In order to provide you with the best experience as a community-based Web platform at all levels, we believe that you should always have a say in what data we collect and how we use it with KWA and our consultants.

Since the design of KWA Digital & KWA Community, we have always taken care to protect your data. Indeed, we have never spammed you or used your data for any other purpose than to improve our sourcing support service for all your digital projects.

Our approach :
We have created our processing register in order to have a clear map of all the processing of personal data that we implement as well as software or service providers that we use and that process personal data of our employees or our users.


We ensure with all our service providers that they share our commitment to the protection of personal data and insert contractual clauses relating to the protection of personal data in our contracts.

To the extent that you can exercise your rights to your data as easily as possible, we detail a procedure for exercising the rights of access, rectification, opposition and erasure quickly and efficiently.

We have designated a data protection correspondent who will also be your point of contact if you have any questions about the protection of your personal data by KWA Digital. You can contact him at the following address: dpo@kwa.digital
You want to know more ?We invite you to read our entire privacy policy. These changes are effective December 4, 2018. Your use of our services on and after this date indicates that you accept these updates.We remain at your disposal if you have any questions. Thank you for your confidence and participate in this digital adventure!

The KWA Digital team.

Effective date: December 3, 2018

Introduction

The protection of your personal data is important to us. We are committed to only collecting the data we need to ensure optimal service, confidentiality and security, including when we use providers and to facilitate the exercise of your rights to your data. .

Our first commitment is the respect of the applicable legislation on the protection of the data and in particular the General Regulation on the protection of personal data (also called RGPD) and the law known as “Informatique et Libertés” of 6 January 1978 modified.

This policy describes the personal information we collect, how it is used and shared, and your rights in this regard. It applies to any user of KWA Digital & KWA Community services. We advise you to read it carefully. We have done our utmost to make it clear and understandable, as well as accessible at all times in your navigation.

We strive to be as clear as possible. However, if you are not familiar with, for example, the terms “vigilance”, “freelance”, “cookies”, “or” factoring or cash advance “, find out about these key terms in our glossary. end of this charter.

If you wish to obtain a clarification or if you have a question to ask about it, you can contact our DPO at the following address: dpo@kwa.digital.

Please note that features to manage your data and protect your privacy and security are available at https://kwa.digital/en/privacy-policy/.

The updated Data Protection Charter will automatically become effective for all active users as of December 3, 2018. Continuing to use our services after this date constitutes acceptance of the new Data Protection Charter.

We reserve the right to modify this Privacy Policy at any time. The most current version of this policy governs our use of your information and will always be available at https://kwa.digital/en/privacy-policy/

If we make a substantial change to this privacy policy, we will notify you via the email address you provided on www.kwa.digital.

Data Controller: KWA Digital

Groupe LBAC SAS, a simplified joint-stock company, registered with the RCS of Bourg-en-Bresse under number 809 474 414, whose head office is located at 24 rue Saint-Jean – 01300 Belley, owner of the trademark KWA Digital deposited at the INPI.

Contact details of our DPO

You may address any questions relating to the protection of personal data to KWA Digital or submit a request to exercise your rights of access, rectification, opposition, deletion, limitation, portability to our data protection officer:

by e-mail: dpo@kwa.digital

by mail: KWA Digital, 24 rue Saint-Jean – 01300 BELLEY.

Data we collect

As part of your use of our services and browsing our website, KWA Digital collects several categories of data, details of which you will find below. These data come from:

Information that you communicate to us. When you create your account, update your profile or customer account, or interact with our team. This personal information is for example data allowing your identification, your e-mail address, your photo, your bank details.
Information resulting from your use of our services. We collect information about the services you use and the use you make of them. For example, the use of messaging, data about your site navigation, the pages you visited, your activity on the platform, and information about transactions.

We do not deal with particular categories of data (sensitive data) such as data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric health data or data concerning sex life or sexual orientation of persons.

 

Freelance Consultant Data

We inform at the time of the collection of the obligatory nature or not of the data.

Communicated by the user
Personal informations
– Name
– First name
– Birth date
– Sex
– E-mail
– Professional category
– Location
– Profile picture

Information about exchanges with our teams
– emails
– Dates and durations of phone calls
– Professional information
– Professional experiences
– skills
– portfolio
– Mission Preference
– Legal structure
– Company Name
– Legal form
– Identity of the legal representative of the company
– Legal documents
– Bank information
– Bank details
– More information about your profile
– Possible integration of your social networks (Twitter, Behance, StackOverflow, Github)
– Certifications and training
– languages
– Information on the missions performed
– comments
– view
– Generated by your use on the platform
– Navigation data
– Cookies and IP address
– Transaction Information
– Transaction Details
– recommendations
– External recommendations following your requests
– Data on the use of secure messaging
– User IDs
– Date and time of sending
– contents

Customer data

We inform at the time of the collection of the obligatory nature or not of the data.

Communicated by the user
– Personal informations
– Name
– First name
– Birth date
– Sex
– E-mail adress
– Profile picture
– General information about the company
– Activity area
– Number of employees
– Company logo
– Legal structure
– Billing information
– Accounting Contact
– Mission Information
– Reviews received by freelancers
– comments
– Information on the missions performed
– comments
– view
-Information about exchanges with our teams
– emails
– Dates and durations of phone calls
– Generated by your use of the platform
– Navigation data
– Cookies and IP address
– Transaction Information
– Transaction Details
– Data on the use of secure messaging
– User IDs
– Date and time of sending
– contents
– Statistical information about your use of our services

For example, we collect statistics on the use of secure messaging that we offer (percentage of messages answered, response time); end-of-mission evaluation statistics (comments left by clients and freelancers, average ratings); users’ login and navigation data, statistical data on the use of the search engine and the freelance contact form; usage statistics for different modules such as tools and features available to companies.

The statistics may also include commercial data such as the number of missions performed, business volumes by category of freelancers, customers.

Cookies

We use authentication cookies, security cookies and cookies relating to the integrity of the website, location cookies, cookies related to site functionality and services, analysis and search cookies and cookies to broadcast messages. advertising. To learn more about Malt’s cookie policy, you can read our “Cookie Policy” available here: https://kwa.digital/en/privacy-policy/.

 

Aims

KWA Digital processes your personal data, including your connection to the site, your registration to the site, your activity or when using the payment system.

The data we collect allows us to provide, manage, protect and improve our services, to develop new ones, and to protect both our users and ourselves.

Description of the details:

In particular, these data are intended for

Creation and management of your account
Use of the services of the site;


For freelancers, optimizing your SEO in the search engine; for clients the proposal of the most relevant research results; *

Ensure that the proposed missions are relevant (lead moderation, anti-spam policy);

Protect our freelancers against spam and guarantee the quality of our service (especially thanks to statistics);

Allow communication between users (freelancers and customers) by providing secure instant messaging;
Put at your disposal your documents (invoices, contracts …);

Verifying your company on the basis of your legal documents;

Carry out a personalized follow-up to only send you relevant communications, adapted to your needs and directly related to the services of the site;

Secure the site kwa.digital, communaute.kwa.digital, as well as the data and exchanges intervening on the site;

The management of financial flows via the platform including the billing of missions and payments and, in accordance with the law, the fight against terrorism and money laundering;

Evolve our services to offer you new features and adapt to your needs: to this end, we perform statistics monitoring the audience of the pages of our website and monitoring business activities and user behavior on the website. platform. These statistics are anonymized as often as possible;

Guarantee the quality of profiles, fight against fraud, check profile information (eg location, …);

Send you notifications related to your activity on the site, for example, when you have received a message, an estimate, a payment;

Contacting You: KWA Digital may use the information collected to communicate with you about products, services, promotions, studies, surveys, news, updates and events.
Legal basis of the treatments
KWA Digital processes most of your personal data as part of the service contract that you concluded when you registered on the site via the acceptance of our terms of use. However, we may process certain information about you on the basis of your consent, due to legal obligations, or in response to our legitimate interest in processing it.Details:
Service Agreement: KWA Digital processes most of your personal data as part of the service agreement you entered into during your registration on the site by accepting our terms and conditions of use. Thus, all the data that you communicate to us during the creation and the management of your profile as well as the data necessary for the creation, the follow-up and the invoicing of a mission, the exchanges which you can have with our service support or as part of the secure messaging and communications we send you, in connection with our services or monitoring your account are treated in this legal framework.
Legitimate interest: In addition, we also process certain data on the basis of our legitimate interest for the purposes of managing and securing access to our website, fighting fraud and justifying our accounting (publishing invoices for your account and that of your business partners, justification of our service fees).
Consent: we may also obtain your consent prior to the processing of certain data, for example for the reuse of your profile picture, made by our services, on commercial media or when you have not created an account on the platform but wish to receive our commercial offers or our newsletter.
Legal obligations: Finally, we are processing certain data because of the legal obligations imposed on us in the context of the management of payments made via the platform, particularly the fight against terrorism and money laundering.

 

Recipients or category of recipients
Summary :

KWA Digital is the recipient of personal data collected via the website.

Some of the services and features provided by KWA Digital require us to share information with other users or with our service providers. We are also likely to share this information for legal reasons or in the event of litigation.

Details:

KWA Digital is the recipient of personal data collected via the website.

We only disclose your personal data to companies, organizations or third parties in the following circumstances:

Share customer credentials with your customers when you send them a business proposal and legal documents related to your company when a mission starts;


Where necessary for external processing purposes, and only in this case, we will transmit this data to our trusted service providers who process it on our behalf, as instructed or in accordance with a contractual agreement, in accordance with this Policy and the respect for any other appropriate measure of security and confidentiality. We may send your personal data only for the purposes set out below. So,
Google LLC (Google analytics) for the realization of statistics;


Where necessary to satisfy legal, regulatory, and judicial requirements. We retain or disclose your information if we believe that it is reasonably necessary to satisfy any legal or regulatory requirement, legal process or administrative request, to protect the safety of any person, to deal with any fraudulent, security or technical problem , or to protect the rights or property of our users.

Important: KWA Digital does not resell to any third party the data, information or documents that you entrust to us and will never divulge your personal data outside the situations described in this Privacy Policy.

Shelf life or criteria determining these durations and deletion of information about you

Summary :

KWA Digital retains your information as long as your account remains active unless you ask them to be deleted or your account deleted. In some cases, we may retain information about you because of the law or for other purposes, as described in this section, even if you delete your account.

Detail:

KWA Digital retains your information as long as your account remains active unless you ask them to be deleted or your account deleted. Subject to the exceptions listed below, KWA Digital deletes your information or makes it anonymous on request.

We only keep your information in the following circumstances:

If you have completed assignments, KWA Digital keeps your billing information for a period of 10 years from the closing / deletion of your user account in order to comply with our accounting obligations, payroll taxes and our tax obligations.


For freelancers only, KWA Digital also keeps, for a period of 10 years, the legal documentation allowing the verification of your company in order to answer the legal obligations of the customers (carriers of projects / principals).

 

Data security


We implement appropriate technical and organizational measures to ensure the constant security, confidentiality, integrity, availability and resilience of our information system and data and to protect personal data against destruction, loss, alteration, unauthorized disclosure or unauthorized access.

We are committed to implementing all available means to ensure the security and confidentiality of this data, in particular:

We encrypt most of our services using SSL technology;
We verify your email address when creating your account;
We conduct internal audits on the collection, storage and processing of data, including physical security measures, to prevent unauthorized access to our systems;
Access to personal data is strictly reserved for KWA Digital employees and service providers who need to know it. These persons are subject to strict confidentiality obligations and may be subject to disciplinary sanctions, up to and including termination of employment, in the event of a breach of these obligations;


Transfer of data to a third country

All our servers on which your data are stored and those of the providers used to exchange and store these data are exclusively located in Europe (Germany, France, the Netherlands). Very exceptionally, some of our service providers whose principal place of business is in a non-EU country may have to transfer your data to that state. In this case, we first verify that they comply with their data protection obligations.

So,

Mailchimp, adheres to the Privacy Shield, a set of data protection rules equivalent to those planned within the EU
Google, adheres to the Privacy Shield, a set of data protection rules equivalent to those planned within the EU.

For the proper functioning of the Site and KWA Digital Services, cookies are placed on your computer when you connect to the Site. Cookies are small text files that are stored in your browser or device by websites, applications, online media and advertisements.

The table below describes the different categories of cookies that our Services use and why we use them. The list of suppliers of third-party cookies is provided for information purposes only and is not exhaustive.

The shelf life of cookies installed by KWA Digital ranges from two weeks (cookie identification) to 6 months (analysis and research) and up to 24 months (for Google analytics).

However, you have the possibility to oppose the use of cookies by configuring your browser software. As each navigation software is different, you are invited to consult the instructions of your browser to set it as you wish.

For more information about cookies, including which cookies have been installed on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.

In accordance with the provisions of the so-called “Informatique et Libertés” law of 6 January 1978 as amended and the general data protection regulations, you have the right to access, rectify, delete, limit or opposition and the portability of your personal data.

You will find in each of the sections below a description of these rights as well as the means of exercising them.

Permission to access

You have a right of access to your data processed by KWA Digital. It allows you to read the data we have about you and, if you wish, to request a copy.

You can find all the data we collect about users in the “Data collected” section of the data protection charter.

To have a personalized detail of the data we have about you, you can send us your request by email to the address support@kwa.digital or by mail to: KWA Digital – LBAC SAS GROUP, 24 rue Saint-Jean – 01300 BELLEY. We will endeavor to respond within a reasonable time.

Rights to rectification

According to the applicable regulations on the protection of personal data, you can request from us the correction of personal data about you that are inaccurate. You may also request that the incomplete personal data concerning you be completed, including by providing, in support, a supplementary declaration.

In order to allow you to exercise this right as easily as possible, we invite you to proceed directly to these changes and additions to your profile. If you believe that other data concerning you must be modified or completed and that you are unable to make this change by yourself, you can send us your request by email to the address support@kwa.digital or by mail at: KWA Digital – LBAC SAS GROUP, 24 rue Saint-Jean – 01300 BELLEY. We will endeavor to respond within a reasonable time.

Clearing rights

You have the right to obtain from us the erasure, as soon as possible, of your personal data subject to our legitimate interest or any legal obligation requiring us to preserve it.

For security reasons and to avoid an unwanted deletion of the account, we invite you to do this by yourself once logged into your account.

Regarding the data in your profile, you should keep in mind that search engines and other third parties may still retain copies of your public profile information for a certain period of time when you have accepted listing, even after have deleted information from the KWA Digital or KWA Community site or disabled your account. If you wish, you can exercise your right to dereference directly from these search engines.

Right to limitation of treatment

You may request KWA Digital to limit the processing of your data (for example, temporarily making your profile unavailable on the site), when any of the following applies:

a) you dispute the accuracy of your personal data. In this case, we will hide the data about you for a period of time allowing us to verify its accuracy;

b) you believe that the processing of your data is unlawfully implemented and you oppose their erasure and instead require the limitation of their use;

c) we no longer need the personal data about you for the purposes of processing but these are still necessary to enable you to have your case reported, exercised or defended;

d) you exercised your right of objection under Article 21 (1) of the General Data Protection Regulation. We will limit the processing of your data during the audit as to whether the legitimate grounds we are pursuing prevail over your right.

If we decide to lift the limitation of the processing of your personal data, we will keep you informed.

To exercise this right you can send us your request by email at support@kwa.digital or by mail to: KWA Digital – GROUPE LBAC SAS, 24 rue Saint-Jean – 01300 BELLEY.

 

Right of opposition

You may object to sending communications, including commercial, by KWA Digital. To this end, we provide you with an unsubscribe link in all e-mails we send you and you can manage your notification preferences directly in our data protection center.

You can also object, for legitimate reasons, to the processing of your data, unless it meets a legal obligation imposed on KWA Digital (for example, tax declarations, declarations of social charges …).

To exercise this right you can send us your request by email at support@kwa.digital or by mail to: KWA Digital – LBAC SAS GROUP, 24 rue Saint-Jean – 01300 BELLEY.

Right to portability

You can request the portability of your KWA Digital data at any time. By exercising this right, we undertake to send you, within a reasonable period of time and in a machine-readable format, the data that you have provided to us whether it has been declared by you or generated by your activity on the platform.

To exercise this right you can send us your request by email at support@kwa.digital or by mail to: KWA Digital – LBAC SAS GROUP, 24 rue Saint-Jean – 01300 BELLEY.

Right to withdraw consent

You have the right to refuse at any time the processing of your personal data for personal reasons. As well as the right to refuse the processing of your personal data for direct marketing purposes.

To exercise this right you can send us your request by email to support@kwa.digital or by mail to: KWA Digital – LBAC SAS GROUP, 24 rue Saint-Jean – 01300 BELLEY.

Right to lodge a complaint with a supervisory authority

GROUPE LBAC, via its trademark KWA Digital, registered at INPI has its principal establishment at 24 rue Saint-Jean, 01300 BELLEY. As such, the competent supervisory authority to know any request concerning us, including, where appropriate, the complaint of a user, is the National Commission of Computing and Liberties (CNIL).

If you wish to seize the CNIL of any request, you will find below the coordinates:

CNIL (NATIONAL COMMISSION OF INFORMATICS AND FREEDOMS)

3 Place Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

Such. : 01 53 73 22 22

(Monday to Thursday from 9h to 18h30 / Friday from 9h to 18h)

Fax: 01 53 73 22 00

Warning! The CNIL does not receive the public and does not provide any information on the spot.

If you wish to lodge a complaint with the CNIL, you can fill in the online complaint form available at the following address: https://www.cnil.fr/en/complaints

If you have a question about your computer rights and freedoms, you can consult the website of the CNIL: www.cnil.fr.