Privacy Policy

This Privacy Policy (the “Privacy Policy”) outlines how M&L Company processes personal data, as well as the various rights data subjects hold over this data. This Privacy Policy may be subject to modifications, which will take effect on the date of publication of their update on the M&L Company website, without prejudice to rights acquired before such modification.

ARTICLE 1 – DATA CONTROLLER

The data controller refers to the person who determines the purposes and means of personal data processing, i.e., the one who defines the objectives for which this data is processed.

M&L Company, a SARL (limited liability company) with a capital of 7500 euros, registered with the Paris Trade and Companies Register under number 53178892500026, with its registered office at 2 bis rue Dupont de l’Eure – 75020 Paris (hereinafter the “Company”), publishes the Social Touch’ Website and acts as the data controller.

For any questions or requests regarding personal data, you may contact us by mail at M&L Company, Legal Department, 2 bis rue Dupont de l’Eure – 75020 Paris or by phone at 01 84 80 76 46.

ARTICLE 2 – NATURE OF PERSONAL DATA

Personal data is any information relating to an identified or indirectly identifiable natural person (in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural, or social identity).

ARTICLE 3 – COLLECTION OF PERSONAL DATA

As part of providing our services, we collect personal data directly from you when you fill out personal data collection forms and use the features made available to you on the Sites.

We may also collect personal data from third parties who act in connection with the provision of our services (particularly for the payment of our services).

Furthermore, we may collect and obtain personal data directly or indirectly following the analysis of your behavior when you interact with our site, in accordance with the rules applicable to cookies.

The personal data we collect may include, but is not limited to, your first name, last name, pseudonym, gender, email address, signature, photograph, postal address, details about your professional life, your exchanges and comments on our site, our web pages, your IP address, and your browser type and language.

We do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor do we process genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

If you provide us with personal data relating to a third party, it is your responsibility to ensure that all such data has been collected lawfully, fairly, and transparently, and that the third party does not object to this transmission.

ARTICLE 4 – PROCESSING ACTIVITIES

Beyond the personal data processed in connection with your requests to exercise your rights, we carry out, in connection with the publication of our Site, processing for the following purposes:

4.1 Management of your inquiries

To manage our responses to your inquiries, we process the personal data you provide to us in this context.
Data: identity, personal data related to inquiries.
Duration: inquiries and responses are kept for two years from the last contact.
Legal basis: consent (your expression of willingness to provide us with this data for processing in response).

4.2 Management of our relationships with our customers and prospects

To manage our relationships with our customers and prospects, we collect personal data relevant for customer management, management of unpaid invoices, commercial statistics, prospecting and information operations for prospecting purposes, and the management of rights of access, rectification, and objection.
Data: identity, address, email, phone, fax, internal processing code, data related to commercial relationship tracking (orders, contracts, customer exchanges and comments), data related to loyalty actions, prospecting, prospect selection, customer reviews and ratings on services, data related to transactions, data related to payment methods, invoices, transactional data.
Duration: customer data is kept during the contractual relationship and five years after its termination (statute of limitations). Prospect data is kept for a period of three years from the end of the commercial relationship or the last contact from the prospect.
Legal basis (customers): such processing is necessary for the performance of a contract or pre-contractual measures.
Legal basis (prospecting): such processing is necessary for our legitimate interests to promote our products and services in the market.

4.3 Website Management

We collect and process personal data relevant for the management of our Website and the protection of its cybersecurity.
Data: identity, functions, contact details, data related to navigation (IP address, timestamp, cookies) and on digital platforms via sharing and media buttons, user contact management data, technical service provider management data, and audience and online service usage data offered by M&L Company.
Duration: log data is kept for six months, data necessary for the production of audience and online service usage statistics is kept for thirteen months, exchange data with service providers is kept for five years at the end of the relevant contract.
Legal basis: such processing is necessary for our legitimate interests to implement monitoring actions for the operation and use of our Sites.
Legal basis, for non-exclusively technical cookies: consent.

4.4 Litigation Management

We collect and process personal data relevant for the preparation, exercise, and monitoring of disciplinary actions or legal remedies and, where applicable, for the execution of the rendered decision.
Data: identification data of defendants, victims, witnesses, and legal auxiliaries (names, first names, gender, date and place of birth, nationality, address, phone, email), data related to offenses, convictions, or security measures (disputed facts, information, documents, and evidence collected to establish the facts likely to be alleged, characteristics of the dispute (findings, testimonies, certifications, procedural acts, procedural documents), characteristics of the dispute, convictions, procedure tracking).
Duration: during the litigation and after the exhaustion of remedies, then archiving on a separate and secure medium if there is historical interest.
Legal basis: such processing is necessary for the performance of a contract or pre-contractual measures, in case of litigation related to a contract.
Legal basis: such processing is necessary for our legitimate interests to exercise our rights of defense, in case of litigation not related to a contract.

4.5 Partnership Management

We collect and process personal data relevant for the monitoring of partnership agreements, the realization of joint projects, internal and external communication, and the production of statistics.
Data: identity, contact details, projects monitored, exchanges related to project implementation, statistics.
Duration: partner data is kept during the contractual relationship and five years after its termination (statute of limitations).
Legal basis: such processing is necessary for the performance of a contract or pre-contractual measures.

4.6 Communication and Event Management

We collect and process personal data relevant for the management of our marketing and communication events (registrations, logistical organization, evaluation, statistics) and the sending of our commercial communications.
Data: identity, contact details, exchanges related to project implementation, statistics.
Duration: data for sending newsletters is kept as long as the data subject does not unsubscribe, press relations data is kept for five years, event-related data is kept for five years after the event in question, social media page data is kept for the duration of the existence of the relevant social media account (except for the right to erasure or objection).
Legal basis: such processing is necessary for our legitimate interests to implement communication actions to promote our creative services.
Legal basis: your consent (withdrawable at any time), for sending newsletters.

ARTICLE 5 – MANDATORY OR OPTIONAL NATURE OF PERSONAL DATA TRANSMISSION

In personal data collection forms, we specify the personal data that must be provided for the processing purpose in question. If these fields are not completed, M&L Company cannot implement the necessary actions for the considered processing purpose (for example, creating an account without an identifiable identity).

ARTICLE 6 – TRANSMISSION OF PERSONAL DATA

Generally, we do not transmit your personal data to third parties, but we may transmit your personal data to our subcontractors (who process such data on our behalf (such as our host)), to our partners who are involved in the proper execution of our services, to our partners responsible for controlling M&L Company’s commercial activities (auditor, services responsible for internal control procedures, lawyer, bailiff), and to organizations, legal auxiliaries, and ministerial officers as part of their debt collection or litigation management mission.

M&L Company may also be required to disclose your personal data upon injunction from public authorities, particularly to comply with personal data law requirements, national security, or more broadly, law enforcement.

M&L Company implements organizational and technical security measures adapted to the degree of sensitivity of your personal data to protect it against any malicious intrusion, loss, alteration, or disclosure to unauthorized third parties.

Your personal data is hosted and processed within the European Union. However, M&L Company may use certain service providers located abroad or who use subcontractors located abroad, including outside the European Economic Area (EEA). In such a case, the transfer of your personal data outside the EEA will be carried out by implementing appropriate safeguards, in accordance with applicable personal data protection legislation, notably through the case-by-case signing of contractual clauses based on the European Commission’s model or any other GDPR-compliant mechanism.

ARTICLE 7 – YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You benefit, within the limits defined by law, from the following rights

Right of access: you can obtain information relating to the processing of your personal data and a copy of this data;
Right to rectification: you can request the correction of your personal data that you consider incomplete or inaccurate;
Right to erasure: you can request the erasure of your personal data;
Right to restriction of processing: you can request the restriction of the processing of your personal data;
Right to data portability of your personal data: you have the right to have the personal data you have provided to us returned to you or, where technically possible, transferred to a third party, in a machine-readable format;
Right to withdraw your consent at any time if the processing is carried out on the legal basis of your consent (for example, for sending newsletters or for non-exclusively technical cookies);
Right to lodge a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés – cnil.fr) for any potential complaint;
Right to define directives regarding the retention, erasure, or communication of your personal data after your death;
Right to object: right to object to the processing of your personal data for reasons related to your particular situation.

ARTICLE 8 – MODALITIES FOR EXERCISING YOUR RIGHTS

If you have a question or comment regarding the content or implementation of our Privacy Policy, we invite you to contact us (01 84 80 76 46) for any clarification or additional information.

To exercise your rights, you may submit a request to us, enclosing a copy of proof of your identity, to one of the two following addresses: by mail at M&L Company, Legal Department, 2bis rue Dupont de l’Eure, 75020 Paris or by phone at 01 84 80 76 46.

A response will be sent to you within a maximum period of one (1) month following the date of receipt of your request. This period may, however, be extended by two (2) months given the complexity and/or number of requests.

ARTICLE 9 – COOKIES

A “cookie” is a string of information, usually small in size and identified by a name, which can be transmitted to your browser by a website you connect to. Your web browser will store it for a certain period and send it back to the web server each time you reconnect.

When a cookie is purely functional (memorizing information entered in forms, managing and securing access to reserved areas), its use does not require your prior consent. If it is not purely functional, its use requires your prior consent.

During your first visit to the www.socialtouch.io Website, we request your consent for the installation of non-purely functional cookies via a banner explaining the purposes of these cookies and a system for managing your preferences. You are free to configure, at any time, your potential consent or the withdrawal of your consent for the placement of non-purely functional cookies on your device.

The retention period for personal data resulting from the placement of cookies on your device is a maximum of 13 months.