Privacy policy

SMILE WANTED GROUP, a simplified joint stock company whose registered office is located 41 rue Boissy d’Anglas – 75008 Paris, registered with the Paris Trade and Companies Registry under number 818 380 040 (hereinafter, the « Company ») in its capacity as data controller, attaches great importance to the protection and respect of your privacy.

The purpose of this policy is to inform you of our practices regarding the gathering, use and sharing of information that you may provide to us through the website https://www.smilewanted.com (hereinafter, the « Site »).

This policy describes how we handle the personal data we gather and that you provide to us. We invite you to read this document carefully to know and understand our practices regarding the processing of your personal data.

Article 1. Data controller

The data controller on the Site is the Company.

As such, the Company determines the purposes, technical and legal means of the processing of personal data and undertakes to take all necessary organizational measures to ensure safe processing and compliance with the Data Protection Act of January 6, 1978, as amended by the Act of August 6, 2004 (hereinafter, the « Act ») and the European Regulation of April 26, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, the « GDPR »).

Article 2. Method of processing personal data

The use of the Site, the access to some of its sections and/or any request for information or services from the users of the Site may lead to the communication of personal data.

Personal data will be processed mainly in an automated manner, with procedures strictly related to the purposes mentioned in Article 3 below.

The Company is committed to ensuring that your personal data is processed securely and confidentially and takes appropriate measures to prevent the loss, misuse, alteration, and deletion of such personal data.

Article 3. Purposes of personal data processing

Your personal data are processed for the following purposes:

  Purposes    Legal basis  Duration of data retention
Processing of requests (for information or intervention), files, follow-up, etc.;Management of customer relations;Improvement of the navigation on the Site and correction of possible errors;Improvement and personalization of the Company’s services;To carry out pre-contractual measures taken at your requestYour data is kept for a period of 3 years from your last contact.
To constitute a file of customers and prospectsOur legitimate interest in developing and promoting our businessFor customers: data is kept for the duration of the contractual relationship.   For prospects: data is kept for a period of 3 years from your last contact, for prospecting purposes.
To send newsletters, solicitations, and promotional messages to our prospects; to invite them to eventsBtoC Prospects: Your consent   BtoB Prospects: Our legitimate interest in building loyalty and informing our prospects of our latest newsData is kept for 3 years from your last contact or until your consent is withdrawn.
To manage requests to exercise rightsOur legitimate interest in responding to your requests and keeping track of themIf we ask you for proof of identity: we keep it only for the time necessary to verify your identity. Once verification is complete, the credential is deleted.   If you exercise your right to opt-out of receiving marketing communications: we keep this information for 3 years.

Article 4. Personal data likely to be processed

A personal data is a data that allows to identify an individual directly or by cross-checking with other data.

Mandatory data are indicated when you provide us with your data. It is marked with an asterisk and is necessary to provide you with our services.

We may collect and process the following data:

4.1. Information that you provide directly to us

By using the Site, you are led to transmit information to us, some of which are likely to identify you. This is particularly the case when you fill in forms, when you contact us – whether by telephone, email or any other means of communication – or when you inform us of a problem. This information contains in particular the following data:

  • Name, first name, title, date and place of birth;
  • Telephone number, e-mail address, postal address;
  • Data relating to your profession (in particular, the identity of the company, the position held, the sector of activity);
  • Any information that you wish to provide us in the context of your contact request;
  • A copy of all the services provided by the Company;
  • Data that we may ask you to provide when you report a problem with the Site or our services, such as the purpose of your request;
  • Consent (click) data primarily for access to the services.

This information is mandatory. Otherwise, the Company will not be able to provide you with the services offered by our Site.

4.2. Data that we collect automatically

During each of your visits, we may collect, in accordance with applicable legislation and with your consent, where applicable, information relating to the devices on which you use the Site or the networks from which you access our services, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, data about your browsing experience on the Site, including your path through the various URL pages of the Site, the content you access or view, search terms used, download errors, the length of time you spend viewing certain pages, your device’s advertising ID, interactions with the page, and any telephone number used to contact us. Among the technologies used to collect this information, we use cookies as described in Section 9 below

The Company does not process sensitive data within the meaning of Article 9 of the GDPR (i.e. personal data revealing racial or ethnic origin, philosophical, political, trade union or religious opinions, sex life or health).

Article 5. Communication of users’ personal data for internal purposes

5.1 Scope and purposes

Personal data may be transmitted to employees, collaborators, or service providers of the Company who, operating under the direct authority of the Company, are appointed as data controller or subcontractors of such data and receive the appropriate operational instructions. Personal data may also be made known to employees or collaborators of the data controllers if the latter, appointed by the Company, so decide and provided that such data are processed in accordance with the purposes pursued.

5.2 Obligations of the Company

The Company ensures that its subcontractors, employees or collaborators guarantee the same level of protection as the Company, and ensures that these subcontractors, employees or collaborators process personal data only for the goals authorized by the purposes pursued, with the required discretion and security.

5.3 External service providers

Users’ personal data may be communicated to and processed by external service providers acting on behalf of the Company.

5.4 Transfer of personal data

Your data is kept and stored for the duration of the processing on the servers of Hetzner Online GmbH, located at 91710 Gunzenhausen, Germany.

Your data will not be transferred outside the European Union.

Article 6. Rights of Users

6.1 Right of information

This is the reason why we have drafted this policy. This right is provided for in Articles 13 and 14 of the GDPR.

6.2 Withdrawal of consent

You have the right to withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of the processing already carried out, based on the consent given prior to such withdrawal.

This right can be exercised electronically at [email protected] or by mail at the following address : SmileWanted – 41 rue Boissy d’Anglas – 75008 Paris indicating the mention « SECURITY » in the subject line of the email or on the envelope.

6.3 Right of access to personal data

The Company guarantees you a right of access to your personal data.

In accordance with Article 15 of the GDPR, you have the right to obtain from the Company the following information regarding your personal data:

  1. purposes of the processing;
  2. categories of personal data concerned;
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients who are established in third countries or international organizations;
  4. where possible, the period of time for which the personal data will be kept or, where this is not possible, the criteria used to determine this period;
  5. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, where applicable, at least useful information regarding the underlying logic, as well as the significance and intended consequences of such processing for the data subject.

6.4 Right of correction and deletion of personal data of the user

In accordance with Article 16 of the GDPR, incorrect or inaccurate data can be corrected or deleted at any time. You may request the Company to make these changes if they cannot be made independently.

You have the right to obtain the deletion of your personal data in the cases listed in Article 17 of the GDPR.

6.5 Right to data portability

In accordance with Article 20 of the GDPR, you have the right to receive from the Company your personal data in a structured, commonly used and machine-readable format. You also have the right to transfer your data to another data controller, without the Company interfering with this in the cases provided for in the GDPR.

6.7 Right to object to data processing

You have the right to object to the processing of your personal data at any time, where there are compelling and legitimate reasons relating to your particular situation. In this case, the Company will no longer process the personal data, unless there are compelling legitimate grounds for the processing that override the interests and rights and freedoms of the user, or for the establishment, exercise or defense of legal claims.

6.8 Right to limit processing

You have the right to obtain the limitation of the processing of your personal data in the cases listed in Article 18 of the GDPR.

6.9 Right to make a complaint

You have the right to make a complaint regarding the processing of your personal data by the Company with the Commission Nationale de l’Informatique et des Libertés, the competent body for the French territory.

6.10 How to exercise these rights

You may, at any time, exercise the rights mentioned above and/or modify the data provided by sending an e-mail to the following address [email protected] or by mail to the following address : SmileWanted – 41 rue Boissy d’Anglas – 75008 Paris indicating the mention « SECURITY » in the subject line of the email or on the envelope.

6.11 Right to define directives relating to the retention, deletion, and communication of personal data after death

Law No. 2016-1321 of October 7, 2016 (Law for a Digital Republic) has enshrined the right to organize the fate of one’s personal data after death. This right allows individuals to give directives regarding the retention, deletion, and communication of their personal data after their death.

Article 7. Limitation of responsibility of the data controller

The Site may contain hypertext links to websites controlled and operated by third parties not related to the Company. In this case, the Company cannot be held responsible for the content of these sites, nor for the personal data protection practices of these third parties. We encourage you to review the privacy policies of these sites before submitting your personal information to them.

The Company cannot be held responsible for the loss, corruption of data or identity theft, which may be caused, in particular but not limited to, by the presence of viruses or computer attacks.

Article 8. Cookies

The Company uses cookies in order to offer an improved and more personalized service.

8.1 What is a cookie and what is its purpose?

A « cookie » is a small amount of data in « text » format sent to a user’s browser by a website and stored on the user’s computer hard drive.

Cookies also make interactions with sites safer and faster because they can remember your preferences (such as your user ID and language) by sending the information they contain back to the original site (internal cookie) or to another site to which they belong (third-party cookie) when you revisit the site from the same terminal.

Depending on their function and the purpose of their use, cookies are classified into the categories described below and used by the Company on this Site:

  • Absolutely necessary cookies allow you to move around the Site and use its basic features. They are generally installed only in response to actions on your part to access services, such as logging into a secure area of our site. These cookies are essential for using the Site.
  • Functionality cookies are used to recognize you when you return to the Site and allow us to provide you with enhanced and more personalized features, such as saving your preferences (e.g., your language choice or region). These cookies collect anonymous information and cannot track your movements on other sites.
  • Analytics and performance cookies allow us to recognize and count the number of visitors to the Site and to collect information about how the Site is used (e.g., which pages visitors view the most, do visitors get error messages on certain pages, etc.). This allows us to improve the way the Site operates, for example, by ensuring that users can easily find what they are looking for.
  • Advertising or targeting cookies record your visit to the Site, as well as the pages you view and the links you follow. We will use this information to display ads that are relevant to your interests. It is also used to limit the number of times you see the same ad and to help measure the effectiveness of advertising campaigns. Thus, we may also share this information with third parties (such as advertisers).

One or more « cookies » are placed by the Company or its service providers and advertising partners on your computer’s hard drive when you browse the Site. Their purpose is not to infringe on your privacy. They allow us to constantly improve the service offered in terms of access to content, to recognize you when you connect to the Site again, to facilitate the management of the Company, and for statistical purposes (pages consulted, date and time of consultations, etc.).

8.2 Use of third-party cookies

Please note that the Company uses the services of third parties to track your use of this Site to optimize your user experience and to display advertisements outside of this Site. These third parties (such as advertising networks and external service providers, such as web traffic analysis services) may also use cookies that we do not control.

8.3 What if you do not want to enable cookies?

You can revoke your consent to the use of cookies at any time in the following ways:

  • By setting your internet browser

If you wish to delete the cookies stored on your terminal and set your browser to refuse cookies, you can do so via your internet browser preferences.

These browser options relating to cookies are usually found in the « Options », « Tools » or « Preferences » menus of the browser you are using to access this site. However, different browsers have different ways of disabling cookies. To find out how to do this, visit the sites linked below according to your browser type: FirefoxGoogle ChromeInternet ExplorerSafariOperaiOSAndroid.

Please note that if you refuse to accept cookies from your browser, you will still be able to browse this Site, but some parts and options may not function properly.

  • By disabling cookies online

For cookies set by Google Analytics, you can refer to the following links:

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

https://tools.google.com/dlpage/gaoptout?hl=fr

  • By using online advertising cookie control platforms:

Regarding advertising cookies deposited by third parties, you can also connect to the Youronlinechoices site, proposed by digital advertising professionals grouped together within the European association EDAA (European Digital Advertising Alliance). You will be able to refuse or accept the cookies used by the member advertising professionals.

For more information on cookies, you can visit the CNIL website at this address: https://www.cnil.fr/vos-droits/vos-traces/les-cookies/

Article 9. Modification of the Privacy Policy

The Company reserves the right to modify this Privacy Policy to comply with the obligations provided by the legislation protecting privacy or in order to adapt it to its practices.

Therefore, you are invited to consult it regularly to be aware of possible modifications and adaptations.

Article 10. Contact

If you have any questions about this Privacy Policy or if you have any requests regarding your personal data, you can contact us by sending an email to: [email protected] or by mail to the following address : SmileWanted – 41 rue Boissy d’Anglas – 75008 Paris.

Version updated on 01/01/2023

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