Data protection policy

Infoelsa builds strong and lasting relationships with its Clients, based on mutual trust: Ensuring the security and confidentiality of its users’ personal data.

The purpose of this Privacy Policy is to inform you about our practices regarding the collection, use and sharing of information that you may provide to us through our website infoelsa.com and about the steps and commitments Infoelsa has taken to ensure that the data of our Customers and visitors is respected.

This policy may change according to the legal and regulatory context and the CNIL.

1. Data collected

Infoelsa takes care to collect and process only the data strictly necessary for the purpose for which they are processed.

By using the infoelsa.com site, you are led to transmit information to us, some of which are of a nature to identify you and therefore constitute data of a personal nature (hereinafter referred to as the “Data”).

When you visit our site, we collect data of the following types:

Account information: information you provide when filling out a registration form.
Navigation data: data that we collect indirectly during your navigation of the infoelsa.com site through the use of Internet technologies, such as “cookies”. Infoelsa undertakes to allow you to object to this, whenever necessary. (See 5. Cookies and Tracers Policy)

Finally, you provide some of this Data directly to us, for example when you send an application to Human Resources.

2. The treatments

The processing carried out by Infoelsa has an explicit, legitimate and specific purpose:

Contact form
Purpose	Respond to your requests for information, demonstration or documentation on our Solutions
Legal basis	This processing is based on your consent
Recipients	The data controller Infoelsa and its internal teams Sales and Marketing to respond to visitors’ requests Our subcontractor for hosting, maintenance and updating – under our control.
Transfer outside the European Union	No transfer outside the European Union- Data hosting in the EU
Shelf life	The time to process your request. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing carried out before the withdrawal of consent.

Carry out commercial actions
Purpose	Acquire new customers: You propose solutions related to your activity, you send invitations to events… Our prospects and customers file is linked to our commercial follow-up and allows to associate opportunities, quotations and orders to improve the quality of this follow-up.
Legal basis	This processing is based on the legitimate interest of Infoelsa
Recipients	The data controller Infoelsa, the Sales and Marketing teams within the DL Software Group Our Salesforce solution integrator for hosting, maintenance and updates, under our control.
Transfer outside the European Union	No transfer outside the European Union – Data hosted in the EU
Shelf life	Not applicable – Prospects may object to the processing and request the deletion of data at any time.

Application
Purpose	Review and respond to your application for a position
Legal basis	This processing is based on your consent
Recipients	The data controller and its internal HR teams as well as the HR Department of DL Software Group (parent company)
Transfer outside the European Union	No transfer outside the European Union- Data hosting in the EU
Shelf life	2 years, unless you give your explicit consent to retain beyond this period

Request for access rights or other rights related to the GDPR
Purpose	Responding to and managing requests for access rights or other rights arising from the European Data Protection Regulation
Legal basis	This processing is based on the respect of a legal obligation
Recipients	The data controller Infoelsa and its legal teams within the DL Software Group, if necessary the lawyers appointed to defend the rights of the data controller, the DPO.
Transfer outside the European Union	No transfer outside the European Union – Data hosted in the EU
Shelf life	The time of the legal prescription of the rights of the controller and/or the data subjects

These processing operations have been brought to the attention of our DPO (Date Protection Officer) via the prior formalities carried out with the latter.

3. Recipients of the data

Personal Data is not sold or rented.

Only authorized recipients determined within Infoelsa have access to it to meet the purpose.

In accordance with the regulations, they may also be communicated to the competent authorities upon request and in particular to public bodies, judicial auxiliaries and legally authorized officers (in particular in the event of a judicial requisition or right of communication).

We work closely with third party companies who may have access to your Data and in particular with our subcontractors and service providers who only act on our instructions. They are contractually bound to ensure a high level of security and confidentiality of your Data and to comply with applicable data protection regulations.

4. Security

Infoelsa is committed to a continuous approach to the protection of its users’ data,
in compliance with the French Data Protection Act of January 6, 1978 as amended (hereinafter “LIL”) and the General Data Protection Regulation (EU) of April 27, 2016 (hereinafter “GDPR”).

Infoelsa has a team dedicated to the protection of personal data, composed of :

A DPO within the DL Software Group (Data Protection Officer)
A CISO – Information Systems Security Manager

Infoelsa ensures the security of personal data by implementing enhanced data protection, including:

Implementation of appropriate organizational and technical measures to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties.
Our staff is subject to an obligation of confidentiality through the employment contract and an IT charter attached to our internal regulations. We also make our staff aware of privacy and security measures.

5. Cookies and Trackers Policy

Our website uses cookies or other tracking devices, hereafter referred to as “Cookies” for simplicity.

The law states that we may only store Cookies on your device if they are strictly necessary for the operation of this site or exempt from consent. For all other types of Cookies, we need your permission.

There are different types of cookies :

Necessary (2)

These necessary Cookies help make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these Cookies, they are essential and not subject to consent.

Name	Supplier	Finality	Expiration
ReCAPTCHA	Google	Distinction between robots and humans	Persistent
tarteaucitron	tarteaucitron	Explicit consent recovery	12 months

Preference (0)

Preference cookies allow a website to remember information that changes the way the site behaves or displays, such as your preferred language or region. They do not require your prior consent, but we do allow you to disable them if you wish.

Audience measurement or Statistics (Number)

Statistical cookies allow us to know the use and performance of our sites and to improve their operation. The service used for our site allows us to count the pages visited, the visitors and identify the way they use the site. They are subject to consent.

Name	Supplier	Finality	Expiration
Google Analytics	Google	Audience measurement, To distinguish users	12 months
Name	Description	Expiration	Name
__utma		This cookie is used to identify you as a unique visitor to our website and is updated each time the page is viewed. It contains a unique identifier that uses Google Analytics to help with data validity.	13 months
__utmb		This cookie is used to establish and maintain a session on our website. Each time a new page is visited, it is updated to and expires in 30 minutes.	30 minutes
__utmc		This cookie is used in conjunction with __ utmb to establish and maintain a session. If you choose to close your browser, this cookie expires – ending your session on our website.	End of Session
__utmv		This is a Cookie used to track visitor behavior and measure site performance.	13 months
_utmv		This Cookie allows us to know the site of origin by which you arrived on our site and also to know the keywords used in the case of a search in order to analyze and improve the referencing of our site.	6 months

Marketing or Advertising (2)

Marketing cookies are used to track visitors across websites. The purpose is to display advertisements that are relevant and interesting to the individual user and therefore more valuable to third-party publishers and advertisers. They are subject to consent.

Location-based advertising cookies are used to deliver advertising to you based on your location.

Name		Finality	Expiration
IDE test cookie)	Doubleclick.net Google	Measures advertising interactions (exposure, clicks), tracking cookie used by Google to improve your web experience including printing more relevant ads	12 months
CONSENT	Youtube	Measures completion rate (% of video views), storage of video viewing preferences	Persistent
VISITOR_INFO1_LIVE	Youtube	A cookie that YouTube sets to measure your bandwidth and determine whether you have the new or old interface.	Up to 3650 days
YSC	Youtube	This cookie is set by YouTube video on pages with embedded YouTube videos.	At the end of the session

Cookies and other third-party trackers depend on external processors, who may, if you accept these cookies, process personal data about you.

The issuance and use of these cookies and other tracers by third parties are subject to their own privacy policies. For more information about these treatments, you can refer to their privacy policy.

List of partners

6. Your rights

In accordance with the laws and regulations in force, in particular the General Data Protection Regulation (RGPD) and the French Data Protection Act (Loi Informatique et Libertés), you have the following rights: access, rectification, deletion, limitation, opposition, and when applicable: portability, withdrawal of consent, organization of the fate of your personal data in the event of your death

To exercise your rights, contact us at the following address: infoelsa@infoelsa.com or by mail at the following address: 122 av des Champs-Elysées, Paris 75008, accompanied by a copy of a signed ID.

7. Contact

If you have any queries regarding Infoelsa’s personal data protection policy, please contact infoelsa@infoelsa.com. We will do our best to respond to your queries in a satisfactory manner. If, for any reason, you consider that our response is not satisfactory, we inform you that you may file a complaint with the CNIL.