This charter (the “Charter”) details Blue Paper’s policy on personal data and cookies. The purpose of this Charter is to inform you of the conditions under which Blue Paper collects your personal data, the reasons for which this data is collected, the use that is made of it and your respective rights. It applies to all information provided by you or collected by Blue Paper during your interaction(s) with us.
As the data controller, Blue Paper attaches great importance to protecting and respecting your privacy. As this is an important subject, we invite you to read the Charter carefully in its entirety so that you know and understand our practices regarding the processing of your personal data. This Charter sets out the rules relating to the personal data of all our customers and prospective customers, regardless of the channel through which this data is collected.
When we refer to our Platform, we mean one of the digital and/or physical channels and/or means that you may use to interact with us via the website, bluepaper.eu (the “Site”), by post or by telephone.
When using our Platform, Blue Paper may process personal data about you that we have collected from you or that you have provided to us.
As soon as you use our Platform, you are subject to the Charter in force at the time and you signify your acceptance of the latter. As we may modify our Privacy Policy at any time in accordance with the conditions set out in Article 6, we invite you to check it before each use of our Platform.
1. General information
The persons responsible for processing your personal data are :
Blue Paper
4 Rue Charles Friedel CS 30009, 67017 Strasbourg
This is how we have established guidelines and ensure that we are responsible for the processing and protection of your personal data.
Through our Platform, you may be asked to provide Blue Paper with personal data, for example when creating a customer account, ordering products or subscribing to the newsletter.
Blue Paper may also collect certain information relating to your browsing on the Site, under the conditions more fully described in the “Cookies” section below.
In accordance with the applicable regulations, François Bru has been appointed Data Protection Officer (DPO).
2. Data concerned
The data we collect and use varies according to the products, services or functions you wish to use. The personal data that we collect or that you decide to provide to us includes in particular :
- identification data, such as your first name, surname, company, telephone numbers and e-mail address, which you provide when you visit the website or decide to commit to a project by signing a contract or quotation;
- electronic identification data available on or from your computer (such as “cookies” or “IP addresses”). Your electronic identification data makes it possible to identify or geolocate (without being more precise than the town) your connection terminal or the pages consulted on the Site during your browsing and is generally insufficient on its own to identify you by name. For more information on the browsing information collected, please consult Article 5 on cookies and connection cookies;
3. Your rights
In accordance with the regulations in force, you have various rights concerning your personal data. These rights may be exercised directly and at any time by contacting us at info@bluepaper.eu or Blue Paper,4 Rue Charles Friedel CS 30009, 67017 Strasbourg, simply stating the reason for your request and the right you wish to exercise. If there is any doubt about your identity, we may ask you for a copy of your identity card or other proof of identity. You have the following rights:
- The right of access: The right to request a copy of the personal data we hold about you. If your request is unjustified or abusive, we may charge you a fee for this request.
- The right of rectification: The right to request the correction of inaccurate personal data that we hold about you. We would like to remind you that if you have a customer account, you can access the section corresponding to your personal data in order to modify or update it. You must ensure that this information is true and accurate. Similarly, you undertake to inform us of any changes or modifications to this data. We also remind you that, in principle, you should only communicate your own personal data and not that of a third party. Any damage or loss caused as a result of providing inaccurate or incomplete information in our data collection forms is the sole responsibility of the user of our Platform.
- The right to erasure: The right to request the deletion of your data, when one of the following conditions is met:
- your personal data is no longer required for the purposes for which it was collected,
- you have withdrawn your consent and there is no other legal basis for continuing to process your personal data,
- you have validly exercised your right to object,
- the processing of your data is not lawful, or your personal data must be deleted to comply with a legal obligation.
However, there are cases where you cannot exercise your right to erasure, even if one of these conditions is met (in particular when the processing of your data is necessary for freedom of expression and information, to comply with a legal obligation, to contest/exercise/defend a legal right or for statistical, archival purposes in the public interest, or for scientific or historical research).
To delete your customer account, simply send us your request to info@bluepaper.eu or Blue Paper, 4 Rue Charles Friedel CS 30009, 67017 Strasbourg.
- The right to object: The right to object on grounds relating to your particular situation to the processing of your personal data based on our legitimate interests. In this case we will stop processing your data, unless we have a legitimate reason to continue processing your data. If your data is used for commercial prospecting purposes, you have the right to object to this without having to justify yourself.
- The right to restrict processing: The right to request, in certain cases, the temporary suspension of the processing of some of your data or its retention, if you need it, for longer than necessary.
- The right to portability: If the processing of your personal data is based on your consent or the performance of the contract and if the processing is carried out by automated means, you will have the right to request receipt of your data in a structured, commonly used and machine-readable format, so that it can be transferred to another entity, provided that this is technically possible.
- The right to define directives concerning the fate of your personal data in the event of your death.
You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you habitually reside, your place of work or the place where the breach is alleged to have occurred, if you consider that the processing of your personal data constitutes a breach of the applicable regulations. In France, the supervisory authority is as follows: Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22
You also have the right to withdraw your consent, at any time, for any processing that is based on consent. To simply unsubscribe from our newsletter, simply click on the unsubscribe link in each e-mail.
4. Management of personal data by Blue Paper
4.1 Purposes and legal basis of data collection
The following summary will help you understand how Blue Paper uses your personal data (the “purpose”) and the legal basis (the “legal basis”):
To carry out commercial prospecting and marketing activities:
If you decide to subscribe to the newsletter, you consent to us processing your data in order to manage your subscription and/or to send you information relating to our products and/or services as well as commercial prospecting messages through various means, such as email or SMS. If you enter a competition via the Platform or our social networks, you consent to your data being used in connection with the competition and the award of the prizes you have won. Unless you give your express consent, the data collected will not be used for advertising purposes by us or our commercial partners. If you agree in advance to the legal terms and conditions applicable (in particular to the social networks you use), we may publish on our Platform or our various social networks photographs that you share publicly or with us. Subject to obtaining your prior consent, we may record data relating to your preferences (such as your size or colorimetry) to personalise your experience with Blue Paper.
Legitimate interest:
We have a legitimate interest in contacting you by telephone or post to inform you of our offers, provided you did not object at the time your data was collected (please note that you can object at any time by sending an email to info@bluepaper.eu). Similarly, unless you object, we have a legitimate interest in sending you commercial communications by electronic means (e.g. SMS or e-mail) if you are already a customer and if these communications relate solely to products or services similar to those we have already provided to you.
To respond to any questions, requests or complaints you may send us via the available channels
If your request relates to a contact by email or telephone, the processing is necessary for the proper management of our services.
Legal obligations
If your question concerns the exercise of the rights set out in Article 3 “Your rights” or relates to a complaint about our products or services, we will need to process your data in order to comply with our legal obligations.
To produce anonymous statistics on site traffic
We consider that we have a legitimate interest in analysing the ergonomics and quality of our Platform in order to improve the experience of our users and offer a better quality Platform to our customers. Please read Article 5 “Cookies” for more information.
Carrying out customer satisfaction surveys or studies
We consider that we have a legitimate interest in carrying out polls and surveys designed to analyse the degree of satisfaction of our customers in order to improve the quality of our products and services
4.2 Data retention period
Management of our customer and prospective customer files
Retention for a period of 3 years from your last contact with us (e.g. for customers, a purchase or, for prospects, a click on a hypertext link contained in an e-mail) or until your consent is withdrawn.
Your questions sent via the contact form
Retention for the time necessary to process your request.
Your electronic identification data (your connection logs collected, subject to your consent and the settings on your terminal, via the use of cookies and other tracers placed on our Site)
Retention in accordance with applicable regulations for a period not exceeding 13 months. For more details on cookies, how they work and how you can deactivate them, see “5. Cookies and Connection Cookies” below.
Secondly, regardless of the retention period required to fulfil the purpose of the data processing, it may be justified for us to archive your data for a limited period of time, in a secure manner and with restricted access, for various reasons:
- To comply with a legal obligation to retain data (for example, personal data for accounting purposes must be retained for 10 years).
- To protect against any liability claims arising from the processing of your personal data. In order to manage pre-litigation and litigation, we may archive your data for evidential purposes for the period during which we may be held liable (duration of the related statute of limitations: civil, commercial, etc.).
Once the retention period imposed by law has elapsed and any actions have become time-barred, your personal data will be deleted or made anonymous.
4.3 Data recipients
Your personal data is intended for the Blue Paper departments concerned by your requests. However :
The processing of your personal data is authorised to third parties that we use in order to provide certain services. These include :
- technical, logistics, transport and delivery service providers,
- payment service providers and fraud detection and prevention entities.
We may share your data with certain business partners only with your consent.
In any case, there is no transfer outside France and Blue Paper does not transmit your personal data, except :
- If Blue Paper needs to share this information with third parties in order to provide you with the service you request, or
- If Blue Paper is required by a judicial authority or any other administrative authority to communicate the information, or
- If you have given your prior consent to the sharing of this information.
In this case, the transfer of your personal data outside France will be carried out by putting in place the appropriate guarantees and by preserving the security of your data.
Blue Paper may transfer your personal data to judicial and police authorities, regulatory authorities, public bodies or third party companies in order to comply with a court order, subpoena, summons, search or any other legal or regulatory obligation or request. Such transfer may also be made for the purposes of fraud protection or the investigation of possible offences.
4.4 Data security
Blue Paper has taken all reasonable precautions to protect the confidentiality, integrity and availability of the personal data it processes and to prevent it from being distorted, damaged, destroyed or accessed by unauthorised third parties. Technical and organisational security measures have been put in place for this purpose.
Blue Paper does not, however, control all the risks associated with the operation of the Internet and draws the attention of Internet users to the existence of possible risks inherent in its use and operation.
For the purposes of technical storage of your personal data, your data will be centralised at Blue Paper: 4 Rue Charles Friedel CS 30009, 67017 Strasbourg
Blue Paper attaches the greatest importance to the protection and security of its information systems. Tools have been put in place to enable Blue Paper to detect any security breaches. These tools may incidentally lead to access to personal data by security teams. This data will be collected and processed for the sole purpose of managing these vulnerabilities and in compliance with applicable regulations on the protection of personal data.
5. Cookies and connection cookies
5.1 What are cookies?
A cookie is a text file that may be stored in a dedicated space on the hard disk of your electronic equipment when you consult an online service using your browser software. A cookie file enables its issuer to identify the terminal in which it is stored, during the period of validity or storage of the cookie.
5.2 Cookies issued on the Site
When you connect to the Website, Blue Paper may be required, subject to your choices, to install various cookies enabling it in particular to recognise the browser you are using during the period of validity of the cookie concerned.
The cookies issued are used for the following purposes:
- to establish statistics and volumes of visits to and use of the various elements making up the Site (sections and content visited, routes taken), enabling Blue Paper to improve the interest and ergonomics of the services, as well as the visibility of the content published;
- to enable or facilitate your browsing on the Website, or to provide you with the online communication services you request during your browsing;
- to adapt the presentation of the Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Site, according to the hardware and software for viewing or reading that your terminal has;
- to store information relating to a form that you have filled in on the Site (registration or access to your account) or to products, services or information that you have chosen on the Site (contents of an order basket, etc.);
5.3 Cookies issued on the Site by third parties
Blue Paper may include computer applications from third parties on the Site, which allow you to share content from the Site with other people or to inform these other people of your consultation or your opinion regarding content from the Site.
The issue and use of cookies by third parties are subject to the privacy protection policies of these third parties.
Blue Paper does not control the process used by social networks to collect information relating to your browsing on the Site. Blue Paper invites you to consult the privacy protection policies of these social networks in order to become aware of the purposes of use, in particular advertising, of the browsing information that they may collect using these application buttons. These protection policies should enable you to exercise your choices with regard to these social networks, in particular by configuring your user accounts for each of these networks.
The Site may contain cookies issued by third parties (advertising agencies, audience measurement companies, etc.) which, during the period of validity of these cookies, enable them to collect browsing information relating to Terminals consulting the Site, in particular in order to measure the effectiveness of paid search engine referencing campaigns.
5.4 Your choices concerning cookies
You have several options for managing cookies. Any settings you make may affect your browsing on the Internet and your conditions of access to certain services requiring the use of cookies.
You can choose at any time to express and modify your wishes with regard to cookies, by the means described below.
You can configure your browser software so that cookies are stored on your terminal or, conversely, so that they are rejected, either systematically or depending on the sender.
You can also configure your browser software so that you are offered the option of accepting or rejecting cookies from time to time, before a cookie is likely to be stored on your terminal. For more information, see “How to exercise your choices, depending on the browser you are using”
To modify your choices concerning cookies, consult the “Cookie settings” section at the bottom of the Site page.
(a) Agreement on Cookies
The recording of a cookie in a terminal is essentially subject to the will of the terminal user, which the user may express and modify at any time and free of charge through the choices offered to him by his browser software.
If your browser software allows cookies to be stored on your terminal, the cookies embedded in the pages and content you have consulted may be stored temporarily in a dedicated space on your terminal. They will only be readable there by the sender.
(b) Refusing cookies
If you refuse to accept cookies on your terminal, or if you delete the cookies stored on your terminal, you will no longer be able to benefit from a certain number of functions which are nevertheless necessary for browsing certain areas of the Site.
This would be the case if you attempted to access content or services that require you to be identified. This would also be the case if Blue Paper or its service providers were unable to recognise, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.
Where applicable, Blue Paper declines all responsibility for the consequences linked to the degraded operation of its services resulting from our inability to record or consult the cookies necessary for their operation and which you have refused or deleted.
(c) How do you exercise your choices, depending on the browser you use?
To manage cookies and your choices, the configuration of each browser is different. This is described in your browser’s help menu, which will tell you how to modify your cookie preferences.
5.5 If you share the use of your terminal with other people
If your terminal is used by several people and when the same terminal has several browsers, Blue Paper cannot guarantee with certainty that the services and advertisements intended for your terminal correspond to your own use of this terminal and not to that of another user of this terminal.
Where applicable, the sharing with other persons of the use of your terminal and the configuration of the parameters of your browser with regard to cookies are a matter of your free choice and your responsibility.
For more information on cookies and their use, you can consult the file of the Commission Nationale de l’Informatique et des Libertés at the following address: https: //www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.
6. Changes to the charter
Blue Paper may modify the Charter and will ensure that you are informed either by a special mention on the Site, or by a personalised warning, particularly when sending newsletters.
7. Personal data policy relating to minors
The Site is not intended for minors. However, access to the Site is not forbidden to them as it does not contain any content that is prohibited to minors under the age of 18.
If information is collected on a minor by the Site, the minor’s legal representative will be able to contact info@bluepaper.eu to rectify, modify or delete this information.