1. DATA CONTROLLER
APLO (ex-SheeldMarket), a French company with company number 878 929 405 RCS Paris and registered office at 15 rue des Halles, 75001 Paris, France, is the controller of your personal data.
2. DATA COLLECTION AND USES
We collect personal data:
- provided by visitors of our website, when they contact us, sign up to our newsletter, and more generally, each time they interact with us;
- provided by our clients, in two contexts: our compliance diligence measures and to create user accounts;
- provided by job applicants;
- through cookies.
We use personal data we collect for the purposes listed in the table below, on the basis of a lawful “justification” (or lawful basis) for processing and for a limited period of time. Please note that, as a principle, we do not request sensitive personal data, therefore, please only provide us with necessary information and not with any sensitive personal data.
|Purposes||Lawful basis||Retention period|
|To process requests received by any means (contact form, email, phone)||This processing is based on your consent.||Duration necessary to process your request|
|Newsletter||This processing is based on your consent.||Until you unsubscribe from our newsletter|
|Marketing activities||We consider that we have a legitimate interest in making our promotion and developing our activities.||Until you exercise your right of objection, or if you are a client, for the duration of the commercial relationship, and 3 years after the end of this commercial relationship, or if you are a prospect, from your last contact with us.|
|To provide our services (create/update accounts, send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages).||This processing is necessary for the performance of the contract we have with you, if you are a freelancer, or with your employer, if you are employed.||For the duration of the contract with you or your employer, as appropriate, or until the deletion of your account|
|The compliance diligence measures before the onboarding of our clients on Aplo (collecting the ID cards and any relevant documents in order to assess the reputation of our clients)||This processing is necessary for Aplo to be compliant with the Anti-money laundering and counter financing terrorism regulations, as part of the “Know-Your-Customer” diligences||For the duration of the commercial relationship with the client, and 5 years after the end of this commercial relationship. If the onboarding was not finalised (date of the last email of the client), the duration becomes 3 years. If the client was onboarded but did not use the services offered by Aplo, his/her documents will be retained 3 years after the onboarding.|
|Recruitment (to process applications, develop our recruitment process and comply with our obligations)||We rely on our legitimate interest in managing our recruitment process and processing applications to process your personal data||Unless you ask us not to, we retain your personal data for 2 years after you apply, or we identify you as a potential candidate|
|To respond to requests to exercise data protection rights||This processing is necessary to comply with our legal obligations.||The time necessary to respond to your request, plus 1 year|
|To manage an objection list||We consider that we have a legitimate interest in respecting your wishes with respect to the processing of your personal data.||3 years from the exercise of your objection right|
Please note that we may retain your personal data for longer periods of time, for instance where such data is necessary to establish the existence of a right or contract, following legal requirements imposing longer retention periods. In that case, your personal data will be retained for longer than is strictly necessary. When your personal data will no longer be necessary, we will delete or anonymize them.
- authenticating users;
- remembering user preferences and settings;
- improving and customizing the user browsing experience;
- analytics and metrics about our visitors.
The following table sets out the different categories of cookies that we use and why.
|Types of cookies||Purpose||Who serves|
|Essential website cookies||These cookies are strictly necessary to provide you with services available through our website and app (such as the online chat). Such cookies cannot be deactivated from our systems. You can set your browser to block or alert you about these cookies. However, if you refuse this category of cookies, which do not collect personal data, certain aspects of the website will not function properly.||
|Analytics||These are used to understand, improve and research our website, app and services You have the right to choose whether or not to accept these cookies. If you consent to the use of such cookies, your consent will be valid for 13 months from its recording. If you decline the use of such cookies, a single cookie will be used to remember your preference not to be tracked.|
4. DATA SHARING AND DISCLOSURE
We may share personal data with:
- the relevant collaborators within Aplo, on a need-to-know basis, for Aplo to perform its services,
- our service providers which process your personal data on behalf of Aplo,
- our professional advisors (such as lawyers, accountants and auditors) when required in providing their services,
- public or judicial authorities where required,
- your employer, if you use our services in the context of your employment.
We may also share your personal data with third parties in connection with a potential or actual sale or restructuring of our company or certain of our assets, in which case your data may be one of the transferred assets.
In this context, your personal data may be transferred outside the European Economic Area (EEA), to countries not offering a level of protection of personal data equivalent to that offered within the EEA, such as the United States. In the absence of an adequacy decision of the European Commission, the transfer of your personal data will be made pursuant to standard contractual clauses adopted by the European Commission. You can obtain a copy of the relevant safeguard by contacting email@example.com, although some details may be redacted for confidentiality reasons.
5. YOUR RIGHTS
You have a number of rights in relation to your personal data.
- You can withdraw at any time your consent in respect of any processing of personal data based on your consent.
- You can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characteristics of such processing, allow you to access such data and give you a copy of it.
- You can ask us to rectify or complete inaccurate or incomplete personal data.
- You can ask us to erase your personal data or to restrict its processing in certain cases.
- You can ask us, in certain cases, to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller.
- You have the right to define (general or specific) directives regarding the fate of your personal data after your death.
- Where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims.
- You have the right to object to the processing of your personal data for direct marketing purposes at any time.
You can exercise your rights by contacting us at the contact details in article 6 “Contact” below.
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. In France, the supervisory authority for the protection of personal data is the CNIL (www.cnil.fr).
For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data, please contact firstname.lastname@example.org.
7. CHANGES TO THIS POLICY
Last updated: August 2022.