Data Privacy Policy

Data Privacy Policy

As part of his use of this website and related services, personal data of the User may be collected by Kosc after obtaining his consent and with respect to the conditions below.

According to the European regulation, a personal data (here after “personal data”) means any information related to an identified or identifiable person. The processing of personal data is regulated by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (here after “GDPR”).

Kosc commits to take all the necessary measures to respect the privacy and protect the personal data of the User. Personal data are contained behind secured networks and are only accessible by Kosc employees and providers who have a need to know and who are required to keep the personal data confidential.

This policy is intended to provide the information necessary for the understanding of the User related to his personal data processing, in order to provide adapted services. Any capitalized terms not defined herein will have the meaning ascribed to them in the Terms of Use.

I – Personal data processed

1.     Categories of personal data

Kosc ensures to collect and process only necessary data regarding to the processing purpose and with respect to the data minimization principle.

Personal data can be collected during the navigation on website through cookies after obtaining the consent of the User (see below II – Use of Cookies) in except to the cookies strictly necessary.

Personal Data can be also collected:

·       By the registration to our newsletter or through our contact form. Personal data concerned are identification data (name, surname) and contact details (email) given by the User.

·       By the sending of a candidature in response to a job offer through our website. Personal data concerned are identification data (name, surname) and contact details (email) as well as any other information given by the User as part of his candidature (example CV or motivation letter).

2. Data controller identity and contact details

The data controller is Kosc, a company incorporated under the laws of France whose head office is at 33 Avenue du Maine, 75015 Paris, France, registered in the Paris Trade and Companies register under n° 813 528 866.

Regular mail:

Data Protection Officer

KOSC

33 Avenue du Maine

75015 Paris

FRANCE

3. Purposes of the personal data collected from the User

Personal data collected among the User are intended for internal use only and concerned the following purposes:

·       Management of the subscription to the Kosc newsletter,

·       Management of requests or exchange of information (contact forms),

·       Recruitment management (following an application for an employment offer or internship / alternation, unsolicited application),

·     Cookies management (such as improving the ergonomics of the Site and inserting share buttons on social networks, without the list being exhaustive (see below II – Use of Cookies).

The personal data collected does not lead to an automated decision-making within the meaning of Article 13.2 (f) of the European Regulation 2016/679.

In the event of further processing of personal data for other purposes than those for which the personal data has been collected and as identified above, the controller will provide the person with the information in advance about this other purpose and any other relevant information required before obtaining its consent.

4. Lawfulness of processing

The processing of personal data is based on the consent of the User wishing to use additional services via the website, such as the newsletter or the possibility to be contacted by Kosc. The User is informed that the provision of these data is not regulatory or contractual. It is therefore only optional and failure to respond to the collection of personal data will not affect navigation on the website.
As for the personal data processed for management purposes of external recruitments and associated applications, the legal basis of the treatment is the legitimate interest in accordance with article 6.1 f of the GDPR. These data will be processed for the sole purpose of analysis of the application and to proceed to the recruitment procedures.

5. Data Retention Period

The personal data collected are only kept for the period necessary to fulfill the purposes mentioned above.
The data collected as part of the subscription to the newsletter will be deleted within a maximum of 3 years without response to Kosc solicitations. 
The data collected via the contact form will be kept during the processing of the request for information or the time of the exchange.  
The data relating to cookies are stored for 13 months. 
The data collected as part of an application for a job offer will be destroyed immediately if the candidate is not selected for the position to be filled, or in the context of future recruitment. Otherwise, personal data will be kept within a maximum of 2 years from the last contact with the candidate.

6. Personal Data Recipient

Kosc has implemented an authorization policy for its employees. As a result, access to the User's personal data can only be accessed by our employees or providers with a professional interest in the context of their functions. 
For purely technical reasons, Kosc may be required to outsource some services to its charge (such as hosting the Website). The User is informed that the information collected by Kosc on the Website is only used by persons authorized by Kosc and that in any case they cannot be sold to third parties.

7. Personal Data Transfer

The User is informed that the data controller may, if necessary, transfer his personal data to a third country or to an international organization subject to an adequacy decision issued by the European Commission. However, in the case of a transfer to a country or an international organization which is not subject to an adequacy’s decision, such transfer may only be made subject to the provision of appropriate safeguards and effective remedies for Users, under the conditions of the Regulations in force.

8. Exercise of data protection rights by the User  

The User has the right to oppose, access, rectify, limit or delete his personal data. He may also request the portability of his data. He has also the right to withdraw, at any time, his consent to the processing of his personal data (without prejudice to the lawfulness of the treatment based on the consent made prior to his withdrawal).

No fee will be charged for requests from the User related to the exercise of his data protection rights. In the event of an unfounded or excessive request, Kosc may refuse to answer with the User's requests. In order to exercise any of the above rights, the User is invited to contact the Data Protection Officer at one of the following addresses: dpo@kosc-telecom.fr

Or KOSC TELECOM

To the attention of the Data Protection Officer (DPO)

33, avenue du Maine

75015 PARIS

In the event of a complaint to which Kosc has not given a satisfactory answer, the User is entitled to apply directly to the National Commission for Data Processing and Freedoms (CNIL): 3 Place de Fontenoy – TSA 80715 – 75334 Paris 07.
 

II- Use of cookies

According to the CNIL, « a cookie is a suite of information, usually small in size and identified by a name, that can be passed to your browser by a website you are connecting to. Your web browser will keep it for a period and return it to the web server each time you will reconnect. Cookies have many uses: they can be used to memorize your customer ID with a merchant site, the current content of your shopping cart, an identifier to trace your navigation for statistical or advertising purposes, etc.» 
Kosc uses cookies to improve the usability of the website (functional cookies), and to insert social sharing buttons (cookies issued by third-party applications).  
Kosc may include on its website, computer applications from third parties, which can share content with other people. This is particularly the buttons "Share" and "Like", from social networks such as LinkedIn. 
The social network providing such an application button is likely to identify the user with this button, even if he did not use this button by consulting the website. Indeed, this type of application button can allow the social network to follow the navigation of the User on the website because the account to the social network concerned was activated on the user's terminal (open session). 
Kosc has no control over the process used by social networks to collect information relating to the User's navigation on the website and associated with the data they have. Kosc invites the user to consult the privacy policies of these social networks to learn the purpose of use, including advertising, navigation information they can collect through these application buttons. 
These protection policies must enable the User to exercise his choices with these social networks by setting up his usage accounts for each of these networks. 
To know about the privacy policy of the social networks:

LinkedIn

During the User’s first visit to the Website, a banner informs the User or the presence of these cookies and invites him to indicate his choice.

They are only deposited if User accept them or continue his navigation on the Website. He can at any time withdraw his consent in the setting tools of his navigator or by clicking on the tab « withdraw my consent » at the bottom of the website.

How to change the browser settings? (proceedings for Chrome, Firefox, Safari, IE and Opéra)

On Chrome (https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=fr)

 

At the top right of the Chrome Window, click on « More » then « Settings ».

As the bottom of the page, click on « Advanced Settings ».

In the section « Privacy and Security », click on « Content Settings » then « Cookies ».

Uncheck « Allow sites to save / read cookies data ».

On Firefox (https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites)

At the top of the Firefox window, click on the Firefox button (Tools menu under Windows XP), then select "Options". 
Select the "Privacy and Security" panel. In "Content Lock", select the "Custom" option. 
Check "Cookies" to block them.

On Safari (https://support.apple.com/fr-fr/guide/safari/sfri11471/mac)

Go to "Settings" and then to "Preferences". 
Click on the "Privacy" tab. 
Select "Block all cookies".

On Internet Explorer (https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies)

Click on the gear icon at the top right of the Internet Explorer window and select "Internet Options". 
Click on the "Privacy" tab. 
Click on the button "Advanced", check the box "Ignore the automatic management of cookies".

On Opera (https://help.opera.com/en/latest/web-preferences/#cookies)

Go to "Settings" and then "Preferences".
Click on the "Advanced" tab, then "Privacy and security".
In the "Cookies" box, check the "Never accept cookies" box.

 

Applicable Law

Applicable Law

The Privacy Policy is subject to French Law and constitutes the entire agreement between Kosc and the User. The Privacy Policy is established in several languages. In the event of any dispute arising out the validity, interpretation and/or performance of the Privacy Policy, the Privacy Policy shall be submitted to the competent courts of Paris.