If there is any contradiction between the French language version of the Privacy Police. (here) and the translation, the French language version shall take precedence.
- Intermediate Archives: shall mean the movement of Personal Data which still present an administrative benefit for Jollyclick, (such as, for example, in the event of litigation and/or in the event of a legal obligation) in a separate database, separated logically or intentionally and for which, in any event, the access is restricted. This archive is an intermediate stage prior to the deletion of the Personal Data concerned or its anonymization;
- G.T.S.: shall mean the General Terms of Service accessible by clicking here: G.T.S.;
- Specific Rights: shall mean the rights granted by the Personal Data Regulations for Users concerning the processing of their Personal Data;
- Personal Data Regulations: shall mean the Law no.78-17 dated January 6, 1978 relating to I.T., files and liberties, modified by the Law no.2018-493 dated June 20, 2018 relating to the protection of personal data, in accordance with the E.C. Regulation dated April 27, 2016 published in the Official Journal of the European Union on May 4, 2016 relating to the protection of individuals with regard to the processing of personal data and the free movement of such data (called “GDPR” or General Data Protection Regulation);
- Terminal(s): shall mean the hardware (computer, tablet, smartphone, telephone, etc.) used by the User to consult or have the Website displayed and/or any other digital support edited by a third party;
- User: shall mean interchangeably the Webuser and/or the Talent.
In this case, designated processing is required for the performance of an agreement to which the User is a party.
Accordingly, in order to use the Website and to benefit from its Services, the User accepted the G.T.U. and, as the case maybe, the G.T.S. These documents formalize a contractual relation between the User and Jollyclick, and are used as the legal basis for the collection and processing of the User's Personal Data by Jollyclick.
This Personal Data is necessary for the accomplishment of certain processing related to the performance of the contractual relation between the User and Jollyclick, the purposes of which are set forth in Article 4 hereafter.
The processing of the Personal Data may also be necessary for the respect of a legal obligation to which Jollyclick may be subject, for example, the retention of access logins to the Website, in accordance with the Decree no. 2011-219 dated February 25, 2011 relating to the retention and communication of data to identify any person who has contributed to the creation of content posted online.
The processing of the User's Personal Data may also be necessary for Jollyclick's legitimate interests or for those of a third party, yet the User's interests and fundamental liberties shall prevail, as a protection of Personal Data is required in such case, in particular when the User is a child.
The processing of the User's personal data which is strictly necessary for the protection against fraud is an example of a legitimate interest for Jollyclick.
In the event whereby the processing would be based on a legitimate interest for Jollyclick or that of a third party, the latter shall ensure that the processing in question is actually necessary for the accomplishment of his legitimate interest and shall evaluate the consequences for this processing for the User, in particular taking into consideration the nature of the Personal Data processed, and the processing method used.
In any event, Jollyclick shall ensure not to misrepresent the User's interest and fundamental liberties by enabling the User to object to all or part of the processing as defined herein, at any time, and to implement Specific Rights, in the conditions of Article 9 hereafter.
4. The purposes of the processing carried out by Jollyclick
The User's Personal Data is required to enable access to the Services and their use, in particular via the creation of an Account, for the improvement of the Services, and to enable Jollyclick to:
- ensure interaction between Users according to their use of the Services;
- generate a profile calculated according to an algorithm according to the Talent's responses and the personality Test, which, for the record, is not obligatory;
- carry out the operations relating to his relation with the User, i.e., concerning the follow-up of the “client relation” with a User, such as carrying out satisfaction surveys, complaints management, the use of the Website and more generally, the Services, etc.;
- select Users to carry out surveys, opinion polls and service tests, as well as affiliation programs, prospection and promotion;
- customize the communication to the Users, in particular by information emails, according to his preferences that he has mentioned and from his use of the Services;
- carry out prospection operations, i.e., the management of technical prospection operation, (which includes, in particular, the technical operations such as standardization, beneficiation and deduplication);
- the setup of commercial statistics; analyses and marketing tools (in particular, classification, score, etc.);
- the organization of contests, lotteries or any promotional operation at the exclusion of online gambling, which is subject to the approval of the regulatory authority for online games;
- the management of requests to exercise rights as set forth in Article 8 hereafter;
- litigation management;
- the management of the Users' comments on the Website and/or on the website pages edited by Jollyclick such as the social network pages;
- the combat against fraud;
- the moderation of the Services in the conditions defined in the G.T.S.
The operations set forth hereafter are not used for establishing profiles that could result in the collection of sensitive Personal Data such as racial or ethnic origins, philosophical, political, trade union and religious opinions, sexual activity or health, and shall also not be used by Jollystick to produce automated decisions, in particular relating to the personality test.
5. The storage of Personal Data
The Website is hosted with Microsoft, the contact details of which are available by clicking here.
All the precautions were taken to store the Users' Personal Data in a secure environment and to prevent any distortion or damage to such data or any access thereto by any unauthorized third parties. The information provided by the User shall never be communicated to third parties for commercial purposes, nor shall such information be sold or exchanged.
6. The collection of Personal Data on the Website
Upon the creation of an Account and upon updates thereto, Jollyclick collects the following Personal Data, provided by the Talent or which is collected when the Talent is browsing the Website and related to his use of the Website and Services.
Such Personal Data is stored by Jollyclick for a period of two (2) years, in active mode, as from the Talent's latest connection to the Website:
- First name
- Email address
- The password and the data to be verified or modified, in their latest updated version
- Telephone number
- Level of expertise in a given skill, by auto-evaluation
- Form of co-operation
- Human qualities
- Language proficiency
- Project affiliation
- Project status
- Network affiliation
- Network status
- Accounts: Facebook, Twitter, Instagram, Youtube, Linkedin and others
- Subscription to third-party Talents
- Subscription to third-party Projects
- Third-party subscriber Talents
- Third-party subscriber Projects
- Subscription to third-party networks
- Third-party subscriber networks
- Events in which the Talent participates or expresses an interest
- Discussions in which the Talent participates
- Opinion polls in which the Talent participates
- Messages exchanged (sent and received)
- Invitations exchanged (sent and received)
- Browsing (duration of visits, searches, clicks, etc.)
- As the case maybe, the ground(s) of exclusion (all the elements enabling proof of actions that date less than one month and which justify the exclusion)
The Personal Data above is then stored in Intermediate Archives for an additional period of three (3) years, in accordance with the standard statute of limitation period.
Jollyclick collects the following Personal Data, from Website browsing and the use of the Services, including upon the creation of an Account, which is stored for a period of twelve (12) months in active mode, as from the User's latest connection to the Website:
For each use of the Services, in particular upon the creation, modification or deletion of Content: a) the login details at the origin of the communication; b) the login details attributed by the Website for the Content, subject of the operation; c) the types of protocols used for the connection to the Service and for Content transfer; d) the nature of the operation; e) the date and time of the operation; f) the Login used by the Talent, at the origin of the operation; g) the name and version of the browser and operating system used during the operation; h) the display resolution used during the operation.
Only the Personal Data designated as obligatory on the Website is necessary to open an Account.
The Talent is informed that the Content, Projects, Events created by the Talent and/or in which he has participated, and their time and date of access, shall remain on the Website upon the deletion of his Account and shall therefore be available to all the other Users. The Talent shall always be able to manually remove any of the aforementioned elements.
The Talent may also exercise one of his Specific Rights, in accordance with Article 9 herein.
7. Personal Data recipients or categories of recipients
In addition to the other Users in the context of the use of the Services by the Talent and within the limit of the Personal Data published by such Talent on the Website, in particular, on his Account and/or in the context of a Project, the recipients of the Users' Personal Data are listed hereafter.
- Recipient of the Personal Data transferred:Sendinblue
- Nature of the Personal Data transferred:Name, First name, Email
- Purpose of the transferCommunication to the Users by email (newsletter, warning, maintenance, launch of a new service or functionality, etc.)
- Place of storage of the Personal Data by the recipient:The hosting servers on which SendinBlue processes and stores the databases are exclusively located in the European Union, on Jollyclick's servers, on those of Google Cloud or AWS. SendinBlue rents units in data centers located in France (data centers DC2 and DC3 Online, which are located in Vitry-sur-Seine, in Ile-de-France), with SendinBlue's equipment. The data stored in the cloud is on Google Cloud in Belgium or on AWS in Ireland.
- Level of protection offered by the country or exception provided by the Personal Data Regulations if the transfer is made outside of the EU:GDPR level
8. Users' rights
In accordance with the Personal Data Regulations, the User may, at any time, benefit from the following Specific Rights:
- access (Article 39 of the Law no. 78-17 dated January 6, 1978 relating to I.T., files and liberties),
- rectification (Article 40 of the Law no. 78-17 dated January 6, 1978 relating to I.T., files and liberties),
- deletion (Article 40 of the Law no. 78-17 dated January 6, 1978 relating to I.T., files and liberties),
- limitation of processing (Article 40 of the Law no. 78-17 dated January 6, 1978 relating to I.T., files and liberties),
- portability (Article 20 of the GDPR),
- objection (Article 38 of the law no. 78-17 dated January 6, 1978 relating to I.T., files and liberties),
- post-mortem guidelines (Article 40-1 of the Law no.78-17 dated January 6, 1978 relating to I.T., files and liberties),
8.1. Access rights
The User may obtain confirmation of processing from Jollyclick for his Personal Data and in the affirmative, the access to such Personal Data and the following information:
- a) the purposes of the processing;
- b) the Personal Data categories;
- c) the recipients or categories of recipients of such Personal Data;
- d) when possible, the envisaged retention period for the Personal Data or, if this is not possible, the criteria used to define such duration;
- e) the right to request Jollyclick for the rectification or deletion of Personal Data, or a limitation on the processing of his Personal Data, or the right to object to such processing;
- f) the right to file a claim before the French Data Protection Authority (CNIL);
- g) when the Personal Data is not collected from the User, any information available regarding the source of such data;
- h) the existence of automated decision making, including profiling, and, at least in such cases, appropriate information concerning the underlying rationale and the importance and intended consequences for this processing for the User;
When the Personal Data is transferred to a third-party country or an international organization, the User is entitled to be informed of the appropriate guarantees concerning this transfer.
Jollyclick shall provide a copy of the Personal Data that is subject to processing.
Jollyclick may demand the payment of reasonable expenses based on the administrative costs for any additional copy requested by the User.
When the User presents his request electronically, the information is provided in a standard electronic format, unless requested otherwise.
The User's right to obtain a copy of his Personal Data must not violate others' rights and liberties.
8.2. Rectification rights
The User is entitled to request a rectification of any inaccurate Personal Data from Jollyclick, as soon as possible. He is also entitled to request that any incomplete Personal Data be completed, including by providing a complementary declaration.
8.3. Deletion rights
The User is entitled to request Jollystick to delete his Personal Data as soon as possible, in the event of the occurrence of one of the following reasons:
- a) the Personal Data is no longer necessary with regard to the purposes for which it was collected or processed otherwise by Jollyclick;
- b) the User has withdrawn his consent for the processing of his Personal Data and there is no other legal basis for the processing;
- c) the User exercises his right of objection in the conditions recalled hereafter and there is no imperative legitimate reason for the processing;
- d) the Personal Data has been subject to unlawful processing;
- e) the Personal Data must be deleted to respect a legal obligation;
- f) the Personal Data has been collected from a child.
8.4. Limitation rights
The User is entitled to request Jollyclick for a limitation in the processing of his Personal Data in the event of one of the following reasons:
- a) Jollyclick shall verify the accuracy of the Personal Data following a contestation by the User on the accuracy of the Personal Data,
- b) the processing is unlawful and the User objects to the deletion of the Personal Data and demands a limited use thereof;
- c) Jollyclick no longer requires the Personal Data for processing but the latter is still required by the User for the establishment, exercise or defense of legal entitlements;
- d) the User objected to the processing in the conditions recalled hereafter and Jollyclick shall verify whether the legitimate reasons established prevail over the alleged grounds of argument.
8.5. Right to Data portability
The User is entitled to request that Jollyclick send him his Personal Data in a standard, structured and machine-readable format:
- a) the processing of Personal Data is based on consent, or on a contract and
- b) the processing is carried out with the assistance of automated processes.
When the User exercises his right of portability, he is entitled to request that his Personal Data be transferred directly by Jollyclick to another data controller whom he shall designate when this is technically possible.
The User's right of portability on his Personal Data must not violate others' rights and liberties.
8.6. Right of objection
The User may object at any time, for reasons pertaining to his specific circumstances, to the processing of his Personal Data based on a legitimate reason by Jollyclick. The latter shall no longer process the Personal Data unless he is able to prove the existence of imperative and legitimate reasons for the processing which prevail over the User's interests, rights and liberties, or may retain such data for the establishment, exercise or defense of legal entitlements.
8.7. Post-mortem guidelines
The User is entitled to communicate guidelines to Jollyclick relating to the retention, deletion and communication of his Personal Data after his demise, with the possibility for the User to also register such guidelines with a “certified and reliable third-party digital player”. These guidelines, or so-called “digital testament”, may designate a person in charge of their performance; failing that, the User's heirs shall be designated.
In the absence of any heirs, the User's heirs may contact Jollyclick to request the following:
- to access the Personal Data processing enabling the “organization and settlement of the demised's estate”;
- to receive communication of “digital assets” or “data belonging to family memories, transferable to the heirs”;
- to close the User's account on the Website and to object to the continuation of the processing of his Personal Data.
In any event, the User shall be entitled to inform Jollyclick, at any time that, in the event of his demise, he does not wish for his Personal Data to be communicated to a third party.
9. Exercise of the Users' Specific Rights
These rights may be exercised at any time from Jollyclick:
- By email at the following address: firstname.lastname@example.org
- By post at the following address: 12 rue Albert Einstein, 48000 Mende.
In order to assert his rights according to the conditions referred to above and in the event whereby Jollyclick were to query the identity of the party making the request, Jollyclick may request the latter to provide proof of his identity by mentioning his name, first name and email address and to accompany his request with a copy of his currently valid identity document.
A response shall be sent to the User within a maximum period of one (1) month following the date of receipt of the request.
As necessary, this period may be extended by two (2) months by Jollyclick, which shall avert the User and in consideration for the complexity and/or number of requests.
In the event of a request from the User for the deletion of his Personal Data and/or in the event whereby he exercises his right to request the deletion of his Personal Data, Jollyclick may nonetheless retain this data as an Intermediate Archive, for the required period to meet his legal obligations or for the purposes of proof during the applicable period for the statute of limitations.
The User may also file a complaint before the relevant authority (the CNIL).
10. The User's password security
Jollyclick shall take all the necessary precautions to ensure the secured storage of the User's password to access his Account.
Nevertheless, the security of this password also depends on its creation.
Furthermore, the User is reminded that in order for his password to be valid, it must be comprised, a minima of 8 characters, at least 3 of the following 4 types: letters in the upper case, lower case, figures and special symbols and/or signs.
For the purposes of security, Jollyclick shall temporarily file lock the Account after (3) consecutive and erroneous attempts at entering the password, and an extended file lock after ten (10) erroneous attempts and which may only be unlocked after an express and prior validation from Jollyclick.
Mnemonic techniques enable the creation of complex passwords such as:
- only using the first letters of words in a phrase; for example, the phrase “Un Mot de Passe se retient !” corresponds to the password 1mdp@sr!
- by using a capital letter if the word is a name (e.g.: word)
- by keeping the punctuation signs (e.g.: !)
- by expressing the numbers through the use of figures from 0 to 9 (e.g.: One ->1)
11. The cookies deposited on the User's Terminal following his browsing on the Website
Cookies are used on the Website.
A cookie is information filed on the Terminal which enables the User to access the Website.
Cookies are related to the User's browsing on the Website and enable an identification of the pages that he has consulted, and their date and time of consultation.
Under no circumstances, shall these Cookies enable Jollyclick or the Cookie editor to personally identify the User.
The retention period for these cookies on the User's Terminal may not exceed (13) months.
More specifically, the Personal Data collected from the cookies issued by Jollyclick or third parties enables:
- the establishment of statistics and volumes in terms of visits and use of the Website, which shall enable an improvement of the opportunity and ergonomics of the Services;
- to adapt the presentation of the Website to the display preferences on the User's Terminal (language used, display resolution, operating system used, etc.);
- to memorize the information relating to a form completed by the User on the Website (inscription or access to your account);
- to enable the User to access his Account through his pre-registered login details;
- to setup security measures, for example, when it is requested of the User to reconnect to his Account after a certain time has elapsed.
As a result of the cookies, Jollyclick collects and processes for the purposes defined above, all or part of the data and the following Personal Data:
Information relating to the User's Terminal:
- his type of Terminal (Smartphone, tablet, computer, etc.);
- his Terminal operating system (Mac Os, iOS, Android, Windows, BlackBerry etc.);
- the browser that he uses (Safari, Chrome, Internet explorer, etc.);
- his Terminal IP address;
- the geotracking data from his Terminal;
- his language preferences;
- his display resolution.
Information on his browsing and his use of the Website:
- the statistics on the consultation of the different pages of the Website;
- the complete URL links to, via and from the Website.
12. Cookies hosted by Jollyclick
|Service and type of cookie||Role of the cookie and the data collected||Duration|
|Session cookie||Enable and maintain the User's connection to Jollyclick. No data collected.||30 minutes|
|Matomo cookie||Enable a statistical follow-up of the use made by the Users when browsing in order to adapt the service to the latter's actual requirements. The data collected is listed above in Article 11.||13 months|
|Open Web Analytics cookie||It is a similar and supplementary tool to that of Matamo enabling the statistics to be combined and to ensure service availability in the event of a default in the feedback from Matomo.||13 months|
13. Objection to cookies
The User is informed upon his first visit, that he is entitled to object to the registration of cookies which are ancillary to the Website's functioning and, in particular, by setting his Web browser accordingly or by making his selection on this page (see below).
When the User browses on the Website, information may be registered, or read, on his Terminal, at his discretion and according to the options that he has expressed.
You shall find more assistance on the specific pages of your browser (hereafter the most frequently used browsers):
The User may also set his browser to ensure that the latter sends a code mentioning his “no tracking” option to the Websites: