We are particularly concerned about the protection of our user’ personal data.
This policy concerns the bluekomune.org website and the platform to which it provides access.
Aware of the importance of clear and transparent information in this area, we have integrated various tables and visuals to help you better understand and exercise your rights.
This policy was last updated in September 2023.
1 – Who is responsible for processing your data?
The website accessible at bluekomune.org is edited and technically managed by Wafelcrop (hereinafter “Wafelcrop”), a simplified joint stock company registered under the number 917599581 and whose registered office is located at 31, rue Chevalier Paul in Toulon (83000).
When you browse this site and/or interact with Wafelcrop, personal data about you is collected and processed by Wafelcrop.
Wafelcrop is responsible for this collection and processing of your data, within the meaning of the General Data Protection Regulation (GDPR).
This means that we are your contact for any questions or concerns related to this collection or processing. You can write to us at email@example.com.
Note: Wafelcrop has appointed a Data Protection Officer (“DPO”). You can contact this DPO by email at the following address: firstname.lastname@example.org.
2 – What data is collected about you, and for what purposes?
2a – Connection to the bluekomune.org website (http request)
When you connect to the bluekomune.org site, a certain amount of data is automatically collected by the site host concerning your terminal (computer, smartphone, tablet) and your browser. This includes your IP address.
This data is collected to ensure the connection between your terminal and the site’s servers, and subsequently to detect bugs and attempted cyber attacks.
The collection and processing of this data is thus justified by Wafelcrop’s legitimate interest in providing a site and services that are functional, secure and adapted to the different types of terminals and browsers present on the market, in accordance with Article 6.1.f) of the RGPD.
2b – Email contacts
The site provides an address enabling you to contact Wafelcrop, in particular for the purposes of receiving information about our activities.
Data related to our written exchanges (which include the content of messages exchanged) are necessary for us to be able to understand and process your request, and to offer you a presentation of our activities where appropriate.
The collection and processing of this data is thus justified by Wafelcrop’s legitimate interest (Article 6.1.f) RGPD) consisting of promoting its activities and responding to commercial solicitations.
2c – Creating and managing a user account on the platform
The creation of your user account on the platform involves the provision of a certain amount of data on a mandatory basis (for example: your e-mail address and a password), and other data on an optional basis (for example: a description of your profile).
2d – Profiles created by Wafelcrop (“Listed” profiles)
Wafelcrop may create profiles of individuals and organizations that it deems relevant to the purpose of the platform, namely ocean protection.
These profiles appear clearly as “Listed” on the platform, so as to distinguish them from those of users actually registered on the platform. Wafelcrop will inform individuals of the creation of a “Listed” profile concerning them, using their email address whenever it is publicly available, or failing that, social networks.
Listed” profiles are created on the basis of information publicly available on institutional social networking sites and pages (e.g. the official website of the organization concerned). Pre-filling this information also simplifies the creation of your user account, if your profile has already been “listed” by Wafelcrop.
The creation of “Listed” accounts is justified by Wafelcrop’s legitimate interest (article 6.1.f) of the RGPD) consisting in publishing a directory of ocean protection players that is as complete and accurate as possible, using publicly available information.
Note: If you notice the existence of a “Listed” profile concerning you and you wish to have it deleted or modify some of the information it contains, you may, at your option, create a user account to manage the information on this profile yourself, or exercise your rights of rectification and/or opposition described below in this policy.
2e – Invitations to join the platform (user-generated invitations)
Users can send invitations to people whose email addresses they know, using the platform’s dedicated features.
When using these features, Wafelcrop collects and processes, on the one hand, data relating to the sender of the invitation (user account, invitation message written by the user, etc.), and, on the other hand, data relating to the recipient of the invitation (email address).
The sending of invitations is justified by Wafelcrop’s legitimate interest (article 6.1.f) of the RGPD) in promoting its platform to a professional audience considered likely to be interested by existing users.
Note: If you have received an invitation and would like Wafelcrop to delete the information it holds about you (including in particular the email address provided by the user who sent the invitation), you can exercise your right to erasure described below in this policy.
2f – Instant messaging
The platform contains an instant messaging function between users.
When a user uses this feature, Wafelcrop collects and processes metadata (user account ID, date and time of sending and receiving) and the content of messages sent and received, for the purposes of proper message routing.
2g – Managing relations with our customers, prospects and partners
In the course of our relations with our users, prospects and partners, we may collect personal data relating to our contacts.
This data mainly includes the surname, first name, e-mail address, postal address and telephone number of said contacts, as well as copies of all written correspondence with them.
This data is necessary to ensure the proper management and follow-up of these relationships. Their collection and processing are thus based on Wafelcrop’s legitimate interest (Article 6.1.f) of the RGPD), consisting of ensuring the promotion of its activities, as well as the monitoring of its exchanges with its partners.
2h – Moderation, sanctions and management of claims and disputes
This data processing is justified by Wafelcrop’s legitimate interest (Article 6.1.f) of the RGPD) consisting of ensuring the lawfulness and quietude of content and exchanges on the platform, and defending its rights and interests if necessary in court.
3 – Who has access to your data? With whom is it shared?
Your data is hosted by various professional service providers we use (website hosting, hosting of our professional messaging, drive services). Wafelcrop’s teams and employees may have access to this data within the scope and limits of their duties.
Some of your data may also be hosted or at least consulted by the following people and organizations:
- Technical service providers assisting Wafelcrop with site maintenance and development;
- Wafelcrop’s legal advisors.
Where one of these service providers or counsel is located and/or hosts the data in a country that is not a member of the European Economic Area and does not have an adequacy decision from the European Commission, we ensure that appropriate safeguards, in accordance with Articles 44 et seq. of the RGPD, are implemented to ensure the protection of your data in the country in question.
Finally, please note that other users of the platform are, by assumption, likely to consult your personal data that appears there. If you wish to have your personal data removed from the platform, please refer to the following section, which describes your rights to do so.
4 – How long is the data kept?
Data linked to your user account will be kept in principle until it is deleted, and then if necessary for an additional period equal, at most, to the relevant limitation period (as defined by applicable laws and regulations), for the purposes of preventing and managing any disputes.
In addition :
- Data relating to unclaimed “Listed” profiles are kept until the person concerned exercises, where applicable, his or her right to object;
- Data relating to individuals who have received an invitation to join the platform (including their e-mail address) are kept for a maximum of 6 months following the sending of the corresponding invitation;
- Data relating to individuals who are not users of the platform but with whom Wafelcrop may have exchanges (for example, for the purposes of promoting its activities) is kept for the duration of the relationship with the person concerned, and then for a maximum of 3 years from the last exchange.
5 – What rights do you have to control the processing of your own data?
You have a number of rights provided for by law. These are detailed below. A summary table is also provided below.
You can exercise these rights simply by writing directly to the following e-mail address: email@example.com.
Please be sure to indicate in your e-mail the nature of the right you wish to exercise and the reasons that justify your request.
5a – Right of access
You have the right to ask us for a copy of the personal data we hold about you, in an easily understandable format, as well as a copy of this policy on a durable medium.
5b – Right of rectification
You have the right to ask us to correct, complete or update the data we hold concerning you, should it appear to you to be inaccurate, incomplete or obsolete.
In this case, we would be grateful if you would, as far as possible, voluntarily provide us with the new information required to make the requested correction, completion or update.
5c – Right to object
With regard to the processing of your data based on Wafelcrop’s legitimate interests (see above), you have the right to object on grounds relating to your particular situation. In other words, you may ask Wafelcrop to stop processing your data in one or more of these ways, stating the particular reasons that justify this request from your point of view.
However, Wafelcrop may refuse to comply with your request if further processing is necessary for compelling reasons from our point of view (for example, if the data concerned is necessary for the protection and defense of Wafelcrop’s rights in a court of law.
Objection (if based on valid grounds and if there are no compelling reasons against it) will lead to the cessation of processing for the future, but not necessarily to the destruction of the data concerned: to obtain such destruction you must exercise your right to erasure under the conditions described below, it being specified that the latter is subject to limitations arising, for example, again, from the need to retain the data for the protection and defense of Wafelcrop’s interests in court.
5d – Right to erasure
You may ask us to delete all or part of the data we hold about you, provided that at least one of the following conditions is met:
- You have objected to the further processing of your data in accordance with point 3 above, and would like Wafelcrop to destroy the data concerned.
- The data concerned no longer appears necessary for any of the purposes set out above.
- You consider that Wafelcrop has collected and/or processed the data concerned in a manner contrary to the law.
- The deletion of the data concerned is required by law.
- The data concerned relates to a person who was less than fifteen (15) years old when the data was collected.
Please note, however, that Wafelcrop has the right to object to the deletion of certain data when their retention is necessary for particularly important reasons, such as the protection and defense of its interests in court.
You should also be aware that we may choose to completely and irreversibly anonymize your data instead of deleting it. In this way, we will be entitled to retain the data in a format that no longer allows you to be identified (e.g. for statistical purposes).
5e – Right to restrict processing
For example, if you are unable to exercise your right to erasure, you may also ask Wafelcrop to “set aside” certain data concerning you, i.e. to store this data separately, without using it any further (unless we are legally obliged to do so).
You can make such a request if at least one of the following conditions is met:
- The data concerned seems inaccurate to you, and you would prefer Wafelcrop to stop using it for the time needed to check and rectify it if necessary.
- You have exercised your right to object in accordance with point c. above, and you would prefer Wafelcrop to stop using the data concerned for the time necessary to check that your objection is well-founded.
- You consider that Wafelcrop has collected and/or processed the data concerned in a manner contrary to the law, but nevertheless prefer that we retain the data rather than delete it.
- The data concerned is no longer required for any of the purposes set out above, but you would still like Wafelcrop to retain it for the purposes of defending your legal interests.
In such cases, we will “quarantine” the data for as long as necessary, for example by marking it “Do not use – Right to restriction”.
5f – Right to data portability
You can ask us to send you a copy of the data linked to your user account. This data will be provided to you in a standard computer format, enabling it to be reused by you or another service provider.
This “right to portability” differs from the right of access in that its purpose is not to obtain a copy that can necessarily be read by you, but rather a copy of the data that can be reused, in particular with a view to a change of service provider.
5g – The right to define instructions concerning the fate of your data after your death
Finally, you have the right to tell us how you would like us to deal with your data in the unfortunate event of your death.
In particular, you can ask us to destroy all your data (subject to any overriding conservation requirements we may have, for example to defend Wafelcrop’s rights in court), or to pass on a copy of all your data to a person of your choice.
You may also designate any person of your choice to be responsible for carrying out these “last wishes”; this person does not necessarily have to be one of your heirs or even the executor in charge of your estate.
you consider that we have not responded satisfactorily to your request, or that we are processing your data unlawfully?
We invite you to contact Wafelcrop first, so that we can discuss your request together and try to resolve it as best we can.
If you wish, however, you have the right to contact the competent data protection authority in France, i.e. the Commission Nationale de l’Informatique et des Libertés (CNIL), via its website cnil.fr or by post at the following address: CNIL – 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.
This right may be exercised at any time and does not incur any costs for you, apart from the cost of sending postal mail where applicable, and any costs of assistance or representation if you choose to be assisted in this procedure by a third party.