PRIVACY AND PERSONAL DATA MANAGEMENT POLICY
The KOALYZ company supports companies in the organization of their control analyses and in their analytical subcontracting projects.
Within this framework, KOALYZ company publishes a solution in SaaS mode, under the name CIKLAB, accessible via Internet allowing the organization, the piloting and the management of the cycles of controls and analyses of products.
To deliver the Solution and its services, the KOALYZ company needs to collect and process personal data. The KOALYZ company attaches great importance to the use of personal data and to the respect of private life. It commits itself to do everything possible to guarantee the confidentiality and the security of the information.
Users of the Solution will be notified of any significant changes made to this Policy. In the event of modifications, these will only apply to users of the Solution and services after their implementation. At any time, they are free to stop using the Solution and its Services.
For a perfect understanding, the KOALYZ company places at the disposal of the Users a Glossary. The terms used in the document have the following meaning:
“Client” refers to the subscriber of the CIKLAB user license contract allowing access to the CIKLAB solution published by KOALYZ.
“Solution” refers to an application solution named CIKLAB accessible via the Internet, published by KOALYZ and which offers its products and services to its professional clients and their users.
“Personal Data” or “Data“: means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, an online identifier, or to one or more elements specific to his or her physical, physiological, genetic, psychological, economic, cultural or social identity.
“Partners“: means the various service providers and suppliers of goods of the KOALYZ company for the realization of the services and supply of the products via the Solution.
“Personal Data Regulations“: means together the General Data Protection Regulation n°2016/679 (hereinafter RGPD), the Law 79-17 of January 6, 1978 relating to data processing, files and freedoms as amended, the Law of the Digital Republic n°2016-1321 of October 7, 2016 and any new law, decrees taken for their application.
“Services” means the services provided by the KOALYZ company via the Solution, including the associated support services.
“User“: means any person authorized by the Client (administrator, supervisor, contributor, visitors) with secure personal access (login and password) to the CIKLAB Solution who has entered and/or integrated Personal Data via the Solution.
DATA CONTROLLER – DATA PROTECTION OFFICER
The person in charge of the treatment is the company KOALYZ, SAS with a capital of 20.000 €, registered at the RCS of Rouen under the number 883 364 366, whose head office is located at 107 allée François Mitterrand, 76100 Rouen.
The contact details of the company KOALYZ are as follows: Email : email@example.com – Tel : +33(0)9 72 31 81 06
LEGAL BASIS OF THE IMPLEMENTED TREATMENTS
The data that the KOALYZ company collects are those which are used:
- To execute a license contract subscribed by the Customer or at a request prior to the conclusion of a contract;
- To provide the Customer and the Users with the Solution and its services;
- To comply with the legal obligations incumbent upon it;
- To ensure the performance of a task in the public interest;
- To protect the security of its systems and to detect and prevent fraud.
In any case, the KOALYZ company makes sure not to disregard the interests or fundamental rights and freedoms of the users by allowing them, at any time, to oppose, to all or part of the treatments described in the present Policy of Confidentiality and Management of the Personal Data.
WHAT PERSONAL DATA ARE COLLECTED?
Various information is collected about the User and from the User.
The Data that are collected are the following:
- Data voluntarily declared by the Customer when placing an order (signed order form): name of the structure/Customer, registration number, name and first name of the representative of the structure/Customer, referent designated by the legal representative, telephone, postal address, e-mail address;
- The Data declared in a voluntary way by the Customer at the time of the creation of his account via a request for access to the services provided by the company KOALYZ. For example: title, name and first name, e-mail address;
- The Data entered by the Customer and/or the Users designated by him in order to deliver the Solution and its services;
- The traceability of accesses by users in order to deliver the Solution and its services: Date of connection, login, encrypted password, user name, company (code), role (code), name of the database, email, status
- Technical data: Session cookies (login and password) stored 365 days on the user’s computer;
ACCESS TO THE SOLUTION
The Solution is accessible only to natural person Users expressly designated by the Client of the KOALYZ company who has subscribed to a CIKLAB user license.
USE OF PERSONAL DATA
The Personal Data collected and processed have for object the provision of the Solution and its Services, their use, their improvement and the maintenance of a secure environment.
The treatments operated by the KOALYZ company are based on the realization of the contractual relation, the legitimate interest of the KOALYZ company or the collection of the user’s consent if necessary.
The uses are the following:
- Initiation of a contractual relation between the KOALYZ company and the Customer who intends to benefit from the Solution and the services proposed by the KOALYZ company.
- Access and use to the Solution and to the Services provided by the company KOALYZ by the Customer, and the Users designated by him, within the framework of the execution of the contract of license of use of the Solution.
- Management of the functioning and optimization of the Solution and its Services
- Organization of the conditions of Use of the Solution and its Services
- Implementation of a technical assistance of the Solution by KOALYZ
- Operations relating to the prospection, information, statistics
- Management of the unpaid and litigations
- Implementation of security measures, prevention of computer fraud and management of security incidents
- Personalization of the communication and commercial solicitation to the attention of the Users in particular by electronic mail
The personal data collected by the KOALYZ company can be intended for its partners, suppliers and subcontracting providers exclusively for purposes of management and exploitation of the Solution and the proposed services, in particular hosting, and to the public organizations and police authorities in the event of request etc, according to its instructions and in the respect of the policy of confidentiality and management of the personal data. The intervention of each of the external providers is strictly limited to the service which it carries out for the account of KOALYZ.
The KOALYZ company makes sure that its subcontractors present the sufficient guarantees to ensure the implementation of the measures of safety and confidentiality of the Data to which they have access in the exercise of their missions such as defined by the applicable regulation in the matter.
The recipients of your personal data are the following:
- the technical and administrative services of the KOALYZ company;
- the technical service providers of the KOALYZ company, in charge, in particular, of the hosting of the sites and Solutions published by the KOALYZ company;
- the public authorities if the law requires it, to follow up on the complaints presented to the KOALYZ company and to comply with the administrative and legal procedures, or to comply with a legal obligation.
No Personal data collected and processed is transmitted by the company KOALYZ to a third party for commercial purposes. On the assumption that the company KOALYZ would be brought to make it, the user will be expressly informed and his consent required as a preliminary.
HOSTING OF PERSONAL DATA
All processing of your personal data is carried out on the territory of the European Union (EU). No transfer of data is carried out outside the EU. The KOALYZ company assures that it makes its best efforts to implement the useful precautions and the useful safety measures to preserve the safety of the data.
In all hypotheses, if the KOALYZ company were led to carry out a transfer of data outside the European Union, it commits itself to guarantee the protection of the personal data in accordance with the strictest rules in particular through the signature, on a case by case basis, of contractual clauses based on the model of the European Commission, or any other mechanism in conformity with the Regulation in force.
The KOALYZ Company commits itself to implement the technical and organizational means necessary to ensure the security of the personal data against theft, loss, disclosure or unauthorized modification according to the sensitivity of the data.
The KOALYZ Company makes a commitment to take into account the protection of the personal data as of the design of the products or services which are proposed to you.
However, the company KOALYZ draws the attention of the users to the fact that Internet not being a completely secure environment, it could not be held responsible in the event of interruption of the access to the Website for reasons of major forces or independent from its will.
MALICIOUS USE AND MANAGEMENT OF USER ACCOUNT PASSWORDS
The User of the Solution must manage the password of his account and not communicate it to anybody.
KOALYZ Company recommends that Users take the following security measures to increase Internet security:
- Keep passwords confidential.
- Avoid using the same password on multiple Internet accounts.
The password as well as the links of connection to the Solution are information to the only attention of the User and are confidential. The identifiers and password will never be asked by the KOALYZ company to the User. The latter must not in any case communicate the information relating to his account to a third party.
The infrastructures of the KOALYZ company are protected (malware, virus,…). The KOALYZ company makes its best efforts to offer to the Users a safe and secure environment. However, it is up to the Users (Customers and employees) to make sure of the safety of their terminal (PC, mobile device, tablet, …) and their network, which remain under their whole responsibility.
In case of usurpation or suspicious activity of their account, it is recommended to the Users to contact without delay the company KOALYZ: firstname.lastname@example.org
CONSERVATION OF DATA
The KOALYZ company preserves the personal data for the duration strictly necessary to the provision of the Services or for other essential purposes such as to satisfy the legal obligations.
In case of request for deletion or exercise of rights to request the deletion of Data, the Users are informed that the Personal Data can be preserved in the intermediate archives of the KOALYZ company for the duration necessary to satisfy the legal, accounting, financial and tax obligations, the settlement of disputes, and in particular, in order to prevent possible illicit behaviors.
A “cookie” is a connection indicator that designates a text file that may be recorded, subject to your choices, in a dedicated space on the hard disk of the Internet user’s Terminal, when the Solution is consulted. A cookie file allows its issuer to identify the Terminal in which it is stored, during the period of validity or storage of the cookie and must therefore be considered as Personal Data.
When consulting the Solution, information related to the terminal used (type, operating system, access provider, browser, IP address, language preferences, geolocation data, etc.) may be recorded in cookie files installed on your Terminal, subject to the choices you have expressed concerning cookies and which you may modify at any time.
The User has the possibility to manage the Cookies by configuring and setting the parameters of the navigation software.
The user can consult the CNIL website for help: www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
The recording of a Cookie in a Terminal is essentially subject to the will of the user of the Terminal, which the latter can express and modify at any time and free of charge through the choices offered by his navigation software.
The KOALYZ Company draws the attention of the User to the fact that the refusal of the recording of cookies or the deletion of those recorded can prevent or degrade the access to certain functionalities of the Solution. In such a case, the KOALYZ Company declines any responsibility.
MANAGEMENT OF THE USER’S RIGHTS
Under the conditions envisaged by the regulation relating to data protection the User has:
- a right of opposition to the treatment of his data for legitimate reasons;
- a right of access and communication, a right of rectification, updating, deletion and deletion of data concerning him, subject to legitimate reasons;
- a right to the portability of its data: The natural persons concerned are informed that they can request the delivery of a copy of their personal data, against reimbursement of the costs of reproduction and sending of the same.
- Of a right to the limitation of the treatments operated with regard to your data.
The KOALYZ company can nevertheless oppose the obviously abusive requests, in particular by their number, their repetitive or systematic character.
To exercise your rights, simply send a letter to the following address indicating your name, first name, e-mail address, postal address, company name, and attaching a copy of a valid proof of identity:
- By e-mail: email@example.com
- Par mail: KOALYZ – 107, allée François Mitterrand, 76100 ROUEN
A reply will be sent to you within one (1) month maximum following the date of receipt of your request.
The user has the right to file a claim for breach of data protection with the CNIL, the supervisory authority.
Questions and requests for information regarding this policy should be adressed to: