Privacy and personal data protection policy on the Internet
The Why Factor Company, whose registered office is located at 21, rue du Faubourg Saint-Antoine 75011 Paris, in its capacity as data controller, has an interest in the protection of personal data and privacy of any person accessing our digital ecosystem.
The purpose of this policy is to inform you, in accordance with Regulation n°2016-679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and the free circulation of such data (hereinafter referred to as the “Regulation”), and in accordance with the amended Law n° 78-17 relating to information technology, files and freedoms, of our practices concerning the collection, use and sharing of information that you may provide to us through our website.
The purpose of this policy is to inform you about the categories of personal data that we may collect or hold about you, how we use them, with whom we share them, how we protect them, and the rights you have over your personal data.
By continuing to browse this website (hereinafter referred to as the “site”), the user of the site acknowledges having read this policy as well as the general conditions of use of the site of which it forms an integral part.
1. Who collects personal data (Identity of the data controller)?
Your personal data is collected by The Why Factor Company – 21, rue du Faubourg Saint-Antoine 75011 Paris – SAS – registered under SIREN number 883 784 308 at the Paris Trade and Companies Registry.
The Why Factor Company has appointed a personal data protection officer who can be contacted by clicking here or by e-mail at the following address: dpo@thewhyfactorcompany.com.
2. What personal data is collected?
The notion of “personal data” refers to any information relating to an identified natural person or that can be identified, directly or indirectly.
By using our site, you are led to send us information, some of which is likely to identify you and therefore constitutes personal data. This is notably the case when you complete the contact form or newsletter registration form.
Personal data is information about you that allows you to be identified, such as:
| Identification data |
|
| Professional life |
|
| Login data | IP address, browsing history, click stream, operating system, information about the devices from which you access the website, etc. |
For any other data collected elsewhere, the data collection form will describe the rules applicable to the data so collected in the event that they are different from the rules contained in this Policy.
At the time of Data collection, you will be informed whether certain Data is mandatory or optional. The Data identified by an asterisk in the collection form is mandatory. Failing this, the execution of your request may be restricted.
In the event that you connect to our services using the social network functionalities made available to you, we will have access to some of the Data (in particular your first name, surname, photograph, e-mail address and number of Facebook friends) of your account on the said social network in accordance with the general terms of use of the social network concerned. We may also collect some of your Data when you interact with features of these social networks, such as “Like” features.
3. When do we collect Personal Data?
The Why Factor Company collects your personal data in an explicit and transparent manner through the presence of informational notices or references to this Policy.
Your personal data may be collected when you :
- browse the website,
- fill in any form on the website or leave a message,
- subscribe to our newsletter,
- would like to receive a catalogue or information about our expertise,
- correspond with us by phone, e-mail, social networks, forum or any other means,
- apply for a job offer,
- report a problem or request assistance.
4. For what purposes are personal data collected? What is the legal basis for the processing?
The collection and processing of your personal data is only possible for a specific purpose, which is specified to you at the time of collection.
The Why Factor Company undertakes to collect personal data only for precise, explicit and legitimate purposes and not to subsequently process this data in a manner incompatible with these purposes.
The Why Factor Company undertakes to collect and process only personal data that is adequate, relevant and not excessive in relation to the purposes for which it is collected.
We use the data we collect in order to :
| Purposes | Legal basis |
| Responding to your requests | Consent |
| Managing recruitment | Execution of pre-contractual measures |
| Communicating with you about our products and services and providing you with marketing information | Consent |
| Operation, maintenance and improvement of the website | Legitimate interest |
5. Who are the recipients of my personal data?
The data collected by The Why Factor Company is intended for us in our capacity as data controller.
The Why Factor Company undertakes not to sell, rent or transfer your personal data to third parties without your prior and express consent.
The Why Factor Company may, however, share your personal data with other entities.
5.1 Data transferred to third parties
We work closely with third party companies that may have access to your data, including :
- Our service providers and subcontractors. In particular The Why Factor Company may use third party service providers to host the web site, provide services related to the operation of the site, maintain the site, send communications and commercial offers. We only provide these third parties with the data they need to carry out their services, and we require that they do not use your data for any other purpose. These third parties will only act in accordance with our instructions and are contractually obliged to ensure the same level of security and confidentiality of your data as we do and to comply with the applicable regulations on the protection of personal data.
- Our commercial partners (Google, Hubspot, GetQuanty) and our other entities of the Insign Group within the European Union (http://agenceproches.com/fr, https://insign.fr/) subject to your express and prior agreement, so that they can offer you special offers and advertisements ;
We may also transfer your personal data to any potential buyer in the event of a sale of any The Why Factor Company entity or its assets.
5.2 data transferred to the authorities and/or public bodies.
In accordance with the regulations in force, the personal data collected by The Why Factor Company may be transferred to the competent authorities on request and in particular to public bodies, court officials, judicial officers, bodies responsible for debt collection, exclusively to meet legal obligations, as well as in the case of the search for the perpetrators of offences committed on the internet.
6. How long will my personal data be kept?
The Why Factor Company keeps your personal data in a secure environment for the time necessary to achieve the purposes for which it was collected, in accordance with the retention periods resulting from recommendations of the CNIL and/or provided for by applicable legislation.
| Purposes | Retention time |
| Responding to your requests | 3 years after the last contact |
| Managing recruitment | 24 months |
| Communicating with you about our products and services and providing you with marketing information | 3 years after the last contact |
| Operation, maintenance and improvement of the website | 12 months |
7. Is my personal data transferred outside the European Union?
The personal data collected is not transferred outside the European Union. They are hosted in France.
8. How is my personal data protected?
The Why Factor Company takes technical and organisational protection measures to ensure the confidentiality and security of your personal data and to prevent it from being modified, damaged, deleted or accessed by unauthorised third parties.
Only personnel who are authorised to access your personal data by virtue of their duties are granted access to your personal data. They are also bound by an obligation of confidentiality.
In the event of a violation of your personal data, The Why Factor Company is obliged to notify the competent supervisory authority (CNIL) and to inform you as soon as possible of any violation of personal data that may create a high risk for your rights and freedoms, so that you can take appropriate measures.
9. What are my rights and how can I exercise them?
In accordance with the applicable regulations, you have the rights of access, rectification, deletion, limitation of the processing of your data, opposition to the processing and portability of your data.
Where processing is based on your consent, you also have the right to withdraw your consent at any time.
You also have the right to lodge a complaint with the CNIL or with a data protection authority of a Member State of the European Union and to define post-mortem directives.
You may exercise your rights at any time by e-mail to the following address: dpo@thewhyfactorcompany.com.
With regard to commercial canvassing, you have the right to object and may at any time choose to no longer receive commercial canvassing by using the unsubscribe link in the message.
10. Protection of personal data of minors
The site is not intended for minors under the age of 15.
However, if you are a minor and you have transmitted personal data about yourself, you guarantee that you have obtained prior authorisation from one of your parents, The Why Factor Company declines all responsibility in the event that such authorisation has not been obtained. All parents and guardians are encouraged to encourage responsible and prudent behaviour on the part of minors when communicating their personal data on the Internet.
11. Links to other websites
The Why Factor Company site may contain links to third party sites to which The Why Factor Company is not affiliated.
The Why Factor Company has no control over these sites and cannot be held responsible for their content or the use they make of your personal data.
To ensure the protection of your personal data, we recommend that you consult the privacy policy of any other site that you access through a link on one of our websites. In all circumstances, we disclaim all responsibility with regard to these policies.
12. Changes to the Policy
The Why Factor Company reserves the right to modify the Policy at any time and without notice, in particular in order to comply with any regulatory, jurisprudential, editorial or technical evolution. If necessary, this modification will be indicated on the site and will be effective as soon as it is published. The date of modification will be inserted at the top of this policy.
We invite you to regularly consult this page to be aware of any changes and updates to this policy.
13. Contacting The Why Factor Company
If you have any comments or questions about this document, to exercise your rights, or for any request relating to your personal data, you can write to :
- by email: at dpo@thewhyfactorcompany.com;
- by post: at the following address The Why Factor Company SAS 21, rue du Faubourg Saint-Antoine 75011 Paris.
For any information on the protection of personal data, you can also consult the site of the Commission Nationale de l’Informatique et des Libertés (CNIL) www.cnil.fr.
