Politique de confidentialité du site web

Last updated: January 2023

 

SOURCEPOINT TECHNOLOGIES, INC. WEBSITE PRIVACY POLICY

1. Introduction

This website privacy policy (“Policy”) describes the processing of Personal Data by Sourcepoint Technologies, Inc. (“Sourcepoint”, “we”, “us”, “our”) in connection with the use of our website www.sourcepoint.com (“Website”). This Policy does not cover Personal Data that we process on behalf of our customers when you visit the websites or mobile applications of companies that use our consent management or anti ad block services. That information can be found in our Sourcepoint Services Privacy Notice

This Policy describes: 

  • Who we are (Section 2),
  • The types of Personal Data that we process and the purposes for which we process Personal Data (Section 3),
  • How we use Cookies on the Website (Section 4),
  • With whom we may share your Personal Data (Section 5),
  • Which security measures we have implemented (Section 6),
  • Further information for EU Users (Section 7)
  • Further information for Users in California and Virginia (Section 8)
  • How you can contact us (Section 9)

We may amend this Policy from time to time by uploading a replacement Policy to the Website. 

2. Who We Are

Sourcepoint Technologies, Inc. is a Delaware company. You can contact us by writing to our corporate mailing address in 228 Park Avenue South, #87903, New York, NY 10003-1502, United States or using our contact form under https://sourcepoint.com/connect-page/.

3. Processing Of Your Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person or that may be considered “personal data” or “personal information” under applicable privacy or data protection laws. This may include your name, address, email address, or phone number, but can also include IP address, browser type, or previously visited websites.

3.1 Types of Personal Data and Purpose for Processing 

In connection with your use of the Website, we process the following Personal Data:

Types Of Personal Data Why Processed (Purpose)
Information on your use of the Website that your browser automatically sends as a so-called “logfile” to our servers, such as your IP address, information on your device (computer or smartphone), browser, operating system, access time and the URL visited. To provide the Website to you, improve the Website and for IT security purposes.
Information on your use of the Websites that is tracked via cookies. See section 4 on cookies and the link provided there for details.
Information that you provide on our career page (Name, email, phone number, if you were referred by your current Sourcepoint employee) and Personal Data relating to your job application that you provide to us via the Websites or in a job interview. This may include your name, contact details, academic curriculum, professional qualifications, professional experience, date of birth, gender, photos and your LinkedIn profile, if you wish to include it in your application. Further, we process Personal Data in connection with the decision of your application. To evaluate your job application, to contact you regarding your current application and to include you in our talent pool for future vacancies.
Name, email address, job categories and preferred location To send you job alerts that match your skills.
Name, email address, country, company, the message provided by you in our general contact forms and if you would like to receive a quicker response. To respond to your inquiry.
Name, email address, country, company, the message provided by you and if you would like to receive a quicker response. To provide a demo of our services (such as Dialogue Consent Management Platform) to you.
  1. Your email address.
  2. Your IP address, time of sign up and that you clicked on the confirmation link in the confirmation email that we sent you.
  3. Your interactions with the newsletter, in particular, whether you opened our newsletter and which content you have clicked on.
  1. To regularly send you our email newsletter with information on our products as well as the latest privacy and media news.
  2. To document your consent to receive our newsletter.
  3. To optimize our newsletter.
Name, email address, company name and job title.
To identify you and serve targeted Sourcepoint advertisements to you on social media platforms.

 

3.2. Legal bases for processing and retention of Personal Data

In addition to the information provided in section 3.1 (“Processing Of Your Personal Data”), please find details on the legal bases for the processing your Personal Data (applicable for EU users) and on retention periods below:

Purpose Legal Basis For Processing (EU users) Retention period
To provide the Website to you, improve the Website and for IT security purposes. If the processing of the Personal Data is necessary to provide the Website to you, the legal basis is contractual necessity (Article 6 (1) (b) GDPR). Further, we process the Personal Data based on our legitimate interests (Article 6 (1) (f) GDPR) to provide a secure Website to you and improve our Website. We retain your data for the time required to ensure IT security, and, where applicable, as required or permitted by statutory law e.g. for financial statements, legal claims or archiving purposes.
Purposes related to cookies as explained in section 4. See section 4 on cookies and the link provided there for details. See section 4 on cookies and the link provided there for details.
To evaluate your job application and to contact you regarding your current application and to include you in our talent pool for future vacancies: Processing of this Personal Data to evaluate your job application is necessary in preparation of the performance of a contract between you and us in connection with a possible employment (Article 6 (1) (b) GDPR). We process your Personal Data  to include you in our talent pool for future vacancies only with your consent (Article 6 (1) (a) GDPR). You have the right to opt-out at any time. For more information on your rights, please see “Your Rights” section below. If your application is successful, we retain the Personal Data for the duration of your employment with us, and beyond, based on statutory retention periods. If we do not employ you, we will delete your Personal Data when accordant time limits for legal actions have lapsed, unless you consented to be included in our talent pool. If you wish to be included in our talent pool, we store your Personal Data for 3 years after you have consented.
To send you job alerts that match your skills If you subscribe to receiving job alerts via email from us, the processing is based on your consent (Article 6 (1) (a) GDPR).You have the right to opt-out from the job alerts at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our job alert emails. We will process this Personal Data until you opt out/withdraw your consent, and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes
To respond to your inquiry Processing of this Personal Data is necessary for the performance of a (quasi-) contract between you and us in connection with your inquiry (Article 6 (1) (b) GDPR). We retain this Personal Data for the time required to respond to your request and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
To provide a demo of our products and services  to you. Processing of this Personal Data is necessary for the performance of a (quasi-) contract between you and us to provide the demo to you (Article 6 (1) (b) GDPR). We retain this Personal Data for the time required to provide the demo of our services to you and, where applicable, as required or permitted by statutory law, e.g. for financial statements, legal claims or archiving purposes.
  1. To regularly send you our email newsletter with information on our products as well as the latest privacy and media news.
  2. To document your consent to receive our newsletter.
  3. To optimize our newsletter.
  1. If you subscribe to receive news via email from us, the processing of your Personal Data is based on your consent (Article 6 (1) (a) GDPR).If you are already a customer who has purchased products or services from us, we also process your email address to offer similar products or services to you that may be of interest to you. Such processing is based on our legitimate interests to conduct direct marketing (Article 6 (1) (f) GDPR). You have the right to opt-out from marketing at any time. For more information on your rights, please see “Your Rights” section below or the “unsubscribe” function in our marketing emails.
  2. Processing of this Personal Data is necessary for the performance of the contract between you and us to provide the newsletter to you (Article 6 (1) (b) GDPR).
  3. We only process your newsletter usage data with your consent (Art. 6 (1) (a) GDPR). You have the right to opt-out at any time. For more information on your rights, please see “Your Rights” section below.
We will process this Personal Data for as long as you show interest in our services and newsletters or until you opt out/withdraw your consent, and, where applicable, as required or permitted by statutory law e.g. for financial statements, legal claims or archiving purposes.

 

4. How We Use Cookies

The Website uses cookies and similar technologies, such as pixels or beacons (“Cookies”). These Cookies are used to make it easier for you to use the Website during future visits, authenticate you, remember your preferences, monitor and analyze traffic on our Website, personalize the content of the Website for you, measure ad and content performance, and create personalized content profiles. Please read more about the Cookies we use on the Website in our Cookie preferences, which is accessed in the GDPR Privacy Settings at the bottom of the page. You can always (when first visiting our Website and on every visit thereafter) accept or decline the use of the Cookies on our Website in the GDPR Privacy Settings by (1) clicking on “Accept All” or “Reject All buttons” or (2) moving the switch next to the Cookies to “on” or “off” and clicking on “Save & Exit”. You can also modify your Cookie choices in your browser settings. If you decline the use of Cookies, we may not be able to provide certain functionalities to you.

5. Recipients Of Your Personal Data 

5.1 Service providers

We share information with vendors who assist us with providing the Website, for example with hosting the Website, sending newsletters, storing data in clouds, website tracking (cookies and similar technologies), and processing your job applications.  In some cases, we authorize these vendors to collect data on our behalf. We have carefully selected these service providers and concluded data processing agreements with them, if required by applicable data protection laws.

5.2 Transfers to third parties

We may disclose your Personal Data:

  • To certain social media platforms to enable us to identify you and serve targeted Sourcepoint advertisements to you on such social media platforms. This may include your name, email address, company name and job title. 
  • If required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of us or our employees, or of other users of the Website. We process your Personal Data for these purposes either to comply with legal obligations or based on our legitimate interests in safeguarding us and others;
  • To potential purchasers or investors (and their advisers) on the sale of the whole or any related part of our business and/or assets. Depending on the transaction such transfers may be based on our legitimate interests to conclude the transaction or as disclosure is necessary for the performance of the contract between you and us. 

6. Security Measures

We employ security measures to protect your Personal Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

The transmission of information using Wi-Fi networks and cellular data networks may not be completely secure. Although we will use reasonable methods to protect your Personal Data, we cannot guarantee the security of data transmitted to us using the Website and any such transmission is made at your own risk.

7. Further information for EU Users

The following additional information and rights only apply to users who visit the Website from the EU/EEA.

7.1 Recipients outside the EU/EEA

Some of the recipients listed in section 5 may be located outside the European Union/the European Economic Area. In such cases, we use safeguard to establish an adequate data protection level in the third country, such as standard contractual clauses or binding corporate rules. You may ask to receive a copy of the safeguard by contacting us as described in the “Questions And Contact Details” section below.

7.2 Your Rights

You have the following rights in relation to the Personal Data we hold about you, given that the accordant preconditions are fulfilled:

  • Right of access:
    • If you ask us, we will confirm whether we are processing your Personal data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification:
    • If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will let them know about the rectification where possible.
  • Right to erasure:
    • You may ask us to delete or remove your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we have shared your Personal Data with others, we will let them know about the erasure where possible.
  • Right to restrict processing:
    • You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances such as where you contest the accuracy of that Personal Data or object to us processing it (but not continuing to store it). We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will let them know about the restriction where possible.
  • Right to data portability:
    • You have the right to obtain Personal Data you have provided to us, that we are processing based on your consent or because necessary to perform a contract with you, in a structured, commonly used and machine-readable format, and to reuse it elsewhere.
  • Right to object:
    • You may ask us at any time to stop processing your Personal Data, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your Personal Data, except if we can demonstrate compelling legal grounds for the; or processing your Personal Data for direct marketing.
  • Rights in relation to automated decision-making and profiling:
    • You have the right not to be subject to a decision when it is based solely on automated processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Right to withdraw consent:
    • If we rely on your consent as our legal basis for processing your Personal Data, you have the right to withdraw that consent at any time.
  • Right to lodge a complaint with the data protection authority:
    • If you have a concern about any aspect of our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by completing this form.

7.3 EU representative

Data subjects in the EU may also contact our office in Germany by writing to Sourcepoint GmbH, Friedrichstrasse. 68, 10117, Berlin, Germany.  

8. Further information for Users in California and Virginia

The following additional information and rights only apply to residents of California or Virginia who visit the Website.

8.1 Your Rights

Depending on where you reside, you may have the following rights in relation to the Personal Data we hold about you, given that the accordant preconditions are fulfilled:

  • Right of disclosure:
    • If you ask us, we will confirm (no more than twice in a 12-month period) what (if any) Personal Data about you that we collect, use, disclose, share or sell during the preceding year. You may request the following information:
      Specific pieces of Personal Data that we have collected about you;
      Categories of Personal Data that we’ve collected about you;
      Categories of sources from which we collected Personal Data about you;
      Categories of Personal Data that we sold or disclosed for a business purpose about you;
      Categories of third parties to whom Personal Data about you was sold or disclosed for a business purpose; and
      Our business or commercial purpose for collecting or selling Personal Data about you.
  • Right to correction:
    • If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it corrected or completed. If we have shared your Personal Data with others, we will let them know about the rectification where possible.
  • Right to deletion:
    • You may ask us to delete or remove your Personal Data in some circumstances. If we have shared your Personal Data with others, we will let them know about the deletion request where possible.
  • Right to opt out of sharing / targeted advertising:
    • We do not consider that our disclosure of Personal Data to third parties constitutes a “Sale” of Personal Data under applicable U.S. data protection laws. However, you may ask us at any time to stop “sharing” your Personal Data with third party social media platforms for purposes of identifying you and serving targeted Sourcepoint advertisements to you on such social media platforms.
  • Right of non-discrimination:
    • We will not discriminate against you for exercising any of the above rights.

You may exercise your rights by completing this form or by emailing us at privacy@sourcepoint.com. 

Virginia residents may appeal the denial of a request by emailing us at privacy@sourcepoint.com

9. Questions And Contact Details

If you have any questions about this Policy or our data processing practices, you can contact us using the contact details available at https://sourcepoint.com/connect-page/, by writing to Sourcepoint Technologies, Inc., 228 Park Avenue South, #87903, New York, NY 10003 -1502, USA, or, if you are located in the EU, to our German office named in section 7.3.

If you would like to review further information on Sourcepoint’s processing of Personal Data as a data processor or service provider in connection with the use of our services Dialogue Consent Management Platform and Anti Adblock, please visit our Privacy Notice – Sourcepoint Services.

 

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