactions with other pages on the Service;
- the persons with whom you communicate;
- the content of your exchanges with other persons via the Service’s messaging centre;
For the Talents:
education and career, CV, soft skills, languages spoken, projects for which you have or have not issued a commercial proposition, projects that you have completed, etc.;
For the Businesses:
projects for which you wish to use a Talent;
Furthermore, we are also called on to collect the computerized traces of your connection to our Website (IP address, date and time of connection).
5. PURPOSES OF DATA PROCESSING
The purpose of the personal information that you will choose to give us is:
- For the information that must be entered, shown by an asterisk (*), as well as for your views on the content and your exchanges with zoulloo and other Users, and the comments you publish: for us to provide you with the Service. This consists in particular of allowing you to create the account on the Website, essential for benefitting from the Service, and to provide us with the information needed so that we can put Users into contact. Our legal basis for this processing is the execution of the contract that we have with you when you create your account to use the zoulloo Service as well as, for some functions, your consent;
- In general, to ensure the IT security of the Website and your data and to establish statistics on the use of the Service in order, in particular, to develop new functions. Our legal basis for this processing is zoulloo’s legitimate interest in order to guarantee our Service is secured, optimized and continues to develop to the benefit of our Users;
- Lastly, we are likely to process your personal data in accordance with the legal obligations in force.
6. RECIPIENTS OF THIS INFORMATION
The personal data you are likely to enter may be viewed by our staff, as well as by all our subsidiaries, by the services responsible for oversight (auditors in particular), but also by our sub-contractors within the strict framework of the purposes that we set out for you in Clause 5 above. Furthermore, in order to participate in the Service’s ecosystem, you are informed that the content that you have entrusted to us may be sent to various zoulloo Service Users, namely:
- To the Businesses, for the personal information regarding the Talents who wish to formulate a commercial proposition for their project;
- To the Talents, for the personal information regarding the members of the Businesses for which they have formulated a commercial proposition.
7. STORAGE PERIOD
Within the framework of the services we offer, we are called on to store content that Users publish on zoulloo, whether these are Talents or Businesses. French law requires the conservation of identification data for the people behind the publication of this content (IP address, date and time of connection, pages viewed, etc.); in any case we will store Users’ data for a period of one year in application of these requirements.
Furthermore, data allowing for establishing proof of a right or a contract, which must be kept in compliance with a legal obligation, will be stored for the duration provided for by the law in force.
Subject to these reservations, your personal information will not be stored beyond the period strictly necessary. It is therefore stored throughout the period in which our services are used via your account, until this is closed.
When you close your account, we will ask you to decide what will become of your account information and the content you have published on the Service. In all cases, one your account is deleted, this information and content will no longer be accessible to other Users, but you may choose:
- either to have it rendered permanently anonymous (or to permanently delete it if it cannot be rendered anonymous),
- or to store it on our servers in case you subsequently want to return to zoulloo and recreate an account in which your data may once again appear. In this case, we will store your information and content for a maximum of two years, at the end of which, if you have not recreated an account with the same login as before, this information and content will be rendered permanently anonymous or deleted.
Furthermore, your data will only be stored for a maximum of two years after the last connection to the Service.
A few weeks before this date, as well as on this date, we will recontact you at the e-mail address you will have given us, in order to ask you whether you wish to maintain or delete your account.
If you do not respond, all your content and information will be rendered permanently anonymous or deleted.
We irreversibly render anonymous all the data fir which this is possible, so that this can serve solely for statistical purposes (analysis of the frequency of use of the Service’s functions in particular). Data that cannot be rendered anonymous, and in particular the videos you publish, are permanently deleted.
With regard to the data of deceased persons, provided zoulloo is informed of the death, this data will be rendered permanently anonymous or deleted, unless specific directives are given to zoulloo.
8. SECURITY AND CONFIDENTIALITY
We have taken all the appropriate organizational and technical measures, and all the useful precautions to protect the security of the information described above, especially against accidental loss, distortion, alteration and against any unauthorized access, use, modification or disclosure. We therefore ensure the integrity and availability of the data that we are called on to process at all times.
To do this, we have recourse in particular to rigorously selected specialist technical service providers which allows, especially on an IT level, for ensuring the security, protection, storage and restitution of the data entrusted.
On a contractual level, the appropriate contractual clauses that link us to these service providers have been drawn up in this sense, in order to comply with the legal principles governing the hosting of personal data.
Guarantees are made when data transfers take place outside the European union: either the service providers are located in a country in which the level of protection has been deemed adequate by the European Commission, or the standard contractual clauses approved by the European Commission have been signed with these recipients. We can also establish any other guarantee in compliance with the applicable legislation on personal data protection that constitutes an “appropriate guarantee” within the meaning of the GDPR.
On a technical level, a set of strict and appropriate technical processes and mechanisms allow in particular for:
- ensuring restricted access to the data by security checks and strict authentication;
- preventing data pirating situations;
- ensuring effective encryption of this data, particularly during its transmission, thanks to use of SSL encryption;
- guaranteeing the physical security of the information processed. The information is therefore stored on secured servers.
Lastly, on an internal level, we rely not only on internal organization that specifically integrates personal data protection, but also on a strict contractual framework in order to effectively ensure the protection.
9. MODALITIES FOR AND EXERCISING OF RIGHTS
In accordance with the applicable data protection regulations, you have a right of access, a right to rectification, to erasure, and to data portability with regard to your data, as well as a right to restrict processing. You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data for which the basis is the legitimate interest pursued by zoulloo as the controller. In addition, in the event the processing is based on your consent, you can withdraw this at any time. Lastly, you have the right to set general or specific instructions relating to the storage, erasure and communication of your personal data after your death.
You can exercise your rights by writing to us:
- By clicking here
- or if you prefer, at our postal address:
30 Rue Montrosier
As provided for by the regulations, in the event there are reasonable doubts about your identity, we will then be obligated to ask you for proof of identity in order to ensure the identity of the owner of the data at the root of the request.
In any event, we will do our best to answer your questions about the processing of your personal data. Despite this, if you are not satisfied with the answers you are given, you can, if you wish, lodge a complaint with the CNIL [French Data Protection Agency] according to the methods outlined on its website (https://www.cnil.fr
), or with the competent data protection authority in your country.
Furthermore, we would specify that you are yourself obligated to comply with the personal data protection regulations, violation of which is liable to criminal penalties. In the event, for example, when acting on behalf of a third party, you wish to send us their personal information, you must act in compliance with the law with regard to this data.
In particular, you must refrain, with regard to the personal data to which you have access, from any collection or any fraudulent use, and in general from any act likely to infringe a person’s private life or reputation.
10. MODIFICATION OF THE CONFIDENTIALITY POLICY
We hereby inform you that this Confidentiality Policy may need to change. If the modifications made are substantial, we will inform you of this by a visible notification made via the Service, or by other means such as the e-mail address provided, in order to give you the opportunity to look at the changes before they take effect. If you object to any of the modifications, you may close your account.
You acknowledge that, if you continue to use our Service after the publication of the modifications made to our Confidentiality Policy or notification about this being sent, this means that the collection, use and sharing of your personal data shall be subject to the updated version of the Confidentiality Policy, as of the date this comes into force.
11. USE OF CONNECTION INDICATORS (“COOKIES”)
Cookies are text files, often encrypted, stored on your browser. They are created for a limited period when a user’s browser loads a given website: the website sends information to the browser, which then creates a text file. Every time the user returns to the same website, the browser retrieves this file and sends it to the website server.
The information stored by cookies relates in particular to the pages viewed, the type of browser you use, your IP address, and even the information you have entered on a website so that you don’t have to enter this again.
For more information on cookies, please visit the CNIL information page: CNIL advice for understanding your browser
We use various cookies to adapt the services offered by the Website:
1. Technical cookies and operational cookies
These cookies guarantee the website works and play a role in its optimization. These are cookies intended to:
- secure your connection, by ensuring your identification on your personal account, where applicable;
- remember your preferences for use and/or display parameters;
- display, during your first visit, the banner informing you of the presence of cookies and the option you have to accept or refuse these.
2. Audience/web analysis cookies
These cookies allow for measuring the Website audience and thus establishing anonymous visitation statistics measuring the number of visits, the number of pages viewed, and Users’ activities on the website (pages most often visited, products most often viewed, etc.).
3. Advertising cookies
Lastly, advertising cookies allow for measuring the audience or progress made by an online campaign.
We do not use advertising cookies.
Your browser’s help menu will allow you to find out how to express or modify your cookie preferences: