Policy on the protection and use of personal data



Update date: 01/02/2021

1. Collection of certain Personal Data

The company DYNAMIC SCREEN, a simplified joint stock company with a capital of 17. 380 euros, registered in the Bordeaux Trade and Companies Register under number 834 702 821, and whose registered office is located at 48 Rue Thiac - 33000 Bordeaux ("DYNAMIC SCREEN"), complies with all regulatory and legislative provisions relating to the protection of personal data (the "Applicable Regulations"), and in particular all the provisions set out in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "General Data Protection Regulation" or "GDPR"), as well as the provisions of Law No. 78-17 of 6 February 1978 known as "Informatique et Libertés" as amended (the "LIL"). 

Customers and Users (as defined in DYNAMIC SCREEN's general terms and conditions of use in force on the date hereof) acknowledge and agree that DYNAMIC SCREEN processes certain of their personal data (the "Personal Data"), in accordance with the terms and conditions of this Policy for the Protection and Use of Personal Data (the "Policy for the Protection and Use of Personal Data" and alternatively the "Policy").

Personal Data" is any information relating to an identified or identifiable natural person. An identifiable natural person is 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 factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity. 

2. General rules applicable to the collection and processing of personal data

It is recalled that in accordance with the Applicable Regulations, the Personal Data are: 

. Processed in a lawful, fair and transparent manner with regard to the persons concerned;
.
 . Collected for specific, explicit and legitimate purposes and not further processed in a manner incompatible with these purposes;
.
 . Adequate, relevant and limited to what is necessary for the purposes for which they are processed;
.
 . Accurate and, where necessary, kept up to date;
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 . Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed;
.
 . Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by accidental means, using appropriate technical and organizational measures.

3. Nature of the Personal Data collected

3.1 The data controller is DYNAMIC SCREEN which remains the sole recipient of the Personal Data concerned. 

The Personal Data whose communication is requested from Customers and Users through the forms available on the COMEEN Platform are intended for the data controller. If the person concerned fails to communicate this data, his/her request cannot be processed. For all intents and purposes, it is recalled that the data controller is, in accordance with the applicable legislation, the entity that defines and limits the data to be collected as well as the purposes of processing. 

In any event, such Personal Data is collected and processed on the basis of a legal obligation, a legitimate interest of DYNAMIC SCREEN and/or the consent of the data subject.

3.2 When creating a User account under the User TOU (said terms being defined in said TOU), the User will be asked for a number of mandatory and optional information. In accordance with the terms and conditions of the User TOU, mandatory information is required in order to create a User account.

The mandatory information is as follows: 

- Last name;

 - First name;

 - Email address;

 - Phone number;

 - Password (encrypted).


   It is specified that DYNAMIC SCREEN will not have access to the password set by the User.

3.3 It is specified that the use of certain Services does not require the creation of an account. The User who does not create a User account will be asked for a certain amount of mandatory and optional information to use said Services. 

The mandatory information is as follows:

- E-mail address

.
 The following information may also be required where applicable:

Name - Last name;

 - First name;

 - Telephone number.


- Data relating to the socio-professional situation of the User
 - Connection data when the User accesses and uses the Platform
 - Details of correspondence with DYNAMIC SCREEN and in particular in case of assistance;

 - Cookies;

 - Banking and financial data;

 - Transaction data;

 - Authentication data.

3.5 DYNAMIC SCREEN may further collect information regarding how Customers and Users use the Services, such as the types of content, activities, Services used or interacted with by Customers and Users, features used, actions taken, and the time, frequency and duration of activities, rentals and other recordings.  

It is specified that certain data and information are collected through the interactivity that may be established between the Client and/or User and the COMEEN Platform and/or Visitors in the following ways:

- Statistics;

 - Contact;

 - Management of the Platform.
 Translated with www.DeepL.com/Translator (free version)

4. Origin and purpose of the Personal Data collected

The Personal Data of Users and Customers, if any, are collected directly and solely from Customers and Users of the COMEEN Platform.

DYNAMIC SCREEN undertakes to collect the express consent of the persons concerned and to allow them to object to the use of their Personal Data for any other purpose, as soon as this is necessary. 

In all cases, Customers and Users are informed of the purposes for which their Personal Data is collected via the various online data collection forms and via the actions of the Customer and/or User on the COMEEN Platform. DYNAMIC SCREEN also uses cookies and/or log files. 

It is in any event recalled that the Personal Data collected is necessary for the proper performance of DYNAMIC SCREEN's services and to enable it to comply with its legal obligations. 

Without them, DYNAMIC SCREEN may not be able to provide all the services offered on the COMEEN Platform.

The collection, storage and processing of this information and Personal Data is primarily for the purpose of:

- To facilitate the assistance services provided by the customer relations department

 - To allow to send to the Users the publications, communiqués and information of DYNAMIC SCREEN and COMEEN at their request

 - To provide information to potential future purchasers/merger partners, if any, in connection with the outsourcing, sale or consolidation (including by acquisition) of all or part of DYNAMIC SCREEN;

 - To enable DYNAMIC SCREEN to manage its business relationships, if any, with its service providers and partners

 - To improve the products and services of DYNAMIC SCREEN

 - To allow DYNAMIC SCREEN to make statistical analysis.

5. Non-disclosure of Personal Data

5.1 DYNAMIC SCREEN undertakes not to market the Personal Data of Customers and Users collected. 

5.2 Personal Data may be shared with third party companies in the following cases:

- When the Customer or the User uses the payment services, for the implementation of these services, the Platform is in relation with third party banking and financial companies with which it has contracted;


 
 - When the Customer or the User authorizes a third party's website to access his/her Personal Data;

When the Platform uses the services of a third party;

When the Platform uses the services of a third party;

When the Platform uses the services of a third party
 - When the Platform uses the services of service providers to provide customer and user support, advertising and payment services. These service providers have limited access to the Customer's and/or User's Personal Data in order to perform these services and have a contractual obligation to use it in accordance with the provisions of the applicable regulations on the protection of Personal Data;

When the Platform uses the services of service providers to provide customer and user support, advertising and payment services, the Platform may use the Personal Data of the Customer and/or User in accordance with the provisions of the applicable regulations on the protection of Personal Data
 
 - if the Platform is involved in a merger, acquisition, sale of assets or receivership, it may be required to sell or share all or part of its assets, including personal data. In this case, Customers and users would be informed, before Personal Data is transferred to a third party.

5.3 DYNAMIC SCREEN generally keeps the Personal Data of Data Subjects within the territory of the European Union.

However, in the event that DYNAMIC SCREEN's partners and service providers are located outside of the European Union, the Personal Data thus collected may in this case be transferred to non-European Union countries, whose legislation on the protection of personal data differs from that of the European Union, it being specified that, in the event that the recipient country or countries do not ensure a level of data protection equivalent to that of the European Union, DYNAMIC SCREEN undertakes to take all appropriate safeguards, either on the basis of an adequacy decision or, in the absence of such a decision, on the basis of appropriate safeguards and conclude with the said subcontractors and partners specific contracts to frame and secure the transfer of Personal Data of Customers and Users, in particular on the basis of the adopted standard contractual clauses, a copy of which may be requested at the contact details below.

5.4 The list of DYNAMIC SCREEN's subcontractors may be communicated to the persons concerned upon request sent to the following email address: welcome@comeen.io.

DYNAMIC SCREEN is also likely to work with partners as co-processors, or as processors directly.

The list of these companies can be communicated to the persons concerned on request to the following email address: welcome@comeen.io.
Translated with www.DeepL.com/Translator (free version)

6. Duration of Data Retention

DYNAMIC SCREEN keeps the Personal Data of Customers and Users for the period strictly necessary for the purposes pursued, and in particular for the proper functioning of the COMEEN Platform and the Services offered, and the management of Customers and Users, in accordance with legal and regulatory requirements.

In any case, DYNAMIC SCREEN will delete the said Personal Data at the first request.

7. Legal basis for the processing of Personal Data

DYNAMIC SCREEN collects and uses the Personal Data of Customers and Users if this processing meets at least one of the bases below:


 
 - In compliance with the consent of Customers and Users, which can be revoked at any time through their personal account settings;

 - To the extent necessary to fulfill its legal obligations; and

 - To the extent necessary to pursue its legitimate interests (or those of others), unless those interests are overridden by the interests or fundamental rights and freedoms of Customers and Users requiring the protection of their Personal Data.

8. Rights of Clients and Users

Si le Client ou l’Utilisateur a des questions ou des réclamations concernant le respect par DYNAMIC SCREEN des présentes stipulations, ou si le Client ou l’Utilisateur souhaite faire part à DYNAMIC SCREEN de recommandations ou des commentaires, le Client ou l’Utilisateur peut contacter DYNAMIC SCREEN par écrit à l’adresse suivante : DYNAMIC SCREEN, 48 Rue Thiac – 33000 Bordeaux, France, ou par mail à welcome@comeen.io.In application of the Applicable Regulations, the Clients and Users of the COMEEN Platform expressly acknowledge that they have the following rights:

- Right of access, and in particular the right to obtain copies of all their Personal Data, as well as the essential details concerning the way in which the Data are processed;

Right to obtain the rectification of their Personal Data, within the limits of the lawbr>

 - The right to obtain rectification of their Personal Data, as soon as possible, and the right to have any incomplete, inaccurate, equivocal or outdated Personal Data completed;

The right to erasure of Personal Data


 - Right to the deletion of their Personal Data, as soon as their processing is no longer necessary, or as soon as the Customer has withdrawn his consent or has objected to their processing; or as soon as their collection, use, communication or conservation is forbidden;

 - The right to limit the processing of Personal Data;

The right to the portability of Personal Databr>

 - Right to the portability of Personal Data; and

 - Right to object to the processing of their Personal Data.


 If the Customer or User wishes to know how DYNAMIC SCREEN uses their Personal Data, to request rectification, to object to the processing of their Personal Data, to request deletion of their Personal Data, or to request a copy of all Personal Data in the possession of DYNAMIC SCREEN, the Customer should send their request by mail to DYNAMIC SCREEN, the request to be accompanied by a copy of a valid signed ID to the following address: DYNAMIC SCREEN, 48 Rue Thiac - 33000 Bordeaux, or by email to welcome@comeen.io.

Finally, Customers and Users may file a complaint with the supervisory authorities, including the CNIL (https://www.cnil.fr/fr/plaintes).

9. Security

DYNAMIC SCREEN takes all necessary precautions, in view of the personal nature of the data collected and the risks presented by the processing, to preserve the security of Personal Data concerning Customers and Users, and, in particular, to prevent such data from being distorted, damaged or accessed by unauthorized third parties.

DYNAMIC SCREEN implements all technical and organizational measures to ensure the security of the processing of Personal Data and the confidentiality of Personal Data. Persons working for DYNAMIC SCREEN are required to respect the confidentiality of the Personal Data of Customers and Users.

10. Log files and cookies

DYNAMIC SCREEN may collect certain information through log files and cookies, subject to the choices expressed regarding cookies at the time of connection, which can be modified at any time.

DYNAMIC SCREEN uses such files for the following purposes; it being specified that certain technical cookies are essential for the proper functioning of the Platform:

- Technical cookies

 - Cookies for audience measurement - production of statistics
.
 - Sharing cookies

 - Targeted or advertising cookies

11. Personal Data and minors

The Platform is intended for adults capable of entering into obligations in accordance with the legislation of the country in which the Customer is located.

Pursuant to the General Data Protection Regulation, the Customer who is a minor under the age of 16 or incapable must obtain the prior consent of his legal guardian before entering his data on the Platform. Unless legally required to maintain confidentiality, DYNAMIC SCREEN may directly inform such responsible person (i) of the specific categories of Data collected from the minor (ii) of the possibility to object to the collection, use or storage thereof.

The age of 16 years may be lowered to 13 years depending on the local regulations of the Customer's habitual residence, under the provisions of the General Data Protection Regulation.

12. Links to other websites and social networks

The Platform may contain links to the websites and platforms of DYNAMIC SCREEN's partners or third party companies. 

These websites and platforms have their own policies on the use of personal data and DYNAMIC SCREEN disclaims any responsibility for the use made by these sites of information collected when Customers and Users click on these links. 

13. Changes to the Privacy Policy and Use of Personal Data

DYNAMIC SCREEN reserves the right to make any changes to this Policy at any time in accordance with this clause. 

If DYNAMIC SCREEN makes a change to this Policy, DYNAMIC SCREEN will post the new version on the Platform and update the last updated date at the top hereof. 

DYNAMIC SCREEN encourages Customers and Users to review this page regularly.

14. To contact DYNAMIC SCREEN

If the Customer or User has any questions or complaints regarding DYNAMIC SCREEN's compliance with these provisions, or if the Customer or User wishes to make any recommendations or comments to DYNAMIC SCREEN, the Customer or User may contact DYNAMIC SCREEN in writing at the following address DYNAMIC SCREEN, 48 Rue Thiac - 33000 Bordeaux, France, or by email at welcome@comeen.io.