Personnal Data Protection Policy Kls
This personal data protection policy sets out the way user data is processed within the website https://www.kls-desk.com ("the Public Website") and the website app.kls-platform.com or app.kls-desk.com ("the Kls Desk"), together the Websites ("the Websites").
Users of this Website(s) may communicate personal data concerning them to Kls, publisher of the Website(s), using the various collection media, tools and services made available to them on the Website(s).
In addition, any banking or financial institution that is a client of the Kls Desk may collect the personal data of the borrowing legal entities, available on the Kls Desk, in accordance with their own personal data policies.
The data collected may be processed, automated or not, in accordance with the General Data Protection Regulation “GDPR” of 27 April 2016 and under the conditions attached to each collection medium or service, described in the General Terms and Conditions of Use of the Websites and this personal data protection policy.
DATA CONTROLLER AND PURPOSES
1.1 On the Public Website
The personal data collected via the various data collection services or media appearing on the Public Website are collected by Kls, acting as a data controller within the meaning of the GDPR, except when it is expressly stated on the data collection medium that the data controller is a third party.
In this case, in accordance with the law, the data controller specifies to the User the characteristics of the processing that it implements under its sole responsibility.
In the context of the use of the Public Website, the personal data communicated by the User is collected and processed by Kls, to perform a contractual or pre-contractual obligation vis-à-vis the User, to comply with legal obligations or to satisfy the legitimate interest of the publisher of the Public Website or a third party without infringing the rights of the User.
On these bases, personal data is collected and processed to provide the following services:
For Kls:
- enabling the operation of the Public Website;
- ensure the monitoring of usage and analytics;
- allow the sending of emails;
- commercial presentation of the Kls Desk.
The nature of the operations carried out on the data is:
- consolidation of such data within the tool.
The purpose(s) of the processing is/are:
- be contacted by Kls operational teams;
- receive a presentation from the Kls Desk;
- enable the proper functioning of Kls Desk and the analysis of incidents.
Personal data processed:
| Category of Data | |
|---|---|
| Marital status, identification, identification data, image(surname, first name, nickname, date of birth, identification number, postal or electronic address, image, etc.) | Yes If yes: Surname, First name, Work email address, Work telephone |
| Personal life (lifestyle, family situation, etc.) | No |
| Professional life(CV, education, professional training, awards, etc.) | Yes: Current position (Position and company) |
| Economic and financial information (income, financial situation, tax situation, etc.) | No |
| Login data (IP address, logs, etc.) | No |
| Location data (travel, GPS data, GSM, etc.) | No |
| Sensitive data(health data; social security number; data on offences, convictions and security measures; philosophical, political, religious, trade union beliefs, sex life, racial or ethnic origin) | No |
1.2 On the Kls Desk
The personal data is collected via the various data collection services or media appearing on the Kls Desk either:
- by any banking or financial institution that is a client of the Kls desk, acting as a data controller within the meaning of the GDPR;
- by Kls, acting in its capacity as Data Controller within the meaning of the GDPR.
except when it is expressly stated on the data collection medium that the data controller is a third party.
In this case, in accordance with the law, the data controller specifies to the User the characteristics of the processing that it implements under its sole responsibility.
In the context of the use of the Kls Desk and its applications, the personal data that the User communicates on the Kls Desk is collected and processed by any banking or financial institution that is a client of the Kls Desk, either by Kls, in order to fulfil a contractual or pre-contractual obligation vis-à-vis the User, comply with legal obligations or with the pursuit of the legitimate interest of Kls or a third party without infringing the User's rights.
On these bases, personal data is collected and processed to provide the following services:
For any banking or financial institution that is a client of the Kls Desk:
- allow any banking or financial institution to ensure the entry into contact with a borrowing legal person.
The nature of the operations carried out on the data is:
- consolidation of such data within the tool.
The purpose(s) of the processing is/are:
- collect the information of the borrowing legal entity in order to know it to meet its needs while respecting the regulations.
Personal data processed are:
| Category of Data | |
|---|---|
| Marital status, identification, identification data, image (surname, first name, nickname, date of birth, identification number, postal or electronic address, image, etc.) | Yes If yes: identity of the legal representative of the borrower legal entity, identity of the borrower if natural person, address of the borrower if natural person, tax number if borrower is a natural person, SIRET number of the end customer borrower, legal form if the end customer is a borrower |
| Personal life (lifestyle, family situation, etc.) | No |
| Professional life (CV, education, professional training, awards, etc.) | No |
| Economic and financial information (income, financial situation, tax situation, etc.) | No |
| Login data (IP address, logs, etc.) | No |
| Location data (travel, GPS data, GSM, etc.) | No |
| Sensitive data (health data; social security number; data on offences, convictions and security measures; philosophical, political, religious, trade union beliefs, sex life, racial or ethnic origin) | No |
For Kls
- allow the connection of the natural person (the User) representing any banking or financial institution client of the Kls Desk (the "Client") on the Kls Desk, carry out data analyses.
The nature of the operations carried out on the data is:
- consolidation of such data within the tool.
The purpose(s) of the processing is/are:
- operation of the Kls Desk and its applications:
- login to Kls Desk;
- invitation of non-registered persons to the Kls Desk;
- registration of acceptance of the general terms and conditions of use of the Kls Desk;
- monitoring of the use and analytics;
- verify that the user is not a robot;
- sending emails by the Kls Desk.
Personal data processed is:
| Category of Data | |
|---|---|
| Marital status, identification, identification data, image (surname, first name, nickname, date of birth, identification number, postal or electronic address, image, etc.) | Yes If yes: Surname, First name, Email, Title, Landline telephone, Mobile telephone, Password, Secret question, Answer to the secret question, Position, Account creation date, Date of the last login |
| Personal life (lifestyle, family situation, etc.) | No |
| Professional life (CV, education, professional training, awards, etc.) | Yes: Current position |
| Economic and financial information(income, financial situation, tax situation, etc.) | No |
| Login data (IP address, logs, etc.) | Yes: IP, Logs |
| Location data (travel, GPS data, GSM, etc.) | No |
| Sensitive data (health data; social security number; data on offences, convictions and security measures; philosophical, political, religious, trade union beliefs, sex life, racial or ethnic origin) | No |
COOKIE MANAGEMENT
When consulting the Websites https://www.kls-platform.com and https://app.kls-platform.com/, together the Websites ("the Websites"), information relating to the browsing of the user and the Client may be recorded in "Cookies" files installed on the device (computer, tablet, smartphone...) subject to the choices expressed regarding cookies and which the user or the Client may modify at any time.
The information below allows the User or the Client to better understand the operation of cookies and the use of current tools in order to configure them.
1. What is a cookie?
A cookie is a small text, image or software file containing information that is stored on the hard drive of a device (e.g., a computer, tablet, smartphone, or any device used to browse the Internet) when a website is visited by a browser. It is transmitted by the server of a website to the browser. The cookie file concerns in particular the pages visited, the advertisements on which the user or the Client has clicked and allows its issuer to identify the terminal in which it is stored, during the period of validity or storage of the cookie concerned.
Only the issuer of a cookie is likely to read or modify the information contained in it.
Cookies improve the browsing experience on the Websites(s) and are essential for access to certain secure areas. If the user or the Client Institution decides to block all cookies through the web browser, he/it will only be able to visit the public part of the Website(s).
As indicated on the information banner of the Website(s), by continuing to browse the Website(s), the user or Client accepts the placement of cookies on his device. The Client may revoke this decision at any time by objecting to the placement of cookies.
2. Why do we use cookies?
We use two types of cookies, the purposes of which are described below. Some technical cookies (session cookies in particular) are essential for the proper functioning of the Website(s). Deleting them can cause browsing difficulties.
3. The technical cookies
Technical cookies are cookies that are strictly necessary for the operation of the Website(s). They allow access to the reserved and personal areas of the Website(s), using personal identifiers (session identifier cookie), implement security measures (for example, when it is necessary to log in again to a content or service after a certain period), allow or facilitate communication for the provision of a service by electronic means expressly requested by the Internet user.
These cookies are issued and placed by the Website(s).
4. Audience measurement cookies – production of statistics
These cookies collect information about how visitors use a website or web application.
KLS uses the Matomo tool on the KLS Desk in a self-hosted version in order to measure the audience of this site (performance measurement, detection of navigation problems, optimization of ergonomics, analysis of content consulted), for its exclusive account. In particular, Matomo collects the IP address, browser and operating system of Users, to enable KLS to obtain data that can be used to help improve its products and services.
KLS also uses the Hotjar tool on the KLS Desk to record Users' browsing patterns. The Personal Data collected by Hotjar through cookies relates to the behavior of Users and their terminals (including language used, browser type, operating system, mouse events, pages visited, date and time of consultation and any specific events on the site etc.).
CHARACTERISTICS OF USE AND DATA COLLECTION
The User is not required to answer all questions asked on the Websites https://www.kls-desk.com and app.kls-platform.com or app.kls-desk.com. Failure to provide this data will make it impossible for the publisher of the Website(s) to process the User's request or for the User to be able to use the tool or service.
DATA RETENTION PERIOD
Personal data is kept and processed for the duration necessary to achieve the purpose pursued and at the most for the periods mentioned in this data protection policy:
| Processing concerned | Data retention period/data erasure period |
|---|---|
| Ensure entry into contact | According to the procedures of the regional agencies or any other financial institution of the Kls platform |
| Operation of the Kls Desk | 5 years from the end of the contractual relationship |
| Monitoring of the Use and Analytics | 1 year after the end of the last use of the account |
| Sending of Emails | 1 year after the end of the last use of the account |
| ReCAPTCHA Verification | 5 years from the end of the contractual relationship |
| Commercial Presentation of Kls | 5 years from the end of the contractual relationship |
TERMS OF EXERCISE OF THE RIGHTS OF THE NATURAL PERSON REPRESENTING ANY FINANCIAL INSTITUTION ON THE KLS DESK
The User has rights on the personal data concerning him/her collected and processed as a result the use of the Public Website https://www.kls-desk.com and the Kls Desk app.kls-platform.com or app.kls-desk.com and its applications. These rights are the following:
- a right of access, rectification and erasure of data (inaccurate, incomplete, ambiguous, or outdated);
- a right to object to data processing at any time in the context of commercial prospecting;
- a right to the restriction of the processing of the Client's data under the conditions provided for by the regulations;
- right to data portability;
- a right to withdraw consent for the Client at any time;
- a right to lodge a complaint with a supervisory authority;
- a right to communicate to the controller his/her instructions regarding the data in the event of death.
The User may exercise his/her right by writing by simple letter, to Kls, publisher of the Websites, or to the banking or financial institution of which he/she is a collaborator.
The User may contact the data protection officer of Kls at the following address: dpo@kls-platform.com or the data protection officer of the banking or financial institution of which he/she is an employee.
In the event of a dispute, the User may lodge a complaint with the CNIL, whose website is accessible at the following address https://www.cnil.fr and whose registered office is located at 3 place de Fontenoy, 75007 Paris.
DATA RECIPIENT
The User's or Client's personal data on the Kls platform may be communicated to third parties, exclusively located within the European Union.