PRIVACY & GDPR COMPLIANCE

PREAMBLE

This policy describes how personal data is processed when using the experimental classified ads platform Commercify Beta, published by STÉPHANE DELAMORTE as part of the DreamprojectAI project.

It supplements the Terms of Use, which govern access to the Platform, each party's liability and free access during the beta phase. Open the Terms of Use

ARTICLE 1 - NATURE OF THE SERVICE

1.1 THE SERVICE

Commercify Beta is an experimental classified ads platform, open to private individuals and professionals. It is free during the beta phase, under the conditions of the Terms of Use.

The Administrator acts as host of the content published by users, with no general obligation to monitor that content.

1.2 RELATIONSHIP WITH USERS

Use of the Platform is governed by the Terms of Use, accepted by the user. This policy deals only with personal data.

1.3 EXPERIMENTAL NATURE

The Platform is experimental: its features and the resulting processing may change. Any substantial change is announced in accordance with article 10.

ARTICLE 2 - DATA PROCESSED AND PURPOSES

2.1 DATA COLLECTED

• Account data :
  • Pseudonym or identifier chosen by the user
  • Contact e-mail address
  • Declared country of residence
  • Language, currency and display preferences
  • Badge held and associated publisher accounts
• Published content :
  • Ads, images and videos
  • Banners
  • Comments, ratings and reports
  • Messages exchanged through the Platform's tools and requests sent to support
• Technical data :
  • Connection and browsing logs: IP address, date and time, page requested and referring page, browser and operating system, browser language, session identifier and, for a logged-in user, badge and publisher account identifiers
  • Platform operating data
  • Anonymized usage statistics
  • Technical security data: attempt counters per IP address, checks on the IP address and browser associated with the session

2.2 PURPOSES

• Providing the service: accounts, badges, publishing and viewing ads
• Personalising browsing: HyperProfil and display preferences
• Moderating content and handling reports
• Ensuring the security of the Platform and preventing fraud and malicious use
• Improving the operation of the Platform on the basis of usage statistics
• Complying with legal obligations, in particular the retention of connection data
• Informing people who have signed up to the information list

2.3 CONTENT PUBLISHED BY USERS

Published content remains the sole responsibility of its authors. The Administrator exercises no prior editorial control and acts as host.

Published content is visible to everyone. Users take care not to include personal data they do not wish to make public, or that of a third party without that person's consent.

A user who collects personal data from other users in the course of their exchanges processes it under their sole responsibility, in compliance with the laws that apply to them.

2.4 BANNERS PUBLISHED BY PUBLISHERS

A banner's files (image, video) are hosted by the Platform and attached to the publisher account that publishes them. As an exception to paragraph 2.3, each banner is checked before it is shown.

A banner and its files are kept for as long as the publisher account exists, including after expiry or withdrawal, so that the publisher can put it back online. The publisher may request their deletion under article 5.

A banner may contain a link to a third-party site chosen by the publisher. The Platform passes no visitor data to that site; the third-party site applies its own privacy policy.

The visitor's choice to show banners or not is an interface preference. It is not used for any advertising profiling.

ARTICLE 3 - LEGAL BASES

3.1 GROUNDS FOR PROCESSING

• Performance of the Terms of Use: accounts, badges, publishing, moderation.
• Legitimate interest: security of the Platform, fraud prevention, improvement of the service. A balancing of interests is carried out and documented.
• Consent: where it is required, in particular for signing up to the information list.
• Legal obligations: retention of connection data and the host's obligations.

3.2 WITHDRAWAL OF CONSENT

Where processing is based on consent, it may be withdrawn at any time, for the future, through the unsubscribe link or in the support area.

ARTICLE 4 - RETENTION AND SECURITY

4.1 SHELF LIFE

• Account data: for the life of the account, then three years
• Connection logs: twelve months, in accordance with legal obligations
• Logs older than twelve months: made anonymous (IP address, browser, session, badge and account identifiers erased), then kept without time limit for statistical and technical purposes
• Logs linked to a report, a fraud, a sanction or a dispute: kept as they are until the procedure ends, and for five years at most
• Published content: for as long as it is online or kept in the user's space; it is deleted with the account, unless the law requires it to be kept
• Documents provided for a check: the time strictly necessary for that check
• Information list: until unsubscription

4.2 SECURITY MEASURES

The Administrator implements technical and organisational security measures appropriate to a service of this kind, in particular the encryption of sensitive data and the securing of access.

No system is infallible. In the event of a data breach presenting a risk to individuals, they and the supervisory authority are informed under the conditions laid down by law.

4.3 TECHNICAL OUTSOURCING

The use of hosting and technical service providers is carried out by entities complying with european data protection standards and subject to strict contractual obligations.

ARTICLE 5 - INDIVIDUAL RIGHTS AND HOW TO EXERCISE THEM

5.1 RECOGNIZED RIGHTS

Every individual has, over the data concerning them, the rights provided for by the GDPR: access, rectification, erasure, restriction, objection, portability and withdrawal of consent.

5.2 EXERCISE PROCEDURE

Requests are made in the support area www.support.dreamproject.online. Proof of identity may be requested where there is reasonable doubt as to the identity of the person making the request.

5.3 RESPONSE TIMES

The Administrator replies within one month, which may be extended by two months depending on the complexity of the request. A manifestly abusive or repetitive request may be refused with reasons.

5.4 LIMITS LAID DOWN BY LAW

The exercise of a right may be limited only in the cases provided for by law, in particular to comply with a legal retention obligation or for the establishment, exercise or defence of legal claims.

ARTICLE 6 - DATA ACCESS AND MODERATION

6.1 PRINCIPLE OF NON-INTERVENTION

The administrator does not access users' private data in the normal operation of the platform, and does not systematically monitor content.

6.2 EXCEPTIONAL, STRICTLY SUPERVISED INTERVENTIONS

Access to data is only possible in the following cases:

• Reporting illicit or inappropriate content
• Technical maintenance or safety requirements
• Legal obligations or court orders
• Preventing malicious use of the platform

6.3 PROCEDURAL GUARANTEES

Any intervention respects the principles of proportionality, necessity and purpose. Access is granted for the time strictly required to achieve the objective pursued.

6.4 AUTOMATED MODERATION

Part of the moderation relies on automated processes. Their decisions can be contested under the procedure of the Terms of Use (article 6).

ARTICLE 7 - COOKIES AND TRACKING TECHNOLOGIES

7.1 COOKIES USED

The Platform uses a session cookie necessary for its operation and stores the user's display and HyperProfil preferences.

It may use audience measurement cookies to improve the service. Where a cookie requires consent, that consent is requested before the cookie is set.

7.2 MANAGEMENT AND OPPOSITION

Cookies necessary for operation do not require consent. Users can set their browser to block them; the Platform may then no longer work properly.

ARTICLE 8 - DATA SHARING AND TRANSMISSION

8.1 PRINCIPLE

Personal data is neither sold nor transferred to third parties. It is passed on only in the cases provided for by law or by this policy.

8.2 TECHNICAL SERVICE PROVIDERS

Certain data may be processed by hosting and technical service providers acting exclusively on behalf of the administrator under a subcontracting agreement that complies with the RGPD.

8.3 AUTHORITIES

Data may be disclosed to judicial, tax or administrative authorities where required by law.

8.4 TRANSFER OF THE PLATFORM

If the Platform is transferred, personal data may be passed on to the acquirer, subject to equivalent safeguards and prior information of the individuals concerned.

ARTICLE 9 - LIABILITY

The Administrator's role as host, the limits of the Administrator's liability and users' obligations are set out in the Terms of Use (articles 5, 7 and 8). This policy neither adds to nor takes away from them. Open the Terms of Use

Nothing in these documents limits the rights the GDPR grants individuals over their data.

ARTICLE 10 - CHANGES TO THE POLICY

The Administrator may amend this policy. Any substantial amendment is announced on the Platform at least fifteen days before it takes effect, unless it is required by law or by the security of the Platform.

Where an amendment requires the consent of individuals, they are asked for it.

ARTICLE 11 - CONTACT AND COMPLAINTS

11.1 POINT OF CONTACT

Any request relating to personal data is made in the support area www.support.dreamproject.online or, failing that, by e-mail to dreamproject-ai@proton.me.

11.2 DATA PROTECTION OFFICER

No data protection officer has been appointed, as the law does not require one in view of the nature and volume of the processing.

11.3 COMPLAINT TO THE SUPERVISORY AUTHORITY

Any individual may lodge a complaint with the French data protection authority (CNIL) or with the data protection authority of their country of residence.

ARTICLE 12 - GOVERNING LAW AND JURISDICTION

This policy is governed by French law. The competent jurisdiction is set out in article 12.1 of the Terms of Use.

The French version of this policy is the authoritative one. Any translation is for information only.

ARTICLE 13 - FINAL PROVISIONS

13.1 SEVERABILITY

If any provision of this policy is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

13.2 RELATIONSHIP WITH THE TERMS OF USE

This policy supplements the Terms of Use. In the event of a contradiction regarding the processing of personal data, this policy prevails.