Protection of personal data

Protection of Personal Data

Ingaged (hereinafter ‘Ingaged’ or ‘we’) undertakes, as the Data Controller, to implement appropriate measures to ensure the protection, confidentiality and security of your Personal Data and to process and use such Data in compliance with the applicable provisions, and in particular European Regulation 2016/679 of 27 April 2016 (hereinafter the ‘General Data Protection Regulation’ or ‘GDPR’) and Law no. 78-17 of 6 January 1978, known as the Data Protection Act, and any law or regulation that may supplement or replace it (hereinafter together the ‘Applicable Regulations’).

The purpose of this Personal Data protection policy (hereinafter the ‘Policy’) is to inform you of the manner in which we process your Personal Data and of the commitments made by Ingaged in order to ensure compliance with said Data.

For the purposes of this Policy, the terms ‘Personal Data’ or ‘Data’, ‘Processing’, ‘Data Controller’, ‘Data Processor’ have the meaning given to them in Article 4 of the General Data Protection Regulation.

1. What Personal Data do we process?

We take care to collect and process Personal Data that is relevant, adequate, not excessive and strictly necessary to achieve the purposes that have been previously determined.

1.1 Business contacts (customers, prospects, other external contacts)

As part of the work we carry out on behalf of our customers (hereinafter referred to as the ‘Customers’) and, more generally, as part of our activities, we collect and process Personal Data relating to the aforementioned Customers, as well as their managers, employees, service providers, suppliers and/or customers.

We may also collect and process the Personal Data of prospective customers (hereinafter referred to as ‘Prospects’) which they communicate during events, meetings or various other exchanges.

Finally, we may collect data from various and sundry external contacts in the context of our missions and activities (hereinafter referred to as ‘External Contacts’).

In these circumstances, we are likely to have access to identity and contact Personal Data. However, we may also have access to other Personal Data that you provide to us directly in the context of our missions and activities, if necessary.

1.2. Visitors to the Site

In the context of the use of the Ingaged website, accessible at https://www.ingaged.eu (hereinafter the ‘Site’), Ingaged collects and Processes certain Personal Data about you in your capacity as a user of the Site (hereinafter ‘User(s)’).

Users’ Personal Data is collected when :

    • You browse the Site: in this case, we collect your technical and browsing information. We invite you to consult our Cookie Policy.
    • You contact us via a form: in this case, we collect your identity and contact data and any information that you provide voluntarily and that is relevant to the processing of your request.
    • You subscribe to a newsletter offered by Ingaged: in this case, we collect your identity and contact data.

When your Personal Data is sent to us via a form, the compulsory nature of the information (*) that you must provide is indicated at the time of collection. Any failure to reply or any reply deemed abnormal by Ingaged may result in Ingaged refusing to take your request into account.

2. Why do we process your Personal Data and what is the legal basis for such processing?

Ingaged is committed to collecting and processing your Personal Data fairly and lawfully. Ingaged processes Personal Data for explicit, legitimate and specific purposes.

Your Personal Data may be processed for the following purposes:

    • If you are a Client : The Personal Data of Clients is processed for the purposes of managing said Clients and the relationship we have with them, including for the purposes of (i) contact and communication, (ii) carrying out the assignments entrusted to us, (iii) managing the relationship, (iv) managing invoices and accounting. Similarly, and subject to their not objecting, Clients may receive newsletters, informational content on various professional subjects, press releases, invitations to training courses or events organised by Ingaged, all in an exclusively professional context. In this context, the Personal Data collected may be used for analysis purposes (such as trends, progress of marketing actions, click and open rates).

In this context, we process your Personal Data for the purposes of executing the contract and complying with our legal obligations (accounting and tax), with the exception of the Processing implemented for the purposes of analysis and commercial prospecting, which is based on Ingaged’s legitimate economic interest in promoting its services and developing its relations, which benefits both Clients and Ingaged, without prejudice to the interests, rights and fundamental freedoms of the said Clients.

    • If you are a Prospect: The Personal Data of Prospects is processed for the purposes of contacting and communicating with such Prospects. Similarly, and subject to their not objecting, Prospects may receive newsletters, informational content on various professional subjects, press releases, invitations to training courses or events organised by Ingaged, all in an exclusively professional context. In this context, the Personal Data collected may be used for analysis purposes (such as trends, progress of marketing actions, click and open rates).

The Processing carried out in this context is based on Ingaged’s legitimate economic interest in promoting its services and developing its relationships, which benefits both Prospects and Ingaged without prejudice to the interests, rights and fundamental freedoms of said Prospects.

    • If you are an External Contact: Personal Data of External Contacts is processed for the purposes of managing our business and communicating with these individuals. In certain cases, provided they do not object, External Contacts may receive newsletters, information on various professional subjects, press releases, invitations to training courses or events organised by Ingaged, all in an exclusively professional context.

The Processing carried out in this context is based on Ingaged’s legitimate interest in carrying out the assignments entrusted to it by its Clients, promoting its services and developing its relations, without infringing the interests, rights and fundamental freedoms of External Contacts.

    • If you are a User: Users’ Personal Data is processed for the purposes of (i) communication and management of requests, (ii) analysis of browsing on the Site (We invite you to consult our Cookie Policy) and/or (iii) commercial prospecting (sending newsletters, informational content on various professional subjects, press releases, invitations to training courses or events organised by Ingaged) when a User communicates his/her email address for this purpose on the Site and does not subsequently express opposition.
    • The Processing carried out in this context is based on Ingaged’s legitimate economic interest in promoting its services and developing its relations, constantly improving its Site and communicating easily with its Users. This benefits both Users and Ingaged without prejudice to the interests, rights and fundamental freedoms of said Users.
    • If you are a candidate : Candidates’ Personal Data is processed for the purposes of managing and selecting applications submitted. We invite you to consult the personal data protection policy for candidates by clicking on the following link.

3. How long do we keep your Personal Data?

Ingaged retains your Personal Data for as long as is necessary for the purposes for which it was collected and processed. Ingaged may, however, retain your Personal Data for a longer period in order to comply with legal obligations and in particular applicable limitation periods.

Ingaged therefore retains your Personal Data for the following periods:

    • Customer Data is retained for the duration of the relationship and for the applicable limitation period (generally 5 years). However, in certain cases, we may retain Customer Data for a longer period if this is necessary for the follow-up of assignments carried out. Data required for accounting purposes is kept for a total of 10 years in order to comply with applicable accounting and tax obligations.
    • Prospect Data is kept for a period of 3 years following the last contact with the Prospect.
    • External Contact Data is kept, (i) if it is collected in the context of a relationship with a Customer, for the same period as the Customer Data set out above and, (ii) if it is collected in another context, for the period necessary to achieve the intended purpose.
    • Data collected  for commercial prospecting and analysis purposes are kept for 3 years following the last contact with the person concerned.

When cookies or other tracers that are not essential to the operation of the Site are deposited on your terminal, they are retained for the period indicated in the Cookie Policy.

When your Data is collected in the context of requests/questions relating to the Site and/or Ingaged’s services, it is retained for the time required to process said requests/questions.

4. To whom is your Personal Data destined?

The Personal Data collected and processed by Ingaged is accessible only to authorized internal personnel, i.e. the management team, interim managers and, where applicable, employees handling requests from Customers, Prospects and other external Contacts.

This Data may be communicated to third parties, acting as Subcontractors, bound by a subcontracting agreement, to perform hosting, contact management (CRM), accounting management, communication, database management, Site management and IT outsourcing services. These sub-contractors only act on instructions from Ingaged and only have access to your Personal Data in order to perform their services. They are bound by the same security and confidentiality obligations as Ingaged.

In addition, your Personal Data may be shared with third parties for the following purposes:

    • In response to legal or administrative proceedings of any kind or to law enforcement measures requested by the competent authorities.
    • To comply with legal obligations, to protect the rights and/or safety of any person, to protect the rights and property of Ingaged and to prevent fraud, security or technical problems.

5. Is your Personal Data transferred outside the European Union?

The Personal Data collected by Ingaged is hosted within the European Union and is not transferred outside the European Union.

6. What are your rights?

In accordance with Applicable Regulations, you have the following rights with respect to your Personal Data:

    • The right of access: You have the right to obtain (i) confirmation as to whether or not Personal Data concerning you are being processed and, if so, to obtain (ii) access to and a copy of said Data.
    • The right of rectification: You have the right to obtain the rectification of Personal Data concerning you that are inaccurate. You also have the right to have incomplete Personal Data completed, including by providing an additional declaration.
    • The right to erasure: In certain cases, you have the right to obtain the deletion of your Personal Data. This right is not absolute, however, and Ingaged may have legal or legitimate reasons for retaining said Data.
    • The right to limit Processing: In certain cases, you have the right to obtain the limitation of the Processing of your Personal Data.
    • The right to portability: You have the right to receive the Personal Data concerning you that you have provided to Ingaged, in a structured, commonly used and machine-readable format, and you have the right to transmit this Data to another Data Controller without Ingaged hindering it. This right applies only where the Processing of your Personal Data is based on your consent or on the performance of a contract and where said Processing is carried out using automated processes.
    • The right to object: You have the right to object at any time, for reasons relating to your particular situation, to the Processing of Personal Data concerning you where such Processing is based on Ingaged’s legitimate interests. Ingaged may, however, invoke legitimate and compelling reasons requiring the continuation of the Processing. When your Personal Data is processed for canvassing purposes, you have the right to object to the Processing at any time. You can opt-out of receiving newsletters, communications and invitations to training courses and events organized by Ingaged by sending an email to one of the addresses below. In addition, our commercial prospecting messages contain an “unsubscribe” option should you no longer wish to receive such messages from us.

The right to give instructions concerning the use of data after death: You have the right to give Ingaged instructions concerning the use of your Personal Data after your death.

To exercise these rights, you can send a request:

    • by email to: contact@ingaged.eu
    • or by post to Ingaged, 2 Boulingrin 31000 Toulouse, France

In the event of difficulty in connection with the management of your Personal Data, you may lodge a complaint with the CNIL (3 Place de Fontenoy 75007 Paris) or any other competent authority. However, we invite you to contact us before lodging a complaint with the CNIL.

Customers, Prospects and other External Contacts undertake to pass on the present information to their managers, employees, service providers, suppliers and/or customers whose Personal Data may be processed by Ingaged in the performance of its missions and activities.