Personal data protection policy
OPINIONWAY’s ambition is to be an exemplary company, working with its customers to make the world intelligible so that we can act today and imagine tomorrow.
We attach great importance to the principles of honesty and transparency, particularly in data processing, which is at the heart of our business. We want to establish a relationship with you based on trust and mutual interest.
Part of this commitment involves protecting and respecting your privacy and your choices. Respecting your privacy is an essential issue for us.
This is why you will find below “Our commitment to the protection of personal data” as well as our full Personal Data Protection Policy.
Our commitment to personal data protection
We respect your privacy and your choices.
We ensure that personal data protection and security issues are at the heart of everything we do.
We will not pass on or sell your personal data.
We are committed to securing and protecting your personal data. This means that we only work with trusted partners.
We are committed to being open and transparent about how we use your data.
We will not use your personal data in any way that we have not made known to you.
We respect your rights and constantly strive to satisfy your requests as far as possible, while respecting our own legal and operational responsibilities.
In order to further explain our personal data protection and privacy practices, we set out below the different types of personal data that we may obtain directly from you or as a result of your interaction with us, how we may use it, with whom we may share it, how we protect it and ensure its security, and the rights you have in relation to your personal data. You can of course not be concerned by all these situations. The purpose of this personal data protection policy is to give you an overview of all the situations in which we may interact together.
When you provide us with personal data or when we collect personal data about you, we undertake to use it in accordance with this Policy. Please read this information carefully.
If you have any questions or concerns about your personal data, please contact our Data Protection Officer at the following e-mail address: dpo@opinion-way.com
What is personal data ? What is processing ?
Personal data” refers to any information that may identify you directly (e.g. your name, e-mail address) or indirectly (e.g. through pseudonymised data such as a unique identifier).
This means that personal data includes information such as email addresses, user names, user-generated content, gender, age range, place of origin, user profile (e.g. journalist, consumer etc.).
Personal data may also include unique numerical identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as cookies.
Processing means any operation involving the use of personal data. This includes collecting, recording or storing the data, or performing any operation or set of operations on the data, including organising, modifying, retrieving, using, disseminating, erasing or destroying the data. Processing also includes the transfer of Personal Data.
Principles governing the processing of personal data
OpinionWay undertakes to guarantee a high level of protection of the Personal Data of Data Subjects who use the Site and other Products or Services and of any other person whose Personal Data it processes.
In principle, we only collect and use personal data to the extent necessary to carry out our surveys and research projects.
When we ask you to take part in a specific survey, we explain the objectives in detail and give the name of our customer when they have entrusted us with your data. Participation in our surveys is, of course, voluntary.
OpinionWay undertakes to comply with the regulations applicable (in particular articles 5 and 6 of the RGPD) to all Processing of Personal Data that it implements. In particular, OpinionWay undertakes to comply with the following principles:
Data is processed lawfully, fairly and transparently with regard to the Data Subject (lawfulness, fairness, transparency);
Data is processed for specified, explicit and legitimate purposes and is not further processed in a way incompatible with those purposes (purpose limitation);
Personal data are kept in an appropriate and relevant manner and are limited to what is necessary for the purposes for which they are processed (data minimisation);
Personal Data is accurate, kept up to date and every reasonable step is taken to ensure that inaccurate data, having regard to the purposes for which it is processed, is erased or rectified without delay (accuracy).
Data is kept for no longer than is necessary for the purposes for which it is processed;
Data are processed in a manner consistent with the rights of the Data Subject;
Data is processed securely;
Data is not transferred to persons or organisations located in countries that do not benefit from an adequate level of protection (even to other OpinionWay entities located in these countries).
Purposes of processing and legal bases
The purposes of the Processing of Personal Data carried out by OpinionWay are based on the following legal grounds: contractual performance, the consent of Data Subjects, OpinionWay’s legal and regulatory obligations, its legitimate interests or those of its clients.
The purposes associated with each legal basis are listed below.
On the basis of the performance of pre-contractual measures taken at the request of Data Subjects and/or the performance of the contract they have signed, OpinionWay implements Processing for the following purposes:
- management of contracts with customers, service providers, suppliers and partners). The data concerned is customer identification data (surname, first name, postal address, email address, telephone number, job title).
- As part of its recruitment activities, OpinionWay processes personal data concerning candidates, which is necessary for the processing of their application(s). The data concerned includes the candidate’s identification and contact details, Curriculum Vitae, letters, e-mails and documents sent by candidates, interview dates and results, salary positioning, action taken on the application, type and duration of contract offered.
- in the event of the organization of events, whether physical or online, OpinionWay processes personal data relating to event registrants and participants, in particular their identification data (surname, first name, contact details, email addresses, telephone number, company and position within the company)
On the basis of the consent of the Data Subjects, OpinionWay implements Processing for the following purposes:
- the provision of personalised Services, such as advertisements, newsletters, training, etc;
- the provision of optional Services such as interactive chat rooms;
- managing user participation in our surveys;
- management of cookies subject to consent.
On the basis of compliance with its legal and regulatory obligations, OpinionWay implements Processing for the following purposes:
- the development of Products and Services to facilitate the completion of administrative formalities required to process requests from Internet users;
- managing responses to official requests from public or judicial authorities authorised to do so;
- Compliance with the regulations applicable to our business;
- managing requests to exercise rights.
On the basis of its legitimate interests, OpinionWay implements Processing for the following purposes:
- the development and improvement of new Products or Services and offers of Products or Services to Internet users and/or for the benefit of the public;
- combating fraud and abuse, including managing the consequences of such fraud or abuse;
- managing security breaches or any technical problems encountered by the Products or Services;
- commercial prospecting operations aimed at professionals;
- management of customers or employees within a group of companies for internal administrative purposes;
- managing user requests for information and complaints;
- the establishment of any means of proof necessary for the defence of OpinionWay’s rights;
- management of cookies not subject to consent.
Sensitive data (art.9 of the RGPD) is information that reveals a person’s alleged racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
These particular categories of Personal Data may only be processed if required by law or if the Data Subject has given his/her explicit consent. This data may also be processed if this is necessary to assert, exercise or defend legal claims.
How to exercise your rights
In accordance with General Data Protection Regulation no. 2016/679, Data Subjects may, at any time, exercise their rights of access, rectification and deletion of data concerning them, as well as their rights to limit and object to the Processing and portability of their Personal Data.
In addition, where the Processing of Personal Data implemented by OpinionWay is based on the consent of the Data Subjects, the latter may withdraw such consent at any time. OpinionWay will then cease to process the Personal Data of the Data Subjects without the previous operations for which the Data Subjects had given their consent being called into question.
Under the right of access, OpinionWay may require Data Subjects to pay a reasonable fee based on administrative costs for any additional copies of the data beyond the one provided.
These rights may be exercised by post to the following address
OPINIONWAY
DATA PROTECTION OFFICER
15 PLACE DE LA REPUBLIQUE
75003 PARIS
or by email to the following address dpo@opinion-way.com
In this context, it is kindly requested that requests be accompanied by the elements necessary for identification (surname, first name, email) of the Persons concerned, as well as any other information necessary for confirmation of their identity.
For certain specific Services, these rights may be exercised directly online (management of your user account, management of your subscriptions to newsletters, news, etc.).
In the event of a breach of the regulations applicable to the protection of Personal Data, Data Subjects also have the right to lodge a complaint with the Commission nationale de l’informatique et des libertés on French territory (3 place de Fontenoy – TSA 80715 – 75334 Paris cedex 07; tel.: 01 53 73 22 22), without prejudice to any other administrative or legal remedy.
How is you data protected ?
The personal data processed is protected by technical measures (such as firewalls, encryption, pseudonymisation, etc.) and organisational measures (such as restricted access according to operational needs, etc.) that comply with French and European legal and regulatory requirements to prevent the unlawful or accidental disclosure, loss or alteration of your data.
These protection measures are adapted according to the level of sensitivity of the data and associated processing.
Are personal data transferred outside the European Union ? Under what safeguards ?
We store and process your personal data in the European Union. However, if we were to process your personal data outside the European Union to countries whose applicable legislation on the protection of personal data differs from that applicable in France, we would ensure that the transfer takes place to countries whose legislation has been recognised as conferring an adequate level of protection by the European Commission or, failing that, is governed by the European Commission’s standard contractual clauses which make it possible to guarantee a sufficient level of protection for the privacy and fundamental rights of individuals and compliance with the technical standards used.