(June 2, 2021)
Type of data collected
The following data may be collected about you:
The data you provide
The mandatory or optional nature of the data you provide is indicated by an asterisk at the time of collection.
Creation of a listing
To create a listing, you must give us your nickname, your email address, and your city or zip code.
If you subscribe to a paying option to put forward your ad, we will also ask you for payment information (credit card number).
We use, on the basis of our legitimate interest, an automatic content analysis technology to detect unsolicited content, including fraudulent content. This technology is based on the information you provide when placing your ad and in your account, the history of the latter and technical data related to your use of the website.
When you create your Personal Account, you must communicate us your nickname and your email address, your language and your city.
When you create your Professional Account, you must provide us with your first and last name, mailing address, telephone number and email address.
You may also choose to provide us with the following information:
- Date of birth
- Socio-professional category
- Areas of interest
Customer support contact or advertisement reporting
When you contact our customer support or report an ad, you must provide us with your first and last name and your email address.
Responding to an ad
When you purchase an item from a seller while logged into an Account, the application will ask you to provide your real first and last name to the Seller so that they can ship your order.
If you sell an item on PLGRND, the buyer will have access to your email address so they can contact you if there is a problem.
Sharing a Listing
When you use the share a listing feature we collect the sending email and the recipient’s email.
Share a profile
When you use the share profile feature we collect the recipient’s email and use your account email to share the profile to your recipient.
Search Around Me
By clicking on “Search Around Me” in the app (coming soon), you agree to share your geolocation information with us so that we can respond to your search for Ads near you.
When you request information from us about our offers, both on the PLGRND app and on the plgrnd.app website, we may collect your full name, phone number and email address.
Secure Payment and Sales Service
If you are a Seller and you complete a transaction via our Secure Payment Service you must provide personal information to our payment provider Stripe Payments Europe, Ltd. (referred to as “Stripe” below).
Stripe uses these information to verify your identity in accordance with anti-money laundering and anti-terrorist financing regulations.
These information are as follows:
- First and last name
- Company name (if applicable)
- Mailing address
- Cell phone number
- VAT number (if applicable)
- Email address
- Date of Birth
- ID (proof of identity)
- IBAN (to receive money from your sales)
- Company website or social media profile
Secure Payment Service and Purchase
If you are a Buyer and wish to make a payment to an advertiser on our site, we collect your payment data (number, expiration date and cryptogram of your bank). For this purpose, they are transmitted to our payment service provider Stripe, which technically supports the above purpose.
Your payment data is not stored on PLGRND.
If you are a buyer and want to pick up a package purchased from a seller on our site, we collect the following data:
Name and surname
Postal code of delivery, in order to display the nearest Mondial Relay point
If you are a seller and you wish to sell a parcel the Mondial Relay Delivery Service proposed on our site, we collect your first and last name in order to display them on the parcel’s Delivery Note.
The data we collect through your use of our services
We record via cookies and other tracers usage data when you access our services (or use them in any way), which includes our Site and our Applications, notably when you perform a search, when you reply or post Advertisements, or when you use our Messaging service or Secure Payment Service. We also collect technical data about your internet connection, your browser and your devices.
We also plan to carry out, in particular, audience measurements, to measure for example the number of pages viewed, the number of visits to the Application or the Site, as well as the activity of visitors on the Application and their frequency of return.
In this case, we will use a service that meets the CNIL’s exemption conditions.
By accepting cookies for audience measurement, you will allow us, from indirectly identifying personal data, to obtain more complete statistical results allowing us to improve our service. If you refuse the cookies of audience measurement, you will be in “exempted status of consent”, implying the maintenance of a partial measurement of audience. In this case, the data collected will only be linked to an identifier generated specifically for our site used only to recognize your terminal.
You may object to the processing of personal data for this purpose by contacting us at firstname.lastname@example.org.
We also use this data to improve your experience, to provide you with a personalized experience on our Application according to your profile and to offer you personalized advertisements. To learn more about the purposes related to cookies, please see our Cookies Policy below.
We may receive personal data about you from our customers and partners (e.g., data aggregators).
Use of your data
We use your data for the following purposes:
Use of your data on the basis of the execution of the contract
Based on the performance of the contract between us, we use your data to provide our services to you, including:
- to ensure the publication of your Ad;
- to ensure the creation and management of your Account;
- to provide you with our integrated messaging service;
- sell and bill the paid options that you subscribe to;
- send you push notifications and emails regarding your use of our services;
- answer your customer support questions;
- allow you to make transactions via the Secure Payment Service;
- allow you to make deliveries via the Mondial Relay Delivery Service (in the future);
- allow you to share a listing/profile with a friend via email (in the future);
- allow you to share on social networks.
Use of your data on the basis of our legitimate interest
On the basis of our legitimate interest, we use your data to:
- perform marketing statistics and analysis, to understand how you use our services;
- automatically estimate, from your usage data of our services, the degree of interest of your search. This strictly indicative information may be communicated to the Pro Advertiser when you respond to its Ad and be used by it to improve its management of contact requests;
- provide you with personalized content and improve your user experience;
- send you advertisements that appear on our site that may be of interest to you, based on the advertisements you view or respond to,
- to send you as a User commercial and/or promotional proposals, emanating only from PLGRND and concerning exclusively the PLGRND service;
- carry out surveys (e.g. satisfaction, opinion…). You are free to participate and may object in the manner provided at the time of the survey.
- To fight against fraud, your account and payment data may be processed in an automated way, during your transactions and your sending of messages and, in case of anomalies detected, give rise to an automatic suspension of your transaction or to a blocking of the messages you send.
- For evidentiary purposes.
Use of your data with your consent
We may, with your consent :
- to allow you to be contacted by an Advertiser;
- allow you to search for ads around you based on your location data;
- personalize the advertisements that are displayed on our site, application or third party sites, in order to prevent you from being exposed to advertisements that are not relevant to you. We may personalize these with the following data, used in combination or individually:
- data from advertising technologies such as web beacons, pixels, ad tags, cookies and device identifiers;
- information you have provided to us;
- data obtained through the use of our service (frequency of visits, categories of ads visited, keywords entered…) and the connection identifiers and technical data referred to in the previous article;
- information from third parties (for example, advertising partners and data aggregators);
- information that we can deduce from the data described above.
- You may at any time set up and opt-out of personalized advertising by emailing us at email@example.com.
- to share your data with our advertising partners, data processors, for the purpose of improving the performance of our partners’ campaigns on our application. You can set up and refuse this data sharing at any time, by letting us know by email at firstname.lastname@example.org.
- to personalize the advertisements that are displayed on our site according to your immediate environment. You can set and refuse this personalization at any time by sending an email to email@example.com.
We do not share your personal data with our third-party partners without your consent. However, if you click on an advertisement, the advertiser may know that you have visited the page you clicked on.
We may also send you commercial and/or promotional offers from third parties, but only with your consent, which is obtained when you receive a message from PLGRND offering access to offers from these third-party companies. In this context, your data will not be transmitted to our partners. It will only be used to communicate their offers by email, redirecting you to their websites.
Your data will not be sold to any third party company by PLGRND.
Use of your data to meet our legal obligations
Finally, we may process your data in order to comply with our legal obligations.
Person in charge of the treatment
PLGRND, registered at the RCS of Bobigny under the number SIREN 533 960 860, having its head office at 50 rue Molière 93100 Montreuil, represented by Mr. Régis Boussari, in his capacity as manager, is responsible for the processing of the data it collects in the context of your use of PLGRND.
Recipient of the data
The data we collect is accessible to our service providers, acting as subcontractors, who contribute administratively and technically to the achievement of the purposes mentioned above (hosting provider, payment provider, advertising technology …)
In this context, the data we collect may be transferred outside the European Union. In this case, we ensure that this transfer is made to countries recognized as providing an adequate level of protection of your personal data or, at least, on the basis of appropriate guarantees provided by law.
In order to comply with our legal obligations, your personal data may also be transmitted to authorized administrative and judicial authorities, only upon judicial request.
Some service providers we use may collect data, with your consent, in their capacity as data controller. They are :
- our possible advertising providers (for the moment we do not use any)
- our payment service provider Stripe, which collects the “Know Your Customer” information mentioned above. The latter uses it to verify your identity, in accordance with the regulations aimed at fighting money laundering and the financing of terrorism.
- our hosting platform Adalo, a subsidiary of Apto Labs, Inc.
Finally, when you respond to an Ad, your contact information is transmitted to the relevant Seller, as the data controller, who originated the Ad. In the case of a Pro Seller, we may also transmit your search criteria that enabled you to consult the Ad, your average response time to messages sent to you, and the degree of interest in your search for information purposes.
Indeed, any Pro Seller placing an ad on PLGRND is responsible for the processing of all personal data that it may receive from PLGRND users.
As such, he commits himself to respect the legal and regulatory provisions in force concerning the personal data of the users that he would collect. In particular, he commits to implement all technical means to maintain the integrity, security, confidentiality of personal data as well as to guarantee the security of access to the storage systems of these personal data.
The Seller Pro is informed of its obligations as a data controller, and in particular the respect of the rights of the users and in particular, their right of access, opposition and correction of the information concerning them. If users wish to exercise their rights, they must contact the advertiser concerned directly.
The Pro Seller is liable for any breach of these obligations and shall indemnify and hold harmless PLGRND and its service providers (including court costs and attorneys’ fees) from any action, claim or demand brought by any authority or third party arising out of any breach by the Advertiser of this section.
Length of retention
The length of time we keep your personal data varies according to the purpose of their collection:
- Account data (identity, electronic contact information, history of use of services) are kept for 3 years from the end of the commercial relationship;
- The data related to the management of your Account and your Ads are kept for a period of 5 years from their deletion and this, exclusively for evidential purposes;
- The documents and accounting vouchers are kept for 10 years, as accounting proof;
- Your credit card data is kept by our payment service provider until full payment has been made and, as evidence in the event of a claim, for 13 months, or 15 months in the case of a deferred payment card. For One-ClickPayment, credit card information is retained until your card expires or you delete it from your Account;
- Emails collected for ad and profile sharing are deleted as soon as the email is sent to the designated recipient;
- Data that may be subject to a judicial requisition (connection data, identity, contact details, transaction data) are kept for 12 months from the date of their collection;
- The data stored when you perform a “search around you” are kept only for the time of this search;
- Telephone conversations with our professional customer support may be retained for 6 months.
What are your rights?
Right of access: this is your right to obtain confirmation as to whether or not your data is being processed, and if so, to access this data.
Right of rectification: this is your right to obtain, as soon as possible, that your inaccurate data be rectified, and that your incomplete data be completed. You can also, at any time, modify the personal data of your Personal Profile and/or Professional Profile. Simply go to your Personal Profile and/or Business Profile and click on the “Settings” icon.
Right of deletion: this is your right to obtain, as soon as possible, the deletion of your data, subject to our legal obligations of conservation.
Right of limitation: this is your right to obtain the limitation of the processing when you object to it, when you dispute the accuracy of your data, when you believe that their processing is unlawful, or when you need them for the establishment, exercise or defense of your legal rights.
Right to object: this is your right to object at any time to the processing of your data by PLGRND, except in the case of legitimate and compelling reasons of PLGRND. You can also object to the processing made for canvassing purposes.
Right to portability: this is your right to receive your data in a structured, commonly used, machine-readable and interoperable format, and to transmit it to another controller without our interference.
Right not to be subject to a decision based on automated processing: you have the right not to be subject to a decision based exclusively on automated processing that produces legal effects concerning or affecting you, except where such a decision is necessary for the conclusion or performance of a contract, or is legally authorized.
Complaints: you have the right to lodge a complaint with a supervisory authority.
Instructions in case of death: you have the right to give instructions for the fate of your personal data in case of death.
How to exercise your rights?
If you are an individual, you can exercise your rights of access, rectification, deletion and portability via your Profile in the “Settings” section.
If you wish to exercise your right to object :
- to the processing of personal data for the purpose of audience measurement on our platform or,
- to the processing of personal data in order to measure the effectiveness of promotional campaigns, please contact our customer service at firstname.lastname@example.org.
To exercise your other rights, please also contact our customer support at email@example.com.
If you are a professional, the exercise of your rights must be done by contacting our customer support, either by phone.
IMPORTANT: In the event that a Transaction is initiated by you or your contact via our Secure Payment Service, deletion of your account will be suspended until your transaction is completed.
Security of your data
We protect your information using electronic and administrative security measures. Our safeguards include firewalls, and authorization controls for access to information.
What is a cookie?
A cookie is a text file stored on the hard drive of your computer, tablet or mobile device by your browser when you visit an online service.
Cookies stored by us or by third parties when you visit our Site or Applications do not recognize you personally as an individual, but only recognize the device you are using. Cookies do not store any sensitive or directly identifiable personal data but simply provide information about your browsing experience so that your device can be recognized later.
Cookies do not cause any damage to your device, but make it easier for us to find your preferences, pre-fill certain fields and adapt the content of our services.
Only you choose whether you want to have cookies saved on your device and you can easily control the saving of cookies. For specific information on managing and controlling cookies, please refer to the “Your Choices About Cookies” section. The word “cookies” in this policy refers to any trackers that may be used as part of our Service, including those used in our Applications.
Cookies used by PLGRND
Cookies necessary for the operation of the service
The cookies necessary for the operation of the service that we issue allow us in particular:
- to identify you when you connect to our Site or our Applications and to secure your connection,
- to adapt the presentation of our Site, Applications and advertising spaces to the display preferences of your terminal (language used, display resolution, operating system used, etc.), according to the hardware and software for viewing or reading that your terminal has,
- to keep your choice concerning cookies.
Audience measurement cookies
The audience measurement cookies that we deposit allow us to analyze the use of our Site and Applications and to improve our user experience by establishing statistics and volumes of traffic and use (sections and content visited, path…).
To do this, we use the audience measurement tools of our following service providers, which meet the conditions of exemption from consent of the CNIL:
- (not defined yet)
User Experience Enhancement Cookies
These cookies allow you to benefit from a better experience on our Site or our Applications by taking advantage of generic improvements that are not linked to your profile or to test them. For example, they allow us to store your contact information to pre-fill a form.
Service personalization cookies
These cookies allow you to benefit from a personalized experience on our Site or our Applications according to your navigation, your centers of interest and your uses of our service. They allow us to offer or test content, communications, offers and/or features that are best suited to your profile.
We allow you to benefit from:
- Content adapted to your profile, in order for example to improve the relevance of your search results, to recommend other advertisements likely to interest you, to offer you features adapted to your profile on our Site or our Applications,
- Personalized promotional offers based on your profile,
- Personalized marketing communications, for example when you receive our emails.
Personalized advertising cookies
Personalized advertising cookies are also used:
- to limit the number of times you see an ad and to help measure the effectiveness of an ad campaign
- to allow us to know whether a user who has seen an advertisement has subsequently visited the advertiser’s site and performed an action (e.g., signed up for a newsletter)
The lifetime of our targeted advertising cookies is 60 days.
Cookies from our partners
Cookies may, in the future, be deposited on your browser, with your consent, by our partners acting as data processors. This is known as a third-party cookie. This may be the case for the display of certain personalized advertisements. PLGRND does not manage the cookies of these partner companies and has no control over or responsibility for these cookies and the use of the data collected through them. In this regard, we advise you to consult the partner’s own policies related to cookies.
You can consult the list of these partners and control the deposit of their cookies on your browser (coming soon).
Your choices regarding cookies
You can at any time express or modify your wishes regarding cookies by the means described below:
Settings for your browser and mobile devices
You can configure your browser at any time to store cookies on your device (opt-in) or to reject them (opt-out). Some browsers allow you to set rules to manage cookies on a site-by-site basis.
Each browser has a different configuration for managing cookies. It is described in the help menu of your browser, which will allow you to know how to modify your wishes:
In addition, the procedure for disabling ad targeting on your mobile devices is as follows:
- on iOS, go to the privacy settings, access the “advertising” option and enable “limited ad tracking”
- on Android, go to the “Google settings” app, enable the “disable ads by interest” and “reset ad ID” option.
You can also set your mobile device’s geolocation options and which apps, including PLGRND, have access to them:
- on iOS, go to the privacy settings, access the “Location Service” option and set the apps that can access your location data;
- on Android, go to your phone’s “Settings” and then to “Applications”. Select “PLGRND” and then “Permissions”. There you will find a list of all the permissions we may ask you for, including the one called “Location”, which you can enable or disable. To simplify this access, we have set up a shortcut in our PLGRND application: go to “Practical Info”, then “Help”, then “Permissions” and press the “Access Settings” button.
Other useful resources
To learn more about targeted advertising and the choices you have in this area, you can consult the resources below:
- European Interactive Digital Advertising Alliance
- Internet Advertising Bureau France
- Network Advertising Initiative
We also invite you to contact us with any questions or requests regarding cookies placed on our site and/or targeted advertising at firstname.lastname@example.org.
Data Protection Officer
(to be defined)
We also invite you to contact us with any questions or requests regarding this policy at email@example.com