Privacy Policy

Respect for your personal data is of paramount importance to us.

In its Privacy Policy, SOGEC MARKETING aims, above all, to express as transparently as possible the conditions of use of any information collected as part of the management of promotional-relational activities.

In terms of the collection and processing of personal data, SOGEC MARKETING guarantees compliance with law n° 78-17 of 6 January 1978 relating to data processing, files and modified freedoms, and with regulation 2016/679 of 27 April 2016 (GDPR)

With regard to our QUOTY mobile application: Participation in any promotional or relational offer on the Quoty platform (for which SOGEC MARKETING acts as data controller) requires the acceptance of a separate Privacy Policy specific to Quoty which we invite you to read at : https://quoty.app/pdf/privacy_fr.pdf.

With regard to sales and recruitment activities: Visiting the website, downloading marketing content, subscribing to a newsletter and/or applying for a job offer requires acceptance of the Privacy Policy and therefore of the procedures undertaken in the collection and processing of your personal data.

SOGEC MARKETING’s privacy policy is governed by the conditions set out below.

1. DEFINITIONS

Personal data / Data of a personal nature: Concerns any information relating to an identified natural person or person who can be identified, directly or indirectly, by reference to one or more elements which are specific to him or her.
Processing of personal data: Any operation or set of operations relating to a person’s data constitutes a processing of that personal data, whatever the process used, but in particular its collection, recording, organisation, storage, adaptation or modification, extraction, consultation, use, communication by transmission, broadcasting or any other form of provision, reconciliation or interconnection, as well as blocking, erasure or destruction.
Data controller: entity that collects and processes personal data, having previously specified the purposes and means of processing.
Recipients: a natural or legal person, public authority, service or any other body that receives the data, whether or not it is a third party.
Data subject: natural person whose personal data is subject to the processing.

2. FIELD OF APPLICATION

With regard to our commercial activities and recruitment: This Privacy Policy applies to all our webpages: http://sogec-marketing.com/ (referred to as the “website”) and to all existing commercial and marketing relationships between SOGEC MARKETING and its clients, prospects and business partners.

DATA CONTROLLER: The personal data controller in this instance is SOGEC MARKETING, a simplified joint-stock company with capital of 80,000 euros, registered in the company register of Evry under number 332 444 033, and whose head office is located at 17 avenue du Québec, 91140 Villebon sur Yvette, France.

3. DATA PROTECTION OFFICER

Sogec Marketing, as part of La Poste Group, has a Data Protection Officer who can be contacted at the following address: Data Protection Officer – CPC703 – 9 rue du Colonel Pierre Avia – 75015 PARIS 

4. COLLECTION OF PERSONAL DATA

4.1 PERSONAL DATA COLLECTED IN THE CONTEXT OF COMMERCIAL ACTIVITIES:

 

DATA COLLECTED

SOGEC MARKETING may collect and process the following personal data with your consent:

– Last name;

– First name;

– Date of Birth;

– Gender;

– Home address;

– Postcode

– City

– Email address;

– Telephone number (landline, mobile);

– Date of Birth;

– Company postal address;

– Work email address;

– Telephone number (landline, mobile);

– Intra-community VAT number; – IBAN / BIC;

– Content of a receipt;

– Lifestyle, purchasing habits, family situation and centre of interest;

– Complaints, incidents;

As well as information concerning your use of the sogec-marketing.com site  (such as your IP address, type of browser, the web page from which you received access to the website) and the data connection of your mobile device, as well as geographic location data (if applicable).

Whether the provision of such data is mandatory or optional is indicated during collection using an asterisk.

DATA RECIPIENTS

The personal data collected as part of the management and processing of any promotional-relational operation is destined for clients who have mandated SOGEC MARKETING to manage their operations.

Such data may be transmitted to subcontracting companies which the company SOGEC MARKETING occasionally employs for the execution of its services.

SOGEC MARKETING does not transfer or rent personal data to third parties for marketing purposes, without participants’ express consent for such operations.

Apart from these instances listed above, personal data can only be disclosed to third parties in the following cases:

• With the authorisation and consent of the persons concerned;

• At the request of the legally competent authorities, upon judicial requisition, or in the context of a legal dispute.

PROCESSING OF PERSONAL DATA

As part of the management and processing of promotional-relational operations on behalf of its customers, SOGEC MARKETING may collect personal data.

These data are processed in accordance with the purposes specified during collection, namely:

– Executing the contract concluded between the client and Sogec Marketing, concerning the management of participation in promotional-relational operations;

– Managing user participation in a promotional-relational offer (sending of the prize, transmission of relevant email, issuance of a transfer, etc.);

– Determining the gain in a promotional-relational operation;

– Processing and verifying the terms of the transaction;

– The proper functioning of platforms, applications and websites.

If the data is used for other purposes, SOGEC MARKETING undertakes to obtain the prior consent of the persons concerned before implementing such processing.

The mandatory or optional nature of any data that the Data Subjects may be required to provide will be indicated on the collection forms with an asterisk. They will be informed of the possible consequences for them of a failure to respond.

In any event, SOGEC MARKETING undertakes to process all the data collected in accordance with Law n° 78-17 of 6 January 1978 relating to IT, files and freedoms as amended by the law of 6 August 2004 and regulation 2016/679 of 27 April 2016 (GDPR)

4.2 PERSONAL DATA COLLECTED IN THE CONTEXT  OF RECRUITMENT

DATA COLLECTED

SOGEC MARKETING may collect and process the following personal data during recruitment:

– Last name;

– First name;

– Home address;

– Email address;

– Telephone number (landline, mobile);

– CV;

– Cover letter ;

DATA RECIPIENTS

The personal data collected is destined for SOGEC MARKETING’s Human Resources department.

5. PURPOSES AND LEGAL BASIS OF PROCESSING

Processing	Purpose	Legal basis
Management of commercial activities	Sending of marketing and commercial content (newsletter).	consent
	Portal management: to know and monitor the results of promotional campaigns	Execution of the contract
	Management of requests via contact forms	consent
Recruitment	Management of candidate applications	Pre-contractual measures
	Building a CV-library	Legitimate interest

6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

The company SOGEC MARKETING will not disclose your personal data to third parties, except when this proves necessary for the proper provision of SOGEC MARKETING’s services or solutions and the optimisation of such services and solutions (such as, but without limitation, maintenance work, payment processing, database management). If, in this context, it should prove necessary for SOGEC MARKETING to disclose your personal data to third parties, the third party concerned will be required to use your personal data in accordance with the provisions of this Privacy Policy.

7. DATA RETENTION PERIOD

The personal data collected by the company SOGEC MARKETING relating to the management of commercial activities (in particular, identity and contact details of clients, prospects and stakeholders) are kept for a period of three years following the termination of the contractual client relationship, or dating from the time of their collection by the data controller, or last contact by the prospective client for data relating to the latter.

The termination of contractual relations is understood as the express termination of the contract by the customer or the non-use of the solutions and services of the company SOGEC MARKETING for a period of three years.

The personal data collected by the company SOGEC MARKETING relating to recruitment are kept for a period of two years from the last contact with the unsuccessful candidate.

8. DATA TRANSFER OUTSIDE THE EUROPEAN UNION

SOGEC MARKETING has already implemented and signed standard contractual clauses of the type adopted by the commission with its non-EU partners, in accordance with article 46 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016. SOGEC MARKETING makes these standard contractual clauses available on request.

9. SUBCONTRACTING

In order to fulfil deadline and service provision requirements for its clients, SOGEC MARKETING in its capacity as initial subcontractor is authorised to have recourse to subcontractors to carry out part of its contractual obligations.

In particular for the following services:

• Handling consumer participation and the input of information (opening envelopes and the capture and checking of information);
• The storage, archiving and destruction of the contents of the envelopes;
• The management of the consumer relationship (handling of consumer contacts relating to operations, response and support for the production of a call report.

On the date of this commitment, the subcontractors that SOGEC MARKETING may potentially use for the processing mentioned, depending on workloads and busy times are:

Last name	Location	Area
Médiapost Hitmail	42-46 Siriului Street, 3rd floor, 1st section, 1st District, Bucarest, Romania	Opening and capture, Storage and archiving
Data Embassy	438, ZI Sidi Ghanem 40000 Marrakech, Morocco	Opening and capture, Storage and archiving
Vivetic	Zone Galaxy – Andraharo Immeuble US, Antananarivo Madagascar	Consumer relations

9. EXERCISE OF PERSONAL RIGHTS

Any individual subject to personal data processing has the right to exercise their rights of access, rectification, erasure, opposition, and / or limitation to the processing of their data in accordance with articles 15 and following of Regulation 2016/679 of 27 April 2016, the withdrawal of consent if the processing takes place on this basis, as well as a right to define post-mortem guidelines in accordance with article 40-1 of law n° 78-17 of 6 January 1978 as amended relating to data processing, files and freedoms. Individuals can also exercise the right to the portability of their personal data.

These requests will be processed within a maximum of 30 days from receipt. The user can unsubscribe from our newsletter or marketing emails by following the unsubscribe links in each of these emails.

The user can exercise these rights by sending an email to exercicedroitdespersonnes@sogec-marketing.fr or by post, including the information necessary in order to carry out this action along with proof of identity (copy of identity document or passport) to:

Sogec MARKETING – Exercise of personal rights

Customer service

17 Avenue du Quebec

91140 Villebon sur Yvette, France

In the event of any issue regarding the management of your personal data, you can submit a complaint to the CNIL (French Data Protection Authority).

You are informed of the existence of the “bloctel” list for objecting to telephone solicitation, to which you can subscribe at: https://conso.bloctel.fr

10. KEEPING YOUR INFORMATION SECURE

SOGEC makes every effort to protect your personal data and thus limit the risk of loss, deterioration or misuse of the same.

These measures include the following:

• Multi-level firewall,

• Tried and tested anti-virus and anti-hacking software,

• Encrypted data transmission using SSL / https / VPN technology

In addition, access to processing by recipient Sogec MARKETING services requires authentication of the persons accessing the data, by means of an individual access code and password, which is sufficiently robust and regularly renewed.

11. PLACE OF DATA CONSERVATION

The hosting servers which Sogec MARKETING uses for processing and storing its databases are exclusively located within the European Union.

12. COOKIES

 The SOGEC MARKETING company site and sites developed by the company SOGEC MARKETING as part of its management activity use cookies. The purpose of these cookies is to facilitate navigation on the site, to carry out the services and functions provided by the company SOGEC MARKETING, and to measure site audience or allow the sharing of site pages.

We may use cookies to optimise user experience on sites developed on behalf of our customers and to provide an optimised user experience. The purpose of cookies is to identify a workstation as well as detailed information pertaining to its precise technical specifications in order to improve support for it.

Although most web browsers automatically accept cookies, you can change your browsing settings so that you no longer accept them or so as to receive alert notifications when they are sent again. By refusing a cookie, your user experience when using one of our services is likely to be impacted.

TYPE OF COOKIES USED

Cookies necessary for navigation on the site :

These cookies are necessary for the correct functioning of sites developed by the company SOGEC MARKETING. They enable use of the main services and functions offered by these sites. If use of this type of cookie is not allowed, users will not be able to use the site normally.

Functional cookies:

These cookies make it possible to personalise site user experience.

Analytical cookies:

These cookies give us information about site use and performance, enabling us to improve its operation by analysing information page visits, and monitoring open rates, click-through rates and bounce rates at the individual level.

Share button cookies:

These social cookies allow users to share pages and content on third party social networks through social share buttons.

LIST OF COOKIES USED

Cookies necessary for the operation of the site:

Cookie name	Editor	Purpose	Length of conservation
Axeptio_cookies	Axception	Saves your choices regarding cookie consent	13 months

Statistical and audience measurement cookies:

Cookie name	Editor	Purpose	Length of conservation
To be completed

Advertising cookies:

Cookie name	Editor	Purpose	Length of conservation
To be completed

Cookies specific to social networks :

Cookie name	Editor	Purpose	Length of conservation
To be completed

COOKIE DURATION

French Data Protection Agency (CNIL) recommends a 13-month maximum period for the validity of consent to the placing of Cookies. At the end of this period, you will be asked for your consent again.

Consequently, cookies have a limited lifespan of 13 months from the time they are placed on your terminal device.

NAVIGATION SOFTWARE SETTINGS

In terms of cookie management and your choices, each browser is configured differently. To know how to change your cookie preferences, consult your browser’s help menu.

For Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies,

For Safari™: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html,

For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647,

For Firefox™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies,

For Opera™: http://help.opera.com/Windows/10.20/fr/cookies.html,

etc.

MORE INFORMATION ABOUT COOKIES

For more information about cookies, you can consult the French Data Protection Agency (CNIL) website:

https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs

13. MODIFICATION OF THE PRIVACY POLICY

Sogec MARKETING reserves the right to change this Privacy Policy in order to comply with changes in the laws and regulations in force.

As far as possible, notification of changes made will be displayed on our website, at least thirty days before their entry into force.

14. CONTACT

For any questions regarding Sogec MARKETING’s Privacy Policy, you can contact us by email at: exercicedroitdespersonnes@sogec-marketing.fr

Or by writing to us at:

Sogec MARKETING – Exercise of personal rights

Customer service

17 Avenue du Quebec

91140 Villebon sur Yvette, France

Or by phone at: 01 69 79 10 00

(the service is free aside from the cost of the call)