Personnal Data Protection Policy Kls

 

DATA PROTECTION POLICY FOR THE KLS DESK WEBSITE

Version dated 16 April 2025

Courtesy translation - Only the French version is authentic.

 

The personal data protection policy (hereinafter referred to as the "Policy") sets out the manner in which the personal data of users, as prospective customers and customers (hereinafter referred to together as the "Users") are collected and processed by KLS when they visit the website https://www.kls-desk.com (hereinafter referred to as the "Website"), as part of the promotion of its products and services.

Users' personal data collected by KLS (hereinafter referred to as the "Personal Data") may be subject to processing, whether automated or not, in accordance with European Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as the "GDPR") and any applicable national regulations.

1. Data controller and purposes

The Personal Data collected on the Website are collected by KLS, the publisher of the Website and acting as the data controller within the meaning of the RGPD, except where it is expressly stated on the Personal Data collection medium that the data controller is a third party. In this case, in accordance with the law, the data controller will specify to Users the characteristics of the processing that it implements under its sole responsibility.

KLS undertakes to process Personal Data only for specified, explicit and legitimate purposes, to limit the collection and processing of Personal Data to that which is strictly necessary (data minimisation) and not to process it further in a manner incompatible with those purposes. Personal data means any information relating to an identified or identifiable natural person. This data may vary depending on the nature of the product or service subscribed to.

In the context of their visit to the Website, KLS uses all or part of the Personal Data concerning Users, for the purposes described below and on the following legal basis:

Legal basis	Purposes and sub-purposes
Legitimate interest:  promote products and services and develop the prospect base to improve sales; to respond to a request to ensure safe browsing on the Website.	Prospecting and sales promotion: to enable Users to access the Website and to develop, maintain and improve the Website in order to promote its products and services; develop relations with Users and respond to requests for information made by Users using the contact forms. Risk management: use of cookies/technical tracers strictly necessary for the operation of the Website, in particular to guarantee the security of the network and information.
Consent	Prospecting and sales promotion: personalisation of content, products and services offered through the Website; creation of reliable commercial prospecting databases and implementation of prospecting and sales promotion campaigns (sending personalised commercial communications to prospective customers); use of cookies/trackers for: audience measurement (subject to consent) ; personalised advertising, sharing (social networks). use of a technology for recording and transcribing oral exchanges into written form, for the restitution of meetings with prospects using a technology for transcribing oral exchanges into written form. to carry out marketing profiling operations that do not have any legal effect on Users, such as marketing segmentation and selection, in order to suggest innovative services and products, to propose complementary or personalised promotional offers and to provide a better quality service to Users.

 

The nature of the operations carried out on Personal Data through the Website is the collection, recording, consultation, reconciliation, consolidation and storage for the purpose of making it available to Users. 

2. Categories of Personal Data processed 

The Personal Data processed by KLS are: 

Data category	Data processed
Civil status, identification, identification data, image (surname, first name, pseudonym, date of birth, identification number, postal or e-mail address, image, etc.)	Surname, first name(s), email address, telephone number.
Professional life (CV, education, professional training, awards, etc.)	Company name, profession, business sector.
Economic and financial information (income, financial situation, tax situation, etc.)	No.
Banking and payment information	No.
Connection data (IP address, logs, etc.)	Logs, cookies and other tracers (SDK etc.), IP address.

 

Under no circumstances does KLS sell Users' Personal Data to third parties.

3. Duration of storage of Personal Data

Purposes of processing	Shelf life
Prospecting and sales promotion: personalising the content offered on the Website, creating reliable commercial prospecting databases and sending personalised commercial communications.	Until consent is withdrawn or 3 years from the end of the last contact from the prospect in the case of data relating to commercial prospecting; Until consent is withdrawn or 3 years from the last contact from the prospect in the case of recording and transcribing oral exchanges into written form (reports) for the purposes of restitution of appointments in the context of competitive tendering procedures.
Use of cookies/trackers for audience measurement (subject to consent), personalised advertising and sharing (social networks).	6 months from the date they are deposited for logs, cookies, technical tracers (SDK, pixel, tags, or local storage) and the date they are collected for IP addresses 6 months maximum for cookies and other tracers subject to consent (SDK, pixel, tags, or local storage).

 

The retention periods for Personal Data are necessarily extended for the legal period of foreclosure or prescription as evidence in the event of litigation. In the latter case, the retention period for Personal Data is extended for the duration of the dispute. 

After the deadlines set out above, Personal Data is either deleted or kept after being anonymised, in particular for statistical purposes. You are reminded that deletion or anonymisation are irreversible operations and that KLS is no longer able to restore them.

4. Storage and transfer of Personal Data outside the EU

KLS stores Users' Personal Data on the servers of the following service provider: 

• Hubspot France SAS, 91 Boulevard Haussmann, 75008 Paris, France.

Website: https://www.hubspot.fr 

Contact form: https://preferences.hubspot.com/privacy?locale=fr 

Telephone number: +33 1 86 26 07 91. 

KLS takes the utmost care to ensure that Users' Personal Data is processed and stored in the territory of the European Union or in a country whose legislation is recognised as adequate by a decision of the European Commission in accordance with Article 45 of the RGPD. Thus, Users' Personal Data collected as part of their visit to the Website are hosted by Hubspot on servers located within the European Union. 

However, Users' Personal Data may be transferred outside the European Union by service providers (as KLS’s data processors), to third countries (in this case, the United States). If this is the case, KLS implements a precise and demanding framework, in compliance with applicable European regulations, by signing dedicated contractual clauses (European Commission standard contractual clauses) and security commitments offering the level of guarantee required by European Union regulations (if the service providers do not benefit from the adequacy decision adopted by the European Commission with regard to the United States on 10 July 2023). 

Users may obtain a list of KLS's data processors and a copy of the guarantees associated with the transfer of Personal Data to third countries at any time, by contacting KLS at the address and in the manner specified in article 11 of this policy. 

5. Recipient of Personal Data

The recipients are the natural or legal persons who receive the Personal Data (hereinafter referred to as the "Recipients").

KLS ensures that Personal Data is only accessible to authorised internal and external Recipients, including in particular: 

• the staff of the relevant departments of KLS authorised to manage the relationship with clients and prospects; in this context, KLS decides which Recipient may have access to which Personal Data in accordance with an appropriate authorisation policy and ensures that they are subject to an obligation of confidentiality; 
• KLS's service providers, who process Personal Data on behalf of KLS and in accordance with its instructions, without being able to use this data for purposes other than carrying out the sub-contracted operations;
• the direct and indirect shareholders of KLS, who need to know (the authorities legally authorised to know; in this context, KLS is not responsible for the conditions under which the staff of these authorities have access to and use the Data. These transmissions are carried out in compliance with the "Compendium of procedures - authorised third parties" published by the CNIL.
  

6. Cookie management

When Users  consult the Website, information relating to their browsing may be recorded in "cookies" files installed on their terminals (computer, tablet, smartphone, etc.), subject to their expressed choices concerning cookies, which may be modified at any time. By "cookies" we also mean other tracers such as SDKs, pixels, tags or local storage, as tools integrated directly into the KLS Desk code.  

As indicated on the Platform's information banner, by clicking on the Accept cookies button, Users accept the deposit of cookies on their terminals. They may also choose to continue browsing without accepting the deposit of cookies by clicking on the Reject cookies button. However, certain cookies required for the Platform to function properly, for the security of products and services and for audience measurement purposes are not subject to the consent of the person concerned and will therefore remain active. Users may reverse their decision at any time by objecting to the deposit of cookies by clicking on the dedicated button. 

• What is a cookie?

A cookie is a small text, image or software file containing information which is recorded on the hard disk of the User's terminal (e.g. computer, tablet, smartphone or any device used for browsing the Internet) when a website is consulted using a browser or a web or mobile application (in particular via an SDK). It is transmitted by a website server to the browser. The cookie file records the pages visited, the type of browser used and the IP address used, and enables its issuer to identify the terminal in which it is stored for the duration of the validity or storage of the cookie concerned. Only the sender of a cookie is likely to read or modify the information contained therein.

• Why does KLS use cookies?

KLS uses several types of cookies, the purposes of which are described below. Certain technical cookies (session cookies in particular) are essential for the proper functioning of the Website. Their deletion may lead to navigation difficulties.  

6.1. Technical cookies

Technical cookies are strictly necessary for the operation of the Website. They enable access to reserved and personal areas of our Website, thanks to personal identifiers (cookie, session identifier), to implement security measures (for example, when you are asked to connect again to content or a service after a certain period of time), to enable or facilitate communication for the provision of a service by electronic means expressly requested by the User. 

6.2. Analytical and audience measurement cookies

These cookies collect information about how visitors use a Website or web application. 

KLS uses the Hubspot tool on the Website in a self-hosted version in order to measure the Website's audience (performance measurement, detection of browsing problems, optimisation of ergonomics, analysis of content consulted), on its exclusive behalf. In particular, Hubspot collects the IP address, browser and operating system of Users, in order to enable KLS to obtain data that can be used to help improve its products and services. 

6.3. Targeting and advertising cookies

These are cookies, subject to the prior consent of Users, which enable offers and information to be presented that are personalised and tailored to Users' centres of interest when browsing the Website and web applications.

KLS uses targeting and advertising cookies to personalise the editorial content and the display of its products and services on its Website according to those previously consulted by Users.

KLS uses the Hubspot tool for targeting and advertising purposes. In particular, it allows KLS to analyse the data from form submissions on its Website, to offer personalised content to Users on its Website, to guide them in their use of the KLS Desk, to build interactive and personalised knowledge bases for them, to provide a chat service to Users and to carry out personalised marketing campaigns.

6.4 Social network cookies

The Website may contain sharing buttons and links to LinkedIn and other similar social networks, which allow Users to share content offered by KLS with others. When Users use these sharing buttons, they are redirected to the Website of the relevant social network and any use of cookies by that social network will be governed by its privacy/cookies policy.

KLS invites Users to consult the personal data/cookies protection policies of these social networks in order to become aware of the purposes for which these cookies are used. They can be accessed below:

LinkedIn: https://www.linkedin.com/company/34710294

7. Security of Personal Data 

KLS reaffirms its commitment to ensuring that the security of Users' Personal Data is at the heart of everything it does. 

KLS takes all necessary physical, technical and organisational measures to protect the confidentiality, integrity and availability of Users' personal data, in particular against loss, accidental destruction, alteration and unauthorised access.

KLS also takes the utmost care to maintain a high standard of security and confidentiality of Users' Personal Data by raising the awareness of its employees and commercial partners, and by training its employees in data protection, by implementing content controls, by implementing tools and practices aimed at obfuscation, anonymisation, encryption and data encryption in order to ensure the protection of your personal data against internal and external risks of leakage of Personal Data. 

In the event of a violation of Personal Data concerning Users, presenting a risk to their rights and freedoms, KLS will notify the CNIL of this violation within the regulatory timeframe. In the event that this violation presents a high risk to the rights and freedoms of Users, KLS will inform them as soon as possible of the nature of this violation and the measures implemented to remedy it.

8. Failure to provide Personal Data

Users are not obliged to answer all the questions they are asked in the context of the various collection media and contact forms offered by KLS. However, failure to provide this Data may result in KLS being unable to process the User's request, or prevent the User from benefiting from certain KLS products and services.

9. Rights concerning Personal Data 

Users have rights to their Personal Data collected and processed by KLS in the context of the provision and promotion of its products and services.

Their rights are as follows: 

• a right of access, rectification and deletion of Personal Data (inaccurate, incomplete, equivocal or out of date): KLS guarantees Users access to their Personal Data collected or processed in the context of the commercial relationship;
• a right to object to the processing of Personal Data at any time in the context of commercial prospecting: KLS allows Users to object to the processing of commercial prospecting without justification.
• a right to limit the processing of Personal Data under the conditions provided for by the applicable regulations: if Users no longer wish certain of their Personal Data to be processed, they have the option of limiting its use under the conditions provided for by the applicable regulations.
• a right to the portability of Personal Data: KLS will return Users' Personal Data at their request, in a commonly used electronic format, so that they can, if necessary, forward it to the organisation of their choice.
• a right to withdraw consent at any time: Users may accept or refuse at any time to allow KLS to process some of their Personal Data. However, this may result in the termination of the registration process or access to the KLS Application.
• a right to lodge a complaint with a supervisory authority: Users have the right to lodge a complaint at any time with the CNIL as the French supervisory authority for regulations protecting personal data.
• a right to communicate to KLS as data controller their instructions concerning their Personal Data in the event of their death: Users may communicate their instructions concerning the fate of their data after their death.

The User may exercise this right by writing a simple letter to KLS, publisher of the Website, or to the banking or financial institution of which he or she is a member.

The User may contact the KLS Data Protection Officer at the following address: dpo@kls-desk.com or the Data Protection Officer of the banking or financial institution of which he or she is an employee.

In the event of a dispute, the User may lodge a complaint with the CNIL, whose website can be accessed at https://www.cnil.fr and whose head office is located at 3 place de Fontenoy, 75007 Paris. 

12. Updating the Policy

The Policy may be modified or amended at any time in the event of changes in legislation, case law, decisions and recommendations of the CNIL or practices. Any new version of the Policy will be brought to the attention of Users by any means that KLS deems appropriate and relevant, including electronic means and/or publication on the Website.