Confidentiality and General Data Protection Regulations (GDPR) Policy
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1. Purpose and scope
This confidentiality policy sets out the rules implemented by our organization for the protection of physical persons regarding the processing and free flow of personal data.
The rules listed below apply to the processing of personal data collected by our application and called to appear in a file as part of the delivery of our service, whether or not payment is required.
The definitions set forth above are referred to in Section 4 of the REGULATION 2016/679 OF THE EUROPEAN PARLIAMENT AND COUNCIL, namely the general data protection regulation (GDPR):
For the purposes of this Regulation:
- ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- ‘restriction of processing’ means the marking of stored personal data with the aim of limiting their processing in the future;
- ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
- ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
- ‘filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
- ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
- ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
- ‘third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
- ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
- ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
- ‘genetic data’ means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
- ‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;
- ‘data concerning health’ means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
- ‘main establishment’ means: as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation;
- ‘representative’ means a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;
- ‘enterprise’ means a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;
- ‘group of undertakings’ means a controlling undertaking and its controlled undertakings;
- ‘binding corporate rules’ means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity;
- ‘supervisory authority’ means an independent public authority which is established by a Member State pursuant to Article 51;
- ‘supervisory authority concerned’ means a supervisory authority which is concerned by the processing of personal data because: the controller or processor is established on the territory of the Member State of that supervisory authority; data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or a complaint has been lodged with that supervisory authority;
- ‘cross-border processing’ means either: processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.
- ‘relevant and reasoned objection’ means an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;
- ‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (¹);
- ‘international organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.
General data protection regulation, UE, 2016, c 1, art 4.
3. General principles
As part of the processing operations carried out by LiGRE, personal data, as provided for in the section entitled Definitions, is collected and processed in the follow way:
- licitly, loyally and transparently;
- for determined, explicit and legitimate purposes;
- not to be used for purposes contrary to those explained in this policy;
- to ensure data minimization;
- to be exact and kept up to date during the period not exceeding the period required for the purposes set forth in this policy;
- to guarantee proper security.
For personal data processing to be deemed licit, the user must have consented to the processing of his personal data for the purposes set forth in Section 5.
LiGRE processes personal data once it has obtained the user’s consent. The user can withdraw his consent at any time, and this will not compromise the lawfulness of the data processing, which means that the data will not be processed for purposes other than those explained in Section 5. When the user withdraws his consent, his personal data is no longer collected and kept.
5. Data collected, relevance and purposes
The personal data collected by the application is provided by the user who has consented to it, is relevant and is processed for the purposes explained in this policy.
Personal data is collected when processing requires user identification. Personal data collected for processing not requiring the identification of a person will not be kept.
Identification data such as the last name, first name, user language, email address and password is collected to create a user account and allow the user to reconnect to his account, but also to provide support to the user whenever necessary or upon his request. The user can also choose to create his or her account by associating a social media account (Facebook or Google). In this case, only an authentication ID is exchanged.
Data collected upon using the application remains optional and so the user can decide whether or not to provide it. This data, such as information on the project, or the bibliography of the documents or photo, is used by users who want to create a public page for their project. This data is not used for profiling purposes.
Files uploaded by the user to carry out his project are kept and are not accessed by the members of our team unless the user in charge of this data asks for assistance or support. Files uploaded by the user to use the automatic transcription are transferred to an I.S.O. who transcribes them and sends them to LiGRE. The I.S.O. processes the file automatically (including fragmentation). No other personal data is transmitted, only the file to be transcribed is transferred to the I.S.O.
The address is collected when a product is purchased to know what sales taxes must be invoiced and in what currency the transaction must be billed.
When a user makes a purchase, LiGRE uses the PayPal platform. LiGRE only collects the data that PayPal sends. Bank details are not passed on. PayPal sends LiGRE information on whether or not the payment went through successfully, the first and last name of the buyer, his country of residence, the amount of the purchase and the identification numbers generated automatically by PayPal to help identify the transactions.
Some other personal data is not collected by LiGRE but can be obtained occasionally for support inquiries; it is only used if necessary, to provide the user with technical support when he reports a problem with his account, or can be collected in temporary tables used to ensure the security of our application. This includes the browser, IP address and location data.
6. Rights of our users
Users can send LiGRE a request regarding their personal data at any time at the following address: firstname.lastname@example.org. LiGRE has 30 days to answer these requests and does not require payment for the answers provided. Except for requests deemed repetitive or abusive, LiGRE intends to honour all personal data requests addressed to it within the prescribed deadline.
The purposes and interests for which the personal data is collected are mentioned in Section 5 of this policy. The period during which the data is kept does not extend beyond the data processing period.
6.1. Right to access and correct
The user can ask LiGRE to access his data and also has the right to ask that this data be corrected or deleted. The user also has the right to withdraw his consent at any time and to lodge a complaint before any supervisory authority.
The user has the right to obtain confirmation on whether or not his personal data is processed. The user has the right to know the purposes of the processing, the data collected, the people with whom this data can be shared and the period during which the data is kept. The user has the right to ask that the data be corrected or deleted.
6.2. Right to delete
The user has a right to request deletion, also called the right to be forgotten, as soon as possible after the user withdraws his consent or deactivates his user account. The user can make this request at any time, which will lead to the deletion of his user account as well as his personal data kept.
6.3. Right of processing limitation
The user has the right to request that processing of his personal data be limited to the following situations:
- If he disputes the accuracy of the data;
- If he deems the processing to be illicit;
- If he deems that LiGRE does not need to keep the data;
- If he does not agree with the processing operations used.
The user has the right to be warned about anything having to do with the correction or deletion of his data, or to the limit of the personal data processing.
6.4. Right of portability
The user has the right to ask to receive his personal data and to use it with another personal responsible for processing.
6.5. Right of objection
The user can object to the processing of his personal data at any time if he namely fears profiling; however, LiGRE does not do any profiling.
6.6. Right to be excluded from a decision based on automatic processing such as profiling
The user can ask to be excluded from decisions based on automatic processing such as profiling; however, LiGRE does not engage in such activities.
The scope of LiGRE’s obligations and the users’ rights can be limited by legislation submitted by a public authority such as a State. A limit constitutes a necessary and proportionate measure to guarantee national security, the national defence, public safety, prevention and detection of criminal offences, protection of the independence of legal proceedings, prevention and detection of breaches of ethics for regulated professions, protection of the user and his rights and freedoms and execution of the demands made in the Civil Code.
7. Data protection
To minimize the risks of violating the users’ privacy or confidentiality, LiGRE’s processing rules include advanced identification measures, namely pseudonymization, minimization of data collected, and fragmentation and partitioning of data generated in and uploaded to its cloud computing environment.
8. Data security
LiGRE strives to guarantee its users an annual availability rate of 99.9% for its cloud computing environment; however, this guarantee excludes the interruptions needed to ensure maintenance of the application and network. It also excludes any event resulting from an “Act of God”.
Furthermore, LiGRE also uses a backup plan (backup copies) that help to ensure data recovery in the following situations:
- Application update
- Corruption of software or the database or loss of files
- Corruption of the VM
- Partial server failure
- Complete server failure
- Any other hardware defect (cabinet, router / switch)
- Failure or interruption of the hosting service (fire, extended power outage, telecommunication failure)