Confidentiality policy

PREAMBLE

This Confidentiality Policy applies to you, as user of the SQUARLY® web PLATFORM (Hereinafter the “PLATFORM”) and its objective is to inform you of the way in which your personal data may be collected and processed by WASTE2TRADE, where applicable.

 

WASTE2TRADE, a simplified joint stock company, with share capital of EUR 25,000, registered on the Nantes Register of Trade and Commerce under number 839 315 934, with its registered office at 2 bis, rue Robert le Ricolais – CS 60414 – 44300 Nantes Cedex 3, represented by its legal representative, duly authorised for the purpose hereof (hereinafter the “OPERATOR”), publishes and operates the web platform accessible at the following address: www.squarlymarket.com

The OPERATOR publishes and operates the PLATFORM which offers an online business intermediation service, through which resources vendors (hereinafter “the VENDORS”) can be put in contact with business buyers (hereinafter “the BUYERS”).

Respect for your privacy and your personal data is a priority for WASTE2TRADE. The objective of this Confidentiality Policy is to explain how personal data is processed on the PLATFORM.

WASTE2TRADE undertakes in all cases to comply with the following two (2) main principles:

  • You remain in charge of your personal data;
  • Your data is processed in a transparent, confidential and secure manner.

The processing of personal data is governed:

  • By the Data Protection Act No. 78-17 of 6 January 1978 (hereinafter “the DPA”);
  • By (EU) Regulation 2016/679 of the European Parliament and Council of 27 April 2016, which came into force on 25 May 2018 (hereinafter “GDPR”)

        ARTICLE 1. DEFINITIONS

The terms stated below shall have the following meaning within this Confidentiality Policy:

  • “BUYER”: shall mean any legal entity (paper manufacturers, plastics producers, recyclers, metallurgists, dealers) accessing the PLATFORM and proceeding, for business purposes, with the purchase of RESOURCES offered by a VENDOR.
  •  “ACCOUNT”: shall mean the interface hosted on the PLATFORM in which all the data provided by the BUYER or by the VENDOR is aggregated.
  • “JOINT DATA CONTROLLER”: shall mean cases where several entities are responsible for the processing of the personal data collected on the PLATFORM and who together determine the means and purpose of the processing.
  • “LOGINS”: shall mean the email and password enabling access to the ACCOUNT. These LOGINS are for the exclusive use of the BUYER or VENDOR who alone is responsible for same.
  • “RESOURCE OFFERING”: shall mean the announcement of the presentation of RESOURCES containing all the information which should be brought to the attention of the BUYER, by which the VENDOR offers its RESOURCES for sale. This offer does not contain the VENDOR’s details, but only its Department.
  • “PLATFORM”: shall mean the SQUARLY web PLATFORM accessible at the address www.squarlymarket.com. The PLATFORM consolidates all the web pages, IT information, SERVICES and functionalities offered to the USERS.
  • “DATA CONTROLLER”: shall mean the entity which, alone or jointly with another, determines the means and purposes of the processing of personal data
  • “RESOURCE”: shall mean any recyclable material offered for sale by the VENDORS via the PLATFORM. Only the following shall be considered as resources:
    • paper and cardboard boxes,
    • plastics,
    • ferrous and non-ferrous metals.
  • “SERVICES”: shall mean all the SERVICES provided by the OPERATOR at the same time as the provision of the PLATFORM, of which the MARKETPLACE SERVICE forms part.
  • “MARKETPLACE SERVICE”: shall mean the service consisting of providing VENDORS and BUYERS with the PLATFORM and a dedicated BACK OFFICE. The BACK OFFICE enables VENDORS to sell their RESOURCES to the BUYERS by configuring their RESOURCES OFFERINGS with a view to being put in contact with BUYERS using the bidding system. The BACK OFFICE enables BUYERS to accurately monitor orders placed for RESOURCES.
  • “SUB-CONTRACTOR”: shall mean the entity processing the personal data on behalf of the DATA CONTROLLER, which is acting under the authority of the DATA CONTROLLER and on their instructions.
  • “USER”: shall mean any person who accesses and browses the PLATFORM, which may be a VENDOR, BUYER or simply a web-user.
  • “VENDOR”: shall mean any legal entity (local authority, medium and large-scale retailers, food or non-food, industrialist, recycler and dealer) listed on the PLATFORM and buying the RESOURCES for BUYERS professionally. Only the entity having made the administrative declarations enabling it to lawfully sell its RESOURCES shall be considered as a VENDOR.

        ARTICLE 2. CNIL FORMALITIES

The processing of your personal data is recorded and these records are then included in the OPERATOR’s processing register.

        ARTICLE 3. PURPOSE OF THE PROCESSING

Different data about you may be collected by the OPERATOR in order to ensure:

  • The correct operation and continuous improvement of the PLATFORM, its service and its functionality;
  • The provision of the SERVICES;
  • The sending of alerts to USERS who request such
  • The ability for VENDORS to offer their RESOURCES for sale via the PLATFORM;
  • The ability for BUYERS to purchase the RESOURCES, directly from the VENDORS via the PLATFORM’s bidding system;
  • The management of requests for right of access, rectification and objection.

These purposes are detailed within Articles 4, 5 and 6 in this Confidentiality Policy.

The OPERATOR shall also be allowed to use this data with the objective of fulfilling a statutory or regulatory obligation.

In all cases, and for each defined purpose, the OPERATOR shall use all the means available to them to ensure the security and confidentiality of the personal data entrusted to them, in compliance with the current laws and regulations.

        ARTICLE 4. ACCESS TO THE PLATFORM, INTERMEDIATION and provision of SERVICES

                  4.1    Identity of the Data Controller

In respect of the provision of the PLATFORM, the intermediation with VENDORS and the provision of the SERVICES, the OPERATOR must be considered as a Data Controller.

For further information :

If you have any questions relating to how your personal data is managed and used, you can contact us:

  • Either using the various forms and functionalities on our website www.squarlymarket.com, and specifically via the contact form.
  • Or by email, to contact@squarlymarket.com
  • Or by letter, to WASTE2TRADE, address: 2bis rue Robert le Ricolais – CS 60414 –  44300 Nantes Cedex 3

Legal Notice: THE DATA CONTROLLER is, pursuant to the Data Protection Act, the entity which determines the means and purpose of the processing. When two or more data controllers jointly determine the purpose and means of the processing, they are the Joint Data Controllers (or Joint Controllers).

                  4.2    Collection and processing of personal data

As part of the operation of the PLATFORM, WASTE2TRADE may collect personal data about USERS of the PLATFORM. This data is processed in accordance with the purposes stated on collection.

In particular, WASTE2TRADE may collect personal data:

  • When you visit the PLATFORM;
  • When you order RESOURCES on the PLATFORM, including for the transportation of RESOURCES;
  • When you use the functions and/or SERVICES, including the MARKETPLACE SERVICE offered on the PLATFORM;
  • When you register, create and update your ACCOUNT;
  • The monitoring of bids for VENDORS and BUYERS respectively;
  • During exchanges with WASTE2TRADE via the PLATFORM;
  • When you request contact from WASTE2TRADE.

Furthermore, data relating to your browsing on our website may also be used to target your requirements and interests and to target our commercial and advertising offerings.

Whatever the method of collection, WASTE2TRADE undertakes to inform you of the purpose of the processing, the mandatory or optional nature of the responses to be provided, any consequences in this respect of failure to provide a response, the recipients of the data and the existence and terms of exercising your rights of access, rectification and objection to the processing of your data.

When necessary with regard to the Data Protection Act, WASTE2TRADE undertakes, as appropriate, to obtain your consent and/or give you the opportunity to object to the use of your data for certain purposes.

Further information and legal basis :

WASTE2TRADE undertakes in all cases to process all data collected in accordance with the amended Act No. 78-17 of 6 January 1978, which defines PERSONAL DATA as being: “any information relating to an identified physical individual or who may be identified, directly or indirectly, by reference to an identification number or to one or more details which are specific to him/her. To determine whether a person is identifiable, all the methods with a view to enabling his/her identification available to the Data Controller or any other person, or to which they may have access, should be considered.”

For further details about the management of cookies enabling us to achieve this purpose, please see our Cookies Management Charter:
https://squarlymarket.com/fr/cookies for the French version and
https://squarlymarket.com/en/cookies for the English version

                  4.3    Consent

As Data Controller, WASTE2TRADE has to obtain consent from USERS of the PLATFORM to collect and process their personal data.

In accordance with current provisions, the USER’s consent must be free, given for each designated purpose, clear and unequivocal. It is given by a declaration or by a positive action, which acts as agreement by the USER for the processing of the personal data.

In this case, any USER whose data has been collected for the above purposes has:

  • Given their consent on the creation of their ACCOUNT with a view to accessing the services offered on the PLATFORM.
  • Accepted the Cookies Management Charter by the corresponding cookies banner.

https://squarlymarket.com/fr/cookies for the French version and
https://squarlymarket.com/en/cookies for the English version


For further information :

When you open or manage your ACCOUNT on the PLATFORM, you fill in various forms and provide various personal data about you to benefit from all the services offered by W2T.

All the data concerning you is only collected directly from you, when you register, place orders, connect and during our various exchanges (online requests, letters, telephone calls, etc.).

Furthermore, data relating to your browsing on our PLATFORM may also be used to target your requirements and interests and to target our commercial and advertising offerings.

You will always be informed of the purposes for which your data has been collected by us via the various online data collection forms, your client account or via our Cookies Management Charter
https://squarlymarket.com/fr/cookies for the French version and
https://squarlymarket.com/en/cookies for the English version

Where necessary, WASTE2TRADE undertakes, as appropriate, to obtain your consent and/or to allow you to object to the use of your data for certain purposes, such as, for example, the ability to send you marketing information or to deposit third-party cookies on your terminals (mobile phone, computer, tablet) to be able to measure our site and our application audience and to offer you targeted commercial offers and advertising depending on your interests.

        ARTICLE 5. MANAGEMENT FOLLOW-UP OF THE COMMERCIAL TRANSACTION

                   5.1    Purpose of the processing carried out by the VENDOR

Your various data is collected to ensure:
-    The sale of RESOURCES at the end of the bidding;
-    The management of orders for RESOURCES;
-    The transportation of RESOURCES, it being understood that this will be the responsibility of the BUYER;
-    The management of its BUYER database (ACCOUNT management, loyalty programmes, commercial management, invoices, monitoring of the client relationship by the VENDOR;
-    Claims Management;
-    Management of bad debts and disputes.

                 5.2    Identity of the Data Controller

In respect of the above-mentioned purposes, the VENDOR shall be the Data Controller. The VENDOR will in fact need to collect and process the personal data of BUYERS on the PLATFORM to manage their orders for RESOURCES.

In this respect, the VENDOR guarantees to the OPERATOR that it processes this data in compliance with the rights and obligations resulting from the “Data Protection Act”.

The OPERATOR, which in operating the PLATFORM has defined jointly, with the VENDOR, the means and purposes of the processing associated with the sale of RESOURCES, shall have the capacity of joint controller, pursuant to Article 26 of the GDPR.

It is therefore expressly agreed between the PARTIES that the OPERATOR and the VENDOR as Joint Data Controllers, shall use all the means available to them to ensure the security and confidentiality of the personal data entrusted to them.


For further information :

For the management and follow-up of your contracts, orders, transportation and invoices    

The data which may be processed is as follows:

-    Data relating to your identity: title, surname, first names, address, telephone number, email addresses

-    Data relating to payment methods: bank details form,

-    Data relating to the transaction, such as the transaction number, details of the order for RESOURCES;

-    Data relating to the payment of invoices: payment terms, discounts granted, receipts, balances and unpaid amounts

-    Your connection logs,
For the management of our business relationship and client follow-up  

 -   Data relating to your identity: title, surname, first names, address, telephone number, email addresses

-    Data relating to following up the business relationship: bidding history, addresses of the processing site, RESOURCES order history;

-    Data required for loyalty campaigns

-    Data relating to your browsing on our website via cookies

                 5.3    Consent

The collection and processing of the BUYER’s personal data are needed for the sale and transportation of the RESOURCES. With regard to the fact that the BUYER has chosen to order a RESOURCE, the VENDOR and the OPERATOR do not need the BUYER’s consent, this being necessary for performance of the contract for the sale of the RESOURCES.

        ARTICLE 6. RECIPIENTS OF THE DATA

Only the people stated below shall have access to USERS’ data: 
-    The authorised staff from the different WASTE2TRADE departments (authorised staff from the marketing, sales, administration, logistics and IT departments, responsible for managing the client relationship and for prospecting and responsible for monitoring);
-    The companies responsible for managing the PLATFORM;
-    Our sub-contractors’ authorised staff (if there is a sub-contractor);
-    Where applicable, the courts in question, mediators, accountants, auditors, lawyers, bailiffs, debt collection companies,
-    The third parties likely to deposit cookies on your terminals (computers, tablets, mobile phones, etc.) when you consent to such (For further information, please see our Cookies Management Charter here
https://squarlymarket.com/fr/cookies for the French version and
https://squarlymarket.com/en/cookies for the English version

Your data will not be communicated, exchanged, sold or leased to anyone other than those stated above.

        ARTICLE 7. DURATION OF DATA RETENTION

WASTE2TRADE promises that the data collected will be retained in a form enabling you to be identified for a duration which does not exceed the duration required for the purposes for which such data was collected and processed.

However, the processing of data is possible to provide evidence of a right or a contract. This data may also be retained for the purpose of complying with a statutory obligation or kept in files in accordance with the applicable laws and regulations.

Exceptionally, the data identifying the BUYER and the VENDOR is retained by the OPERATOR for a period of three (3) years with effect from closure of the ACCOUNT, or the last contact with the BUYER, it being understood that this data is anonymised from the time of de-registration.

Finally, to ensure the correct operation and continuous improvement of the PLATFORM and its functionality, the raw usage data associated with a login is retained for a period of thirteen (13) months. After this time, it is deleted or anonymised.

WASTE2TRADE retains the BUYER’s personal data for a duration which does not exceed the time needed to achieve the purpose being pursued.

For further information:

For the management and follow-up of your contracts, orders, transportation and invoices    Your data is retained throughout the period of the contract.
Your data is stored for five (5) years for evidential purposes. Your invoices and accounting data is retained for a period of ten (10) years.

In the absence of an appropriate contract, your data is retained for a period of three (3) years, with effect from the day it is collected or the day of your last contact with us. It is understood that with effect from your de-registration, this data will be anonymised.
For data relating to bank details    In principle, your payment data is deleted once the transaction has been completed, and then archived/stored for a period of thirteen (13) months after the transaction date.
For marketing purposes    If you are a client: three (3) years with effect from the end of the business relationship, it being understood that from your de-registration, this data will be anonymised.
If you are not yet a client: three (3) years with effect from the last time you contacted us.
Your data will then be stored for a period of five (5) years, for evidential reasons, in accordance with current provisions (Insurance Code, the Mutual Companies Code, the Commercial Code, the Civil Code, the Consumer Code, the Homeland Security Code, etc.)

For your identity documents    1 year where you exercise your right to access or rectification
3 years where you exercise your right to objection
For audience measurement and statistics    6 months, then your data will be deleted or anonymised
To ensure the correct operation and continuous improvement of our PLATFORM    13 months, then your data will be deleted or anonymised.

        ARTICLE 8. YOUR RIGHTS

In accordance with the Data Protection Act and the GDPR, you have the following rights:

  • Right of access (Article 15 GDPR), rectification (Article 16 GDPR), update, completeness of your data (to find out more)
  • Right to blocking or deletion of your personal data (Article 17 GDPR), when it is incorrect, incomplete, equivocal, outdated or when the collection, use, communication or retention of such is prohibited (to find out more)
  • Right to withdraw your consent at any time (Article 13-2c GDPR)
  • Right to limit the processing of your data (Article 18 GDPR)
  • Right to object to the processing of your data (Article 21 GDPR) (to find out more)
  • Right to the portability of the data you have provided to us, when your data has been automatically processed based on your consent or on a contract (Article 20 GDPR)
  • Right to define the fate of your data after your death and to choose whether or not we communicate your data to a third party which you have appointed in advance (to find out more).

In the event of death and in the absence of instructions by you, we undertake to destroy your data, except where it is necessary to retain such data for evidential purposes or to comply with a statutory obligation.

These rights may be exercised by simple request by email to the address contact@squarlymarket.com or by sending a letter to WASTE2TRADE - address 2bis rue Robert le Ricolais – CS 60414 – 44300 Nantes Cedex 3, giving their details (surname, first name, address) and a legitimate reason when this is required by law (in particular in the case of objection to processing).

If you send us a copy of an ID document to prove your identity, we will keep it for one (1) year or three (3) years when it is sent in respect of the exercise of a right of objection.

To find out more about your rights, you can also see the Commission Nationale de l’Informatique et des Libertés [French Data Protection Agency] (CNIL) website, which can be accessed at the following address: http://cnil.fr.

        ARTICLE 9. CONNECTION DATA AND COOKIES

WASTE2TRADE uses connection data on its PLATFORM (date, time, website address, visitor’s computer’s protocol, page viewed) enabling us to identify you, to remember what you have viewed and to obtain the PLATFORM’s audience measurements and statistics, in particular relating to the pages viewed.

By browsing on the PLATFORM, you agree that WASTE2TRADE is installing this type of “technical” cookies, which have the sole purpose of enabling or facilitating electronic communication between your terminal device and our website, facilitating the management and browsing on same.

Our access to the information stored on your terminal device or the registration of information on the latter will only take place in the following cases:

-    To enable or facilitate electronic communication;
-    When this turns out to be necessary for the provision of our online communications service, at your express request.

As with the other data, you can exercise your right of access to this connection data, by emailing your request to contact@squarlymarket.com or by sending it by letter to WASTE2TRADE - address 2bis rue Robert le Ricolais – CS 60414 – 44300 Nantes Cedex 3.

If the browser permits such, you can de-activate these cookies at any time, by following the procedure indicated by this browser. However, WASTE2TRADE informs you that such de-activation may result in access to the PLATFORM being slowed down and/or disrupted.

Furthermore, WASTE2TRADE would like to inform you that it uses the services of Google Analytics to measure the PLATFORM’s audience. You can refuse monitoring of your browsing on the PLATFORM via the Google Analytics tool and by installing the Google Analytics Opt-out Browser add-on for your current Browser on the PLATFORM accessible at the following address: http://tools.google.com/dlpage/gaoptout?hl=fr.

To find out more about the type of cookies and other trackers used on the PLATFORM, the USER is invited to view the OPERATOR’s Cookies Charter, provided for this purpose and accessible at the following address
https://squarlymarket.com/fr/cookies for the French version and
https://squarlymarket.com/en/cookies for the English version

To find out more about cookies (how to manage them, delete them and identify them), please see the CNIL’s PLATFORM: http://www.cnil.fr/vos-droits/vos-traces/les-cookies/#c5554

        ARTICLE 10. DETAILS OF THE DATA PROTECTION REPRESENTATIVE

Our Data Protection representative is there to answer all your questions, including in respect of the exercise of the rights relating to your personal data.

You can contact him using this contact form available here, www.squarlymarket.com, by email to contact@squarlymarket.com, or by letter to WASTE2TRADE - address 2bis rue Robert le Ricolais – CS 60414 –  44300 Nantes Cedex 3.

        ARTICLE 11. SECURITY

WASTE2TRADE and any sub-contractors it uses undertake to implement any technical and organisational measures to ensure the security of our processing of personal data and the confidentiality of your data, in implementation of the Data Protection Act and the European General Data Protection Regulation (GDPR) and Law No. 2018-133 of 26 February 2018 “on various provisions to adapt European Union law in respect of security”.

In this respect, WASTE2TRADE takes the appropriate precautions, with regard to the nature of your data and the risks presented by our processing, to preserve the security of the data and, in particular, to prevent it being deformed, damaged or accessed by any unauthorised parties (physical protection of the premises, client authentication process with personal and secure access using confidential logins and passwords, logging of connections, encryption of certain data, etc.).

        ARTICLE 12. TRANSFERS OUTSIDE THE EU

The OPERATOR undertakes not to transfer the USER data outside the European Union.

Should the OPERATOR need to do this, it shall inform USERS thereof, giving details of the measures taken to monitor this transfer and to ensure compliance with the confidentiality of their data.