Politica sulla privacy

User Data Managed by the LittleBIG Connection Platform

 

Table of contents:

1       Definitions

2       Introduction

3       Definition of user data on the LBC platform

3.1        Data linked to the user profile – personal data

3.2        Data produced by the user in its professional capacity

4       Purposes and uses of data

4.1        Purpose and processing of user profile data – personal data

4.2        Processing of data produced by the user as employee

4.3        Data recipients

4.4        Length of data retention

5       LittleBIG Connection and the RGPD

5.1        Data security

5.2        Rights of users

5.3        Data protection officer

 

 

 

1       Definitions

 

Data Controller: the natural or legal person, department or other body which, alone or jointly with others, determines the purposes and means for the processing of data.

Consent: any free, specific, informed and unequivocal expression of will by which the data subject accepts, by a statement or clear positive act, that personal data concerning him or her may be processed.

Employee: any salaried staff of the entity setting up a User account.

Little Big Connection (LBC): platform intended for key account clients enabling them to enter into relationships with SMEs and freelance consultants, with a view to carrying out projects that require a certain skills set.

Personal data: any information relating to an identified or identifiable natural person. An “identifiable natural person” is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data, online login or user name, or to one or more specific elements to his/her physical, physiological, genetic, mental, economic, cultural or social identity.

Processing: any operation or set of operations, whether or not performed, using automated processes and applied to personal data or data sets, such as collection, recording, organization, retention, modification, retrieval or consultation.

RGPD: General Regulation on Data Protection, namely, European Parliament and Council Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data.

User: the natural or legal person registered on the platform through a representative, and making use of the services made available to it.

 

2       Introduction

On 25 May 2018, a new European regulation, called the RGPD, came into force concerning the protection of individuals with regard to the processing of personal data by legal or natural persons.

Little Big Connection undertakes, when conducting its activities, and in accordance with the legislation in force, to ensure the protection, confidentiality and security of the personal data of Users of its services, as well as to respect their privacy.

This document describes the provisions that LBC is committed to implementing to meet data protection requirements. In particular, Little Big Collection defines the organization that will be set up, the methodology to be followed to manage project security and the technical, organizational and procedural measures that will be implemented.

 

3       Definition of User data for the LBC platform

3.1       Data linked to the User profile – Personal data

The User profile data are considered, by default, personal data.

These data are as follows:

  • User profile parameters (e.g.: surname, first name, contacts…)
  • The User’s LBC digital CV
  • References to assignments mentioned on the CV concerning the User
  • All recommendations entered by the User
  • All User recommendations

3.2       Data produced by the User in its professional capacity

Data can be produced on the platform by a User affiliated to a company, as part of its professional activity.

These data are:

  • Company: all company configurations produced by the User
  • Employees: employee invitations
  • Requests for proposals: product bids
  • Appointments
  • Project Ratings and Comments

For more details, you can consult the document dealing with the reversibility of company data.

 

4       Purposes and uses of the data

4.1       Purpose and processing of User profile data – Personal data

The personal data of the User’s profile, when the User is not affiliated with a company, can be made visible in a public way, should he/she decides to communicate the URL of his LBC profile to a third party. The sole purpose of the processing, after their retrieval, is to recruit and assign people to one or more future projects.

In addition, for statistical reasons as well as for better management and use of the platform, the personal data of the User, including its skills, may be utilized

Finally, the data can be used for communicating with the User so as to better understand the platform’s features (tutorials, alerts…) and to also offer targeted communication via a newsletter.

For the User’s Profile, in order to optimize their visibility in the search tools of the platform, personal data such as First Name and Last Name shall be visible to all the other members registered as User Profiles on the Platform.

 

4.2       Processing of data produced by the User as Employee

Where the User is affiliated to a company, many processing operations will be carried out on its data. Such processing is based on the functionalities of the Little Big Connection tool that the User’s company wished to use on the basis of a clear and predefined contract. Thus, the said contract needs to be read.

Agreements signed between the parties cover the management and use of this data, and in particular, and not exhaustively, the management of the customer’s account, the identification and authentication of the customer or user and communication with the customer (technical and sales support, etc.).

 

4.3       Data recipients

In addition to the members of the platform and the companies with which a User is affiliated, personal data may be consulted and processed by LBC’s duly authorized personnel, as part of the proper management of the platform and for the aforementioned purposes. A system of traceability of the latter’s actions has been set up to guarantee data protection.

LBC reserves the right to share with its Group all previously detailed personal data and information. However, it must be emphasized that LBC does not sell or rent User personal data to third parties for commercial purposes.

Following a subpoena, court decision, warrant, court order or any other regulations, LBC may be required to disclose personal data and other related information, if necessary. LBC may also choose to exercise and assert its rights in court against any legal action.

 

4.4       Length of data retention

Little Big Connection shall keep the data only for as long as necessary to fulfill the purposes mentioned above or to meet legal obligations.

It is advisable to specify that after a period of three years of inactivity on the platform from the date of user enrollment, the User will be sent an e-mail proposing to keep its profile on the platform or delete it. After three unsuccessful reminders on the part of LBC, the account will be automatically deactivated.

 

5       Little Big Connection and the RGPD

5.1       Data security

Little Big Connection is concerned about the protection of personal data and commits to ensuring the highest level of protection of personal data in accordance with legal obligations and the RGPD

LBC has therefore defined technical and organizational measures to protect data appropriately according to their nature, the extent to which they are to be processed and are accessible. That can involve data anonymization, access rights management, secure flows, etc.

 

5.2       Rights of users

The User shall benefit from rights relating to its personal data and to the processing carried out by LBC. The User can, thus, at any time request that it be granted access to personal data in order to have them corrected or deleted (insofar as this does not prevent the proper execution of the contract or compliance with the legal obligations of LBC) and it can oppose one or more data processing methods, under the conditions provided by the Regulation.

The User may also file a complaint with the supervising authority in charge of monitoring compliance with obligations regarding personal data.

The User can exercise these rights by writing to the following e-mail address: personal-data@littlebigconnection.com.  All requests must be accompanied by a photocopy of an ID card as proof of identity.

Concerning the right to correct data, the User shall have free access to its profile on the platform and can thus modify certain data. It is important that the information provided to LBC be accurate and up-to-date.

As previously mentioned, the User has a right to be “automatically” forgotten if it has remained inactive on the platform for a period three years from the date of enrollment (see 3.4 “Length of data retention”).

As concerns self-employed profiles such as “freelancers”, two requests must be made:

  • A first request concerning their professional activity by using the reversibility application form;
  • A second request for deletion of personal data.

 

5.3       Data protection officer

The appointment of a Data Protection Officer is “mandatory in public sector institutions, in companies that regularly and systematically monitor people on a large scale or process sensitive data on a large scale.”

Little Big Connection neither possesses nor processes any sensitive data (under RGPD/CNIL).

Nevertheless, a personal data protection officer has been appointed and may be contacted at the following e-mail address: personal-data@littlebigconnection.com., thus allowing any User to obtain information on this.

  1. Cookies

 

The Site uses “cookie” technology. A cookie does not permit identification of users; however, it records information that may be provided by the Client-Provider and Client-Beneficiary via the contact form as well as information relating to the way the user’s computer browses the LBC site (pages viewed, date and time of consultation, etc.), which can be read during subsequent visits without the user having to identify himself/herself, every time. LBC also uses these cookies for statistical analysis of site traffic.

The Client-Provider and Client-Beneficiary as user can oppose the installation of cookies by configuring their browser in the Internet tools/options section and then, depending on the browser, by clicking on the security, confidentiality or privacy icons.

Deactivation of these cookies prevents users from taking advantage of all the Site’s features.

In all cases, the User is asked to exercise discretion in disclosing personal information.