Privacy Policy

GDPR Compliance of the Website

Overall Assessment

The website has a basic legal framework, including legal notices, terms of use, and a contact page, but it has significant gaps regarding GDPR compliance:

Apparent lack of a dedicated privacy policy;
GDPR information buried in the legal notices along with outdated references;
A noticeable lack of sufficiently clear information on the site's collection materials
Regarding cookies, the policy is detailed in the cookie manager, but there is an issue with the “Reject” button—it must be as prominent as the “Accept” button in order to comply with the CNIL’s recommendations (Dark backgrounds in cookie banners: The CNIL issues an official advisory to website publishers | CNIL)

Action Plan

Proposal for a page dedicated to the privacy policy
Draft a privacy policy that complies with the GDPR
In contact forms, the current notice must be replaced with a concise GDPR information notice regarding the handling of the request, and a separate, optional checkbox for marketing communications must be provided when necessary. Main notice below the form:

"The information provided via this form will be processed by POPINA in order to manage your request and follow up on it. To learn more about the processing of your personal data and how to exercise your rights, please see our Privacy Policy. ”

Then add a separate field for prospecting, for example:

☐ I agree to receive marketing information about POPINA's products and services via email, phone, or mail.

Please note: In B2B contexts, you can generally send a B2B newsletter without prior opt-in, based on legitimate interest, if the content is related to the recipient’s role or business (e.g., payment processing solutions if they requested to be contacted about that), and a statement at the bottom of the form is sufficient:

"Your data is used to process your request and, unless you object, to send you information and offers related to your business. You may opt out at any time by clicking the unsubscribe link or by writing to us at DPO@jdc.fr . To learn more : Privacy Policy.” ”

Contact the password manager's provider to comply with CNIL requirements.

2 Draft Privacy Policy

This policy must be approved and then published on the POPINA website.

Privacy Policy

The purpose of this Privacy Policy is to inform users of the POPINA website about how their personal data is collected and processed in connection with their use of the website, contact forms, requests for demonstrations, content downloads, newsletter subscriptions, use of the AI chatbot, and, where applicable, access to the customer portal.

1. Data Controller

The data controller is:

JDC SA
, SAS JDC SA, with a capital of €146,232.

SIRET: 350 753 125 00235 – RCS Bordeaux B 350 753 125.

APE Code: 4666Z

GDPR Contact Email: rgpd@popina.com

JDC SA determines the purposes and means of the personal data processing carried out through the POPINA website.

2. Personal Data Collected

In connection with the use of this website, JDC SA may collect the following personal data:

name of the institution;
name;
first name;
zip code;
country;
work email address;
work phone number;
the content of the message sent via the form or chatbot;
information related to the request submitted (request for information, request for a demonstration, request for support, content download, sales inquiry);
data that may be necessary for managing the customer portal, when the user is a customer under contract;
technical data related to browsing and connection in connection with the use of the website and the customer portal;
data collected through cookies and trackers in accordance with the terms set forth in the cookie policy.

Email and Link Tracking Pixels

The fields marked as required on the forms are necessary for processing the request. If these fields are left blank, POPINA may not be able to respond to the request or provide the requested service.

3. Purposes of Data Processing and Legal Bases

Purpose of the processing	Categories of Data Processed	Legal Basis	Shelf Life
Respond to requests for information about POPINA products and services	Name of organization, last name, first name, ZIP code, country, work email, work phone number, message	JDC SA’s legitimate interest in responding to requests received and, as appropriate, taking pre-contractual measures	3 years from the last active contact, unless a request for deletion is made before that time
Manage Demo Requests	Name of organization, last name, first name, ZIP code, country, work email, work phone number, message	Pre-contractual measures taken at the request of the data subject	3 years from the last active contact, unless a request for deletion is made before that time
Allow content downloads	Name of the organization, last name, first name, ZIP code, country, work email, work phone number	JDC SA’s legitimate interest in disseminating its professional content and, as applicable, precontractual measures	3 years from the last active contact, unless a request for deletion is made before that time
Subscribe to the POPINA newsletter	Last name, first name, work email address, and, if applicable, name of the institution	Legitimate interest	Until you unsubscribe
Respond to requests made through the AI chatbot and direct the user to the appropriate departments	Name of the institution, last name, first name, work email, work phone number, content of communications, data related to the request	JDC SA’s legitimate interest in providing a channel for communication and prompt assistance; performance of the contract when the request concerns a customer under contract	3 years from the last active contact for sales inquiries; the time required to process support requests, followed by archiving as necessary
Manage technical support when a request is forwarded to the technical team	Identification information, business contact information, details of the request, and information necessary to process the support request	Performance of the contract when the party is a customer; legitimate interest in other cases	Time required to process the request, followed by retention in accordance with applicable contractual, technical, or evidentiary obligations
Manage access to and use of the customer portal reserved for customers with active contracts	Identification data, business contact information, login data, data related to the customer account and use of the service	Performance of the Contract	For the duration of the contractual relationship, and thereafter in accordance with the applicable retention periods
Ensure the operation, security, and improvement of the site and the customer area	Browsing data, login data, logs, security data, cookies, and trackers, depending on settings	Legitimate interest for strictly necessary processing; consent when required for certain cookies or trackers	Depending on the nature of the data and the time periods specified in the cookie policy or applicable internal rules
Monitoring of Electronic Communications	Tracking pixels to measure email open rates and link clicks	Consent	13 months maximum

4. Recipients of the Data

The personal data collected is intended for authorized departments at JDC SA that need to know this information in connection with their duties, including:

the sales teams;
marketing teams;
technical and support teams, as needed;
the teams responsible for managing the customer portal;
the authorized internal departments responsible for customer relationship management and compliance.

Data may also be shared with technical service providers acting on behalf of JDC SA, to the extent strictly necessary for them to perform their duties, in particular to:

lodging;
maintenance of the website and tools;
technical management of the customer portal;
the administration of the chatbot solution;
sending electronic communications;
technical support.

These recipients act in accordance with JDC SA's instructions and are subject to appropriate confidentiality and security obligations.

5. Transfers Outside the European Union

To the best of JDC SA's knowledge, the personal data processed through the POPINA website is not transferred outside the European Union.

Should this situation change, JDC SA would implement the appropriate safeguards required by applicable regulations and update this policy accordingly.

6. Data Security

JDC SA implements appropriate technical and organizational measures to ensure a level of security commensurate with the risk, and in particular to protect data from destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

These measures take into account the nature of the data being processed and the risks associated with such processing.

7. Data Source

Personal data is generally collected directly from the individuals concerned:

through the forms on the website;
via the AI chatbot;
through discussions with the teams at JDC SA;
through the customer portal, if the person is a subscriber to a contracted service.

8. Rights of Data Subjects

In accordance with applicable regulations, you have the following rights:

the right to access your personal data;
right to correction;
right to erasure;
right to restriction of processing;
right to object;
the right to withdraw consent when the processing is based on consent;
the right to data portability, where applicable;
the right to establish guidelines regarding what happens to your data after your death.

You can exercise your rights at the following address: rgpd@popina.com

If there is reasonable doubt regarding your identity, you may be asked to provide proof of identity.

You also have the right to file a complaint with the CNIL.

9. Cookies

The POPINA website uses cookies and other trackers necessary for its operation, as well as—depending on your preferences—audience measurement cookies and, where applicable, cookies related to third-party services.

During your first visit, a cookie manager allows you to accept, reject, or customize the use of cookies that require your consent. You can change your preferences at any time using the cookie management tool available on the website.

Details about the cookies used, their purposes, their retention periods, and any third-party providers can be found directly in this cookie manager.

10. Policy Update

This Privacy Policy may be amended at any time to reflect changes in laws, regulations, technology, or organizational structure.

The version published on the website is the current version.

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