1. Identity and contact details of the Data Controller
2. Your data modification rightsIn compliance with the General Data Protection Regulation 2016/679 (GDPR), you have rights to access, modify and erase your own personal data.
You may exercise your rights by sending a registered mail to the Privacy data processor at the above indicated address.
Your request will be handled within 30 days.
We may ask you to provide a proof of your identity and/or authority together with your request.
3. DefinitionUnderstanding the precise and effective stakes of a European regulation is not always easy, even more when it consists in 99 articles, 173 “recitals” and numerous guidelines to clarify how it should be interpreted. It is nonetheless key to avoid misinterpretation risks (too wide or lack of precise interpretation of mandatory rules relative to personal data processing). A good understanding of the below defined wording is thus mandatory.
- Personal dataPersonal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier or to one or more unique features of his own.
- ProcessingAny operation or set of operations performed on personal data or sets of personal data whether or not by automated means (collection, recording, transfer, storage, conservation, extract, consultation, use, interconnection, etc….)
- Data ControllerThe natural or legal person, the public authority, the agency or other body – that on its own or in partnership with others - determines the processing objectives and means.
- Sub-contractor (Data Processor)The person or legal entity, the public authority, the service or any other entity that processes personal data on behalf of the Data Controller.
ePressPack is a Data Processor for his customer.
- ConsentBy subscribing a service or by filling in the contact form on our website, you agree and give the Data Processor a right to collect, process, store and/or use personal data submitted in the frame of the below regulations.
Your consent gives you a right to modify, a right to be forgotten and/or right to erase your personal data.
4. On Site Data collectionAs you anonymously browse our website, the following additional data may be collected and processed: IP addresses and navigation history, downloading history. Some data may be collected automatically following certain actions (see following paragraph related to cookies).
As you register on our site, the following additional data may be collected and processed: email, title, first name, name country, company and job description, and if appropriate, password, postal address, phone number and domain name (see registering form to identify the full list).
As an ePressPack customer, the following data will be collected and processed: your company administrative data, your orders history, claims, problems, information relative to subscriptions and exchanges between your company and ePressPack.
As a user of ePressPack solutions, the following data are collected:
The data submitted via ePressPack never include any sensitive personal data such as Government identifiers (Social Security number, driving licence, taxpayer ID numbers), complete credit card or bank account numbers, medical records or information relative to applications for care or treatment related to individuals.
Cookies are files saved on your computer’s hard drive when browsing on the internet and in particular on our site. A cookie is not used to gather your personal data without you being aware of it, but to collect information on how you browse which can be read directly by ePressPack on your future visits and searches.
You may choose to decline acceptance of all cookies, you would then reduce your ability to browse some of pages of the site. You would then not be able to access secured sections that require both login and password.
Audience cookies used by ePressPack are meant to provide website visit statistics, such as Google Analytics. ePressPack provides the Data Controller with these statistics while being able to recognize the visitor each time he next visits the site.
6. Processing purposesThe main purpose of your personal data collection is to offer you a safe, optimized, efficient and personalized service:
- To manage, publish/release/share multimedia contents for ePressPack customers,
- To access these data either in a privileged manner (using login/password) or in an anonymous way as anyone.
- Provide and facilitate the use of our services, including checking personal data.
- Solve any problems and improve the use of our site and services with the help of ePressPack teams,
- Personalise, assess and improve our services, contents and specs,
- Analyse the volume and history of how you use our services,
- Comply with our legal and regulatory obligations.
7. Data RecipientPersonal data collected on our site are intended exclusively for the Data Controller.
Within the frame of its activity and for technical purposes only, they can be transmitted to ePressPack or to ePressPack sub-contractors. ePressPack ensures compliance with data protection requirements for all its sub-contractors.
ePressPack will never sell or rent your personal data to third parties for marketing purposes.
ePressPack does not disclose your personal data to third parties, with the only following exceptions: (1) if the Data Controller (or the Account Administrator acting on your behalf) requests it or allows disclosure. (2) if ePressPack is requested to do so by a governmental authority or a regulation entity, a legal requisition, a summon, or any government or legal similar request, or to establish or to defend a claim.
8. E-mailingsePressPack solutions give its users the possibility to publish news on the internet and to e-mail them.
With these e-mailing tools, the Data Controller has access to personal data and can possibly manage them respecting applicable regulations.
- Distribution listsWithin the frame of this specific service, i.e. creation of e-mailing campaigns and distribution lists – ePressPack has access to all the information included in the emails distribution lists as established by the Data Controller. ePressPack also has access to the subject and content of emails sent using ePressPack services. The corresponding data are saved on secured servers and only a restrictive number of persons may access the distribution lists, necessary to support services.
The Data Controller can easily recover the distribution lists established from his ePressPack account at any time. The data Controller may also modify and/or delete contacts at any time also from his account.
In no event, does ePressPack sell, share or rent your contact lists to third parties; neither does ePressPack use them for another purpose than that set forth in this policy. ePressPack only uses this information for legal requirements, to invoice and provide the best possible customer support.
Being the author of contact lists and associated e-mailing campaigns, ePressPack customer is the Data Controller as expressed by the GDPR, ePressPack acting as a service provider. This implies the customer is responsible for:
- Making all necessary declarations to the data protection authority, or any other control authority,
- Complying with all applicable regulations,
- Obtaining the explicit and free consent of the concerned persons when collecting their personal data,
- Ensuring they own the right to use collected personal data in accordance with the defined purposes and refraining from any unauthorized use.
- E-mails trackingePressPack analyses and tracks opening and click rates as well as the number of emails sent to assess the performance of its customers emailing campaigns and to be able to report it to the Data Controller.
- UnsubscribingEach newsletter and e-mail sent via ePressPack solutions includes an unsubscribing link.
Unsubscribing is made easy by clicking the unsubscribing links included in each e-mail.
9. SecurityTo deliver its services, ePressPack sets the highest importance on its customers’ personal data security and integrity.
Thus, and in accordance with the GDPR, ePressPack is committed to take all necessary precautions to protect data security and in particular to protect data against any accidental or unlawful destruction, accidental loss, corruption, unauthorised circulation or access, as well as against any other form of illegal processing or disclosure to unauthorised persons.
To this end, ePressPack implements industry standard security measures to protect personal data from any unauthorised disclosure.
Moreover, to avoid all unauthorized access, to guarantee accuracy be maintained and the proper use of data, ePressPack has set in the appropriate electronic, physical and managerial procedures to protect information collected via these services.
Notwithstanding, there is no absolute safety from piracy or hackers. Therefore in the event of a security breach detection, ePressPack is committed to inform you as soon as possible and to use its best efforts to take all possible measures to neutralise the intrusion and minimise its impact.
It is necessary to keep in mind that any user - customer or hacker - who identifies a security breach and takes advantage of it, is liable to legal prosecution. In addition, ePressPack will take all necessary measures – including placing a claim and/or court action - to protect both its users data and rights, and its own rights and to limit the impact to a minimum.
10. Data retentionThe Data Controller and ePressPack on behalf of this Data Controller collects personal data to deliver properly the ePressPack service; ePressPack also collects information on how and how often its solutions are used. ePressPack retains this information in active databases, log files or any other types of files in compliance with applicable regulations.
ePressPack is not committed to store this information without any limitation of time. Access to part of this information is given to our customers if they have an active account with ePressPack (ePressPack customer) and for a period to vary with the nature of data; in all events, this period will not excess three months after the closing of the client account. Data may be erased anytime during the active use of the customer account, in compliance with the above described rules.
11. Data storage location and transfersePressPack is committed to inform you immediately – to the extend ePressPack is legally authorized to do so – upon any administrative or legal authority request relative to our customers’ data.
12. Other points specific to this site