Privacy Policy – In the Balance

This privacy notice sets out the policy of SPARKNEWS SAS (the “Company”) with respect to personal data on the website inthebalance.news (the “Website”). This Notice applies to all the information that you provide, or that we collect while you browse our website, in accordance with all applicable regulations in France relating to personal data such as those under French Law no. 78-17 of January 6, 1978 on information technology, data files and civil liberties, referred to as the “Information technology and civil liberties” law and Regulation (EU) 2016/679 of 25 May 2018 on data protection referred to as the “GDPR”.

The purpose of this privacy notice is to inform persons accessing the services offered on our Website (hereinafter referred to as the “Users”) about how we collect, utilize and share their personal data.

Any amendment to or update of this privacy notice will be brought to your attention. Your active consent to this new privacy notice will be required to continue using the services offered by the Company.

1. Who is responsible for your personal data?

The data controller, who collects and manages your data, is the company SPARKNEWS SAS, a company incorporated under the laws of France, with a share capital of € 1,500 registered with the trade and companies register of Paris under no. 533 807 087, with registered offices at 5 rue Guichard – 75016 Paris, represented by Christian De Boisredon.

2. What personal data is collected?

You are reminded that personal data is any information relating to a directly or indirectly identified or identifiable natural person.

When browsing the Website and using the different services offered by the Company, you are consenting to our collection of the following categories of data:

Operating System and browser used.

(Hereinafter referred to as “personal data”).

You agree to provide personally identifiable information that is up-to-date and valid, with respect to the information required on the Website, and warrant that you will not provide any false or inaccurate information.

3. How and why is your personal data collected?

3.1. Methods of personal data collection

We collect:

• Data relating to your identity: title, surname, first names, address, telephone number (landline and / or mobile), nationality, business address, e-mail addresses, a copy of an identification document may be kept for the purpose of proof of the exercise of a right of access, rectification or opposition or to fulfill a legal obligation;

• Data relating to your professional life: resume, skills, terms and conditions of work;

• Data relating to the means of payment, transaction, and invoices such as the transaction number; RIB; for payment by card retrieval of time-stamp (date, type of payment); check number, transaction reference, debtor name, bank; transfer; terms of payment, discounts, receipts, balances and monitoring of outstanding payments.

• Data relating to User relationship management: requests for documentation, correspondence and comments; implementation of loyalty actions and the organization of any external communication operation;

• Navigation data and your IP address on the website and social networks.

3.2. Legal basis for collecting and processing the data

Your personal data is collected on the basis of the following legal grounds:

Specific, free and informed consent of the User (particularly with respect to the Newsletter subscription);

The fulfillment of a legal obligation incumbent upon the Company;

The performance of a contract concluded between the Company and the User (particularly with respect to the fulfillment of general terms and conditions for use/sale);

The Company’s legitimate interest (particularly to ensure the security of transactions).

4. For what purposes is your personal data collected?

We may collect your personal data for the following purposes:

4.1 For any external communication about our Services, only in connection with the profession of the Users (BtoB) in order to:

• Organize and publish some of your Professional Personal Data within our network (professional directory), only with your explicit and prior consent and the ability to unsubscribe or modify the data communicated as soon as possible, simply and for free.

• Perform all external communication operations concerning our Services to the public, notably through the distribution of our newsletter. When collecting your Personal Data for external communication purposes, you are clearly informed of the identity of SPARKNEWS SAS as responsible for the processing. You are also informed that your e-mail address may be used for external communication purposes, and that you are able to oppose it in a simple and free manner.

We do not transmit your data to third parties without your prior, explicit, specific and informed consent, notably on the collection form.

4.2 To follow your relationship with SPARKNEWS SAS:

• Monitoring of contracts and the implementation of services;

• Billing follow-up, management of outstanding payments and litigations;

• User relationship follow-up such as carrying out satisfaction surveys, managing claims and collecting feedback about services or content;

• Management of loyalty market research operations, studies (selection, standardization, enrichment and deduplication of databases);

• Analysis of visits on our website and our social networks.

4.3 As part of our relationship with our suppliers.

The processing of personal data relating to the management of supplier files may have the purpose of performing administrative operations related to contracts, orders, invoices, accounting with regard to the management of accounts payable, to establish financial statistics and turnover by supplier, to provide selections of suppliers; to maintain supplier documentation.

4.4 In the context of operations relating to the security and proper functioning of our website and our information system.

We collect certain browsing data, including IP addresses to ensure the security and proper functioning of our services and to detect, avoid or trace any attempt of cyberattack or computer intrusion or violation of the user conditions of our services or the law. In this context we are also likely to implement cookies on your device to allow the proper functioning of our site and to measure its audience.

4.5 For the control of your personal data with SPARKNEWS SAS.

When you assert your rights with SPARKNEWS SAS regarding the management of your rights of access, rectification, deletion, opposition, limitation and portability.

4.6 The use of social networks to disseminate information:

In addition to the points detailed below, we invite you to consult the personal data management policies of the various social networks to learn about the collection and processing they perform on your data.

4.6.1 SPARKNEWS pages on social networks

By connecting to our Facebook page (https://www.facebook.com/sparksnews/ ) as well as other social networks, you are likely to share your personal data with these social networks. Other networks collect information about your identity, the persons, pages, accounts, hashtags, and groups with whom you have contact, as well as how you interact with them, for example, the persons with whom you communicate most or groups you belong to. They also collect contact information if you choose to download, sync, or import them from a device (for example, an address book, call log, or SMS history), that social networks are likely to use for the benefit of third parties, notably in the context of digital marketing operations.

To learn more about Facebook: https://www.facebook.com/privacy/explanation

4.6.2 Cookies on our site

Subject to the points mentioned above, the cookies used on our site are intended to enable or facilitate communication by electronic means.

Thus, our website is likely to use:

• « session identifiers » cookies (for the duration of a session, or for a few hours);

• « authentication cookies » of users

• cookies enabling the analysis of audience measurement;

• persistent cookies customizing the user interface (for example for the choice of an interface appearance).

• Cookies are not kept beyond 13 months.

5. Who has access to your personal data?

In addition to the members of our network in a strictly defined framework, may have access to your Personal Data in the context of a strict obligation of confidentiality and computer security:

• The SPARKNEWS SAS staff. Within SPARKNEWS SAS, only some of our employees have access to your Personal Data in the framework of their assignments.

• The potential subcontractors we use for IT, accounting and administrative services;

• Third parties, in limited cases governed by the law, such as the judicial and / or administrative authorities.

• Social networks when:

– social networks implement cookies on your device through our site;

– or when you visit a page dedicated to SPARKNEWS SAS on these social networks.

6. How long is your personal data stored?

The Company keeps your personal data for the time that is strictly necessary to accomplish the purposes for which it was collected and processed, such as managing the commercial relationship or payment.

Beyond this period, your personal data may also be archived to provide regulated, limited and justified access for the time required (i) to fulfill the Company’s legal and regulatory obligations, and/or (ii) to assert its rights through the courts, and before it is permanently deleted.

7. How does the Company maintain the security and confidentiality of your personal data?

The Company undertakes to process your personal data in a manner that is:

lawful,

loyal,

transparent,

balanced,

relevant,

inside the strict framework of the aims pursued and stated,

for the duration required for the processing operations established.

The Company is implementing and updating relevant technical and organizational measures to maintain the security and confidentiality of your personal data by preventing it from being garbled, damaged or disseminated to unauthorized third parties.

8. What are your rights concerning your personal data?

You may, by simple written request, access your personal data, ask that it be modified or rectified, or require that it no longer appear in the Company’s database.

Under the right of access, you are authorized, pursuant to Article 15 of the GDPR, to contact the Company so that (i) your personal data is communicated to you in an accessible form, (ii) you obtain confirmation on whether your personal data is or is no longer being processed, (iii) the purposes of the processing, personal data categories processed and the recipients of your personal data are communicated to you and (iv) you obtain information on how long your personal data is stored or the criteria used to determine this duration.

Pursuant to Article 16 of the GDPR, the right of rectification confers on you the right to require that the Company rectify, complete or update your personal data when it is inaccurate, incomplete, equivocal or expired.

Under the conditions provided for in Article 17 of the GDPR, you have a right to the erasure of your personal data, which enables you to request that the Company erase your personal data without undue delay, particularly when it is no longer required for the purposes for which it was collected.

In addition, you have a right to restriction of processing of your personal data in the cases identified in Article 18 of the GDPR. You may therefore request that your personal data be stored solely for the purposes of:

checking the accuracy of the personal data that you are disputing;

being of use to you with respect to the establishment, exercise or defense of your legal claims, and although the Company no longer has any use for it;

verifying whether the legitimate aims pursued by the data controller will prevail over yours assuming you object to the processing of your data based on the legitimate interest of the Company;

fulfilling your request to restrict the use of your data – rather than erasing it – assuming that the processing of your data is lawful.

Under the circumstances provided for in Article 20 of the GDPR, you have a right to the portability of your personal data, allowing you to retrieve personal data you provided from the Company, in a structured, commonly used, machine-readable format, for the purposes of transmitting it to another data controller.

In accordance with Article 21 of the GDPR, you have the right to object, at any time, to the processing of your personal data for the purposes of business development.

To exercise your aforementioned right of access, rectification, erasure, restriction, portability and objection, you may simply send your request by email to the following address: contact@sparknews.com..

The Company will provide the person who exercises one of these rights with information on the measures taken, without undue delay and, in any event, within one (1) month from the receipt of the request. This period may be extended by two (2) months, considering the complexity and number of the requests.

If the Company does not intend to fulfill the request, it will inform the person, without undue delay, and at the latest within one (1) month from the receipt of the person’s request for the reasons for its refusal and the possibility of filing a complaint with the supervisory authority and lodging an appeal.

Exercising these rights is free of charge. However, in cases of manifestly unfounded or excessive requests, the Company reserves the right to (i) require the payment of expenses including administrative costs, or (ii) refuse to fulfill these requests.

9. What recourse do you have if your personal data is misused?

In the case of a misuse of your personal data protection rights likely to pose a risk to your rights and liberties, the Company will report this violation to the CNIL (the French Data Protection Authority) in an expeditious manner, and, if possible 72 hours at the latest after being notified. The Company will also inform the User, without undue delay, in accordance with the provisions set forth in Article 34 of the GDPR.

Without prejudice to any other administrative or legal remedy, the User who considers that the processing of his personal data constitutes a violation of applicable legal provisions may lodge a complaint with the competent supervisory authority such as the French Data Protection Authority (CNIL).

10. To whom do you address your questions?

For any questions concerning the processing of their personal data and the exercise of their rights, the Users may contact our dedicated service at the following address: contact@sparknews.com.