TOLUNA and THE COMPANY are committed to respecting and protecting your personal data because it helps us to build a relationship of trust with you.
This will inform you of your rights regarding your personal data, the purposes for and grounds on which your data is processed, the recipients of your data, and the period for which your data is stored.
The reference texts for this policy are the General Data Protection Regulation (‘GDPR') and the French Data Protection Act (amended).
I. Roles and Definitions
- V. MANE FILS (the ‘Company'), as the data controller, decides how personal data is processed. The website www.mane.com sets out the Company's commitment to respecting and protecting your personal data.
- TOLUNA is a subcontractor that processes data on behalf of the data controller
- Data subjects are individuals whose personal data is collected or used.
- Members of the ‘Listen to your senses' community refers to individuals who register in the community, mainly in order to complete a survey sent by the data controller.
II. What personal data is collected?
The information we collect about you:
- Identification data – names (including first name, maiden name and married name), date of birth, family and marital status, sex, login and user name
- Contact information (e.g. your email address, postal address and telephone number)
You can provide your contact information through a form on our Website.
- Demographic/profile information - interests, preferences, opinions and answers to survey questions, including age, marital status, sex, date of birth, family situation, income, level of education and employment.
- Data relating to the device and browser
We collect information on your device and the application you use to access our services. ‘Data relating to your device' refers mainly to your IP address, your operating system version, type of device, information on the system and its performance, and browser type.
- Web page tag information
- Log data
Like most websites these days, our internet servers store log files that record data every time a device accesses our servers. Log files contain data on the nature of each access, including the originating IP address of the device, the internet service provider, files viewed on our Website (e.g. HTML pages, graphics, etc.), the operating system version, type of device and time stamping.
- Information on the referrer
If you are directed to the TOLUNA website from an external source (such as a link on another website or in an email), we record aggregated and non-personal information on the source that directed you to us.
- Information from third parties and integration partners
We collect your information or personal data from third parties if you authorise these third parties to share your information with us or if you have made it publicly accessible online.
III. Why do you use my personal data?
IV. What are the grounds for processing my personal data?
The legal grounds that allow us to process your personal data depend on the purpose for which it is processed, as explained in the following table:
Communication - customisation of messages
Communication - sending of emails for information purposes
Invitation to participate in surveys
Sending of rewards - e-gift vouchers
Consent to participate in the prize draw during registration on the website (tick box) AND acceptance of the prize by email
Communication - sending of newsletters
Consent to receive the newsletter during registration on the website (tick box)
Sending of products to test at home
Prior agreement when participating in a survey
Targeting of surveys (aggregated)
Voluntary completion of surveys sent
Analysis by target/profile (aggregated)
Analysis of panel activity (aggregated)
Processing of statistical data (e.g. merging responses to 2 different surveys)
V. How long will my data will be stored?
In accordance with the legal time frame, your personal data will be deleted after three years of inactivity on your part in the ‘Listen to your senses' community or in the month following your request to exercise your rights through this form on the Website.
VI. Is my data shared with third parties?
The COMPANY will not disclose your personal data to third parties, unless this is deemed necessary for the COMPANY's provision of services and their optimisation (for example, product home delivery). In this regard, your personal data may be disclosed to service providers.
The COMPANY may also ask TOLUNA to send you gift vouchers or manage your rewards. These third parties will therefore need your identification and contact information.
The COMPANY may also have to disclose your personal data to the relevant authorities (i) when the COMPANY is bound to do so by law or in the case of ongoing or future legal proceedings and (ii) to enforce and defend its rights.
VII. What are my rights when I give you my data?
The General Data Protection Regulation (GDPR) entered into force on 25 May 2018. This regulation aims to harmonise data protection laws across the European Union (EU). If you are an EU citizen, you may exercise the rights laid down in the GDPR and we will do our best to assist the COMPANY in responding to any requests it receives from survey participants.
Regardless of the purpose or legal basis on which your data is processed, you have the right to:
- Access the personal data that the COMPANY may have about you;
- Correct, add to or update your personal data;
- Delete your personal data (‘right to be forgotten')
- Limit or oppose processing of your personal data;
The COMPANY would like to make it clear that in this context, a request to delete your data or to limit or oppose processing of your data results in deregistration from the ‘Listen to your senses' community.
- Transfer your personal data;
You can access or correct your personal data, request for it to be deleted, or end your membership by logging in to your panellist account under ‘my profile'. Just follow the relevant instructions and your data will be updated automatically. Alternatively, you can send an email to email@example.com. We read all the emails we receive and reply to them individually. In most cases, changes are processed within 2-3 working days, but please allow up to two weeks for your status to be finalised. You may receive emails from us during this time period.
You can also exercise your rights vis-à-vis TOLUNA via the contact form, which can be accessed here.
Please note that in the case of a deregistration request, you will not be able to access and/or benefit from any of the community's services, and you will no longer receive messages from us. In addition, you forfeit any unused rewards balance at the time of deregistration. We also stop using your identification and contact information, except for archiving purposes, and we will process your personal data in accordance with our backup policies. Your identification data will subsequently be destroyed in accordance with our data storage policies, and we will continue to use the necessary security procedures and technologies to protect your personal data.
Lastly, we draw your attention to your right to make a claim to our data protection officer at firstname.lastname@example.org as well as the supervisory authority for data protection: the CNIL.
VIII. What security measures are taken to protect my data?
TOLUNA takes all necessary precautions to ensure the security and privacy of your data and, in particular, to prevent it from being changed, damaged or accessed by an unauthorised person.
IX. Cross-border personal data processing
The transfer of personal data outside the European Economic Area (EEA) to TOLUNA's international web hosting and backup services centre whose place of business or headquarters is based in the United States (Toluna USA Inc.), a country that does not have an adequacy decision issued by the European Commission, is governed by a data transfer agreement, which will include (i) the general contractual terms set out in the ‘European Commission Decision of 5 February 2010 (Decision 2010/87/EC)', or (ii) any other mechanism based on legislation concerning privacy or any other regulation concerning personal data processing. TOLUNA USA has confirmed its compliance with the Privacy Shield administered by the US Department of Commerce regarding the collection, use and storage of personal data transferred from the EEA to the United States.
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