Privacy Policy

01 Who are we?

01.1 Person responsible for the treatment

01. IBridge People, société par actions simplifiée au capital de 25.000 euros, immatriculée au Registre du Commerce et des Sociétés de Versailles, sous le numéro 848 976 965, dont le siège social est situé 75 rue de Lourmel 75015 Paris, France (ci-après « IBridge People »), propose les services de la plateforme iBridge People selon les présentes conditions.

02 Our Data Protection Officer

2. Aleph has appointed a Data Protection Officer (DPO). You can contact him by e-mail at ibp@ibridgepeople.com.
3. The Data Protection Officer is responsible for advising, informing and monitoring compliance with data protection regulations.

03 What are our commitments to the protection of personal data?

4. We are committed to guaranteeing a high level of protection for the personal data of data subjects who use the platform’s services.
5. We undertake to comply with the applicable regulations (in particular Articles 5 and 6 of the RGPD) for all processing of personal data that we implement as part of the platform’s services. In particular, we undertake to comply with the following principles:

• personal data are processed lawfully, fairly and transparently (lawfulness, fairness, transparency);
• personal data is collected for specified, explicit and legitimate purposes and is not further processed in a way incompatible with those purposes (purpose limitation);
• personal data are stored in an adequate and relevant manner and are limited to what is necessary for the purposes for which they are processed (data minimisation);
• personal data are accurate, kept up to date and every reasonable step is taken to ensure that data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy) ;
• data exchanged during a meeting on the platform (images, documents, videos, chat or any other shared information) are not recorded or stored on our servers.
• video or audio recordings of the various language channels are made exclusively at the customer’s request, are delivered as quickly as possible and are immediately deleted from our servers.
• we do not store any data exchanged on the platform.

6. We implement appropriate technical and organisational measures to guarantee a level of security appropriate to the risk inherent in our processing operations, to meet regulatory requirements and to protect the rights and personal data of data subjects from the outset of processing operations.
7. We also contractually impose the same level of personal data protection on our subcontractors (service providers, suppliers, etc.).
8. Finally, we undertake to comply with any other principle that may be required under the applicable regulations on the protection of personal data, and more specifically concerning the rights conferred on the persons concerned, the periods for which personal data is kept and the obligations relating to cross-border transfers of personal data.

04 The personal data we process

9. We collect and process the following data in particular:

• as a customer of the platform: your surname, first name, address, e-mail address, telephone number, company name and address, company name, position within the company, payment details, communicated by e-mail.
• as an anonymous user of the platform: no data.
• as an identified user of the platform: your surname, first name, address, e-mail address, telephone number, language preferences, connection data (dates and times of connection, IP address) and browsing data.
• as an interpreter on the platform: your surname, first name, e-mail address and telephone number, communicated by e-mail directly or via the interpreting agency.

10. We do not process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, nor do we process genetic data, biometric data to uniquely identify a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

05 Recipients of your data

16. The personal data we collect, as well as those collected subsequently, are intended for us in our capacity as data controller.
17. We ensure that only authorised persons have access to this data. Our service providers may receive this data in order to carry out the services we entrust to them. Certain personal data may be sent to third parties or legally authorised authorities in order to meet our legal, regulatory or contractual obligations.
18. It may be communicated to these entities for the purposes set out in this information notice. These operations are carried out on the basis of instruments that comply with the applicable regulations and ensure that your rights are protected and respected.
19. In addition, it may be communicated in application of a law, a regulation, a decision by a regulatory or judicial authority and finally, if necessary for Aleph, in order to protect its rights and interests.

06 Transferring your data

20. Processing does not involve the transfer of data to a third country. No data is stored during AI processing, apart from the transit and processing time of a few seconds. Recordings and/or subtitles requested by the customer are destroyed once delivered, as is any processing by AI to produce a structured text or summary.

07 How long we keep your data

21. Your personal data is kept for no longer than is necessary for the purposes for which it was collected.

22. The retention periods we apply to your personal data are proportionate to the purposes for which they were collected. They are kept for varying periods depending on the purpose for which they were collected, i.e. […]. 

How long we keep your data

The entire duration of the contractual relationship plus the duration of any legal requirements. The ordinary limitation period in civil and commercial matters is 5 years from the end of the contract.

The data may be kept for up to twelve (12) months from the time the alerts are issued before being qualified.

Alerts deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted.

Qualified alerts are kept for a maximum of five (5) years from the closure of the fraud file. For persons registered on a list of proven fraudsters, the data concerning them is deleted after a period of five (5) years from the date of registration on this list.

If legal proceedings have been initiated, the data will be kept until the end of the legal proceedings, plus the time required to comply with legal requirements.

The ordinary limitation period in civil and commercial matters is five (5) years from the end of the contract.

The data may be kept for up to twelve (12) months from the time the alerts are issued before being qualified.

Alerts deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted.

Qualified alerts are kept for a maximum of five (5) years from the closure of the fraud file. For persons registered on a list of proven fraudsters, the data concerning them is deleted after a period of five (5) years from the date of registration on this list.

If legal proceedings have been initiated, the data will be kept until the end of the legal proceedings, plus the time required to comply with legal requirements.

The ordinary limitation period in civil and commercial matters is five (5) years from the end of the contract.

08 Your recognised rights

23. We are particularly concerned to respect the rights you are entitled to in connection with the processing of your personal data by us, in order to ensure that it is processed fairly and transparently, taking into account the specific circumstances and context in which your personal data is processed.

08.1 Your right to access and correct your data

24. As such, you have confirmation as to whether or not your personal data is being processed, and where it is, you have the right to request a copy of your data and information about :

• the purposes of the processing ;
• the categories of personal data concerned;
• the recipients or categories of recipients and, where appropriate, if such disclosures are to be made, the international organisations to which the personal data have been or will be disclosed, in particular recipients established in third countries;
• where possible, the intended retention period for personal data or, where this is not possible, the criteria used to determine that period ;
• the existence of the right to ask the data controller to rectify or erase your personal data, the right to request a restriction on the processing of your personal data, and the right to object to such processing;
• the right to lodge a complaint with a supervisory authority;
• information on the source of the data when it is not collected directly from the data subjects;
• the existence of automated decision-making, including profiling, and in the latter case, useful information concerning the underlying logic, as well as the importance and the expected consequences of this processing for the data subjects.

08.2 Your right to erasure of your data

25. You may ask us to delete your personal data where one of the following reasons applies:

• the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• you withdraw the consent previously given ;
• you object to the processing of your personal data where there are no compelling legitimate grounds for the processing;
• the processing of personal data does not comply with the provisions of the applicable legislation and regulations.

26. Your attention is drawn to the fact that the right to erasure of data is not a general right and can only be exercised if one of the grounds provided for in the applicable regulations is present.
27. Thus, if none of these reasons is present, Aleph will not be able to respond favourably to your request; this will be the case if it is obliged to retain the data due to a legal or regulatory obligation or for the establishment, exercise or defence of legal claims.

08.3 Your right to limit the processing of your data

28. You may request that the processing of your personal data be restricted in the cases provided for by law and regulations.

08.4 Your right to object to the processing of your data

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data for which the legal basis is the legitimate interest pursued by the controller (see article above on the legal basis for processing).
If you exercise such a right to object, we will ensure that we no longer process your personal data in connection with the processing concerned unless we can demonstrate compelling legitimate grounds for continuing such processing. These grounds must outweigh your interests and your rights and freedoms, or the processing must be justified for the establishment, exercise or defence of legal claims.
You have the right to object to any processing linked to commercial canvassing without it being necessary to invoke reasons relating to your particular situation.

08.5 Your right to portability of your data

29. You have the right to the portability of your personal data. Please note that this is not a general right. Not all data from all processing operations is portable, and this right only applies to automated processing, to the exclusion of manual or paper-based processing.
30. This right is limited to processing for which the legal basis is your consent or the performance of pre-contractual measures or a contract.
31. This right does not include derived or inferred data, which are personal data created by Aleph.
32. The data on which this right may be exercised are :

• only your personal data, which excludes anonymised personal data or data that does not concern you;
• declarative personal data and the personal operating data mentioned above.

33. The right to portability may not infringe the rights and freedoms of third parties, such as those protected by business secrecy.
34. You may request data portability in accordance with the procedure set out below, specifying whether you wish to receive the data yourself or whether it is technically possible for us to transfer it directly to another data controller.
35. In the latter case, please let us know the exact name of the person responsible, their contact details and the department or person to whom they should be sent. To facilitate the exercise of this right, you must inform the recipient of your request to our services.

08.6 Your right to withdraw your consent

36. Where the data processing we carry out is based on your consent, you may withdraw it at any time. We will then stop processing your personal data without affecting any previous operations for which you have given your consent.

08.7 Your right to define post-mortem directives

37. You have the possibility of defining directives relating to the conservation, deletion and communication of your personal data after your death with a trusted third party, certified and responsible for ensuring that the wishes of the deceased are respected, in accordance with the requirements of the applicable legal framework.

08.8 Your right of appeal

38. You have the right to lodge a complaint with the Cnil in France, without prejudice to any other administrative or legal remedy.

08.9 How to exercise your rights

40. You can exercise these rights at any time:

• By post to the following address 21 rue du Long des Bois, 78690, Saint-Rémy l’Honoré ;
• By e-mail to the following address: ibp@ibridgepeople.com.

41. In this context, we kindly request that requests be accompanied by the information required to identify (surname, first name, e-mail address) the data subjects concerned by the processing operation, as well as any other information required to confirm their identity.
42. In the event of a breach of the regulations applicable to the protection of personal data, the persons concerned by the processing also have the right to lodge a complaint with the Commission nationale de l’informatique et des libertés on French territory (3 place de Fontenoy – TSA 80715 – 75334 Paris cedex 07; tel: 01 53 73 22 22), without prejudice to any other administrative or legal remedy.

09 What security measures are in place for your personal data?

43. We attach great importance to the security of your data.
44. Appropriate technical and organisational measures are implemented to ensure that data is processed in such a way as to guarantee its protection against accidental loss, destruction or damage that could adversely affect its confidentiality or integrity. In particular, we ensure the security of our servers on which your data is stored.
45. When developing and designing, or selecting and using, the various tools that enable personal data to be processed, we ensure that they provide an optimum level of protection for the data processed.
46. This is why we take all appropriate measures to prevent, as far as possible, any alteration or loss of your data or any unauthorised access to it.
47. Aleph implements measures that respect the principles of protection by design and protection by default of the data processed.
48. When we use a service provider, we only communicate personal data to them after having obtained a commitment and guarantees from them regarding their ability to meet these security and confidentiality requirements.
49. In compliance with our legal and regulatory obligations, we enter into contracts with our subcontractors that precisely define the terms and conditions under which they process personal data.
50. Aleph also carries out audits of its own services and those of its service providers, in order to verify the application of data security rules.

10 Personal data relating to minors

51. We do not collect or process personal data relating to children under the age of 16 without the prior consent of the child’s parents or guardians. If personal data concerning children is collected via the platform, parents or guardians may object by contacting us at the above address.
52. In addition, as stated above, a child who was a minor at the time his or her personal data was collected may have it deleted as soon as possible.

11 Cookies

11.1 Definitions

53. Cookies are pieces of information deposited on the Internet user’s terminal equipment by the server of the website visited. They are used by a website to send information to the Internet user’s browser and enable the browser to send information back to the originating site (for example a session identifier or language choice).
54. Only the sender of a cookie can read or modify the information contained in it.

55 There are different types of cookies:

• session cookies, which disappear as soon as you leave the site;
• permanent cookies, which remain on your terminal until their lifetime expires or until you delete them using your browser’s functions.

56. You are informed that when you visit this site, cookies may be installed on your terminal equipment.

11.2 Purpose of the cookies used

57. The sole purpose of some of the cookies used by Aleph is to enable or facilitate electronic communication (detection of connection errors, identification of connection points, etc.).
58. Others are strictly necessary for the provision of online communication services at your express request, such as screen display preferences.
59. Others are used to :

• to analyse the number of visitors and the use made of the platform, in order to improve the browsing experience;
• improve the relevance of advertisements displayed on the platform;
• make the platform more user-friendly and interactive.

11.3 What cookies do we use?

60. The cookies used on the platform are :

• Aleph’s cookies ;
• third-party cookies selected by Aleph for specific purposes.

11.4 Consent

61. On your first visit to our platform, you will be asked to accept or refuse the use of certain cookies.
62. If you do not wish cookies to be installed or read on your terminal equipment, a refusal cookie will be placed on your equipment so that Aleph can record the information that you have objected to the use of cookies. If you delete this refusal cookie, it will no longer be possible to identify you as having refused the use of cookies.
63. Similarly, when you accept the use of cookies, a consent cookie is installed.
64. Consent or refusal cookies must remain on your terminal equipment. You can change your preferences at any time as indicated in the following section entitled “Cookie management”.

11.5 Managing cookies

65. You have several options for deleting and managing cookies and other trackers.

11.5.1 Browser settings

66. While most browsers are set to accept cookies by default, you can choose to accept all cookies, reject them systematically or select the ones you accept according to the sender. You can also regularly delete cookies from your terminal via your browser.
67. However, don’t forget to configure all the browsers on your various terminals (tablets, smartphones, computers, etc.).
68. To manage cookies and your choices, the configuration of each browser is different. This is described in your browser’s help menu, which will tell you how to modify your cookie preferences. For example:

• for Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ;
• for Safari™: https://support.apple.com/fr-fr/safari ;
• for Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 ;
• for Firefox™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies ;
• for Opera™: http://help.opera.com/Windows/10.20/fr/cookies.html.

69. However, we would like to draw your attention to the fact that if you set your browser to refuse cookies, certain functions, pages and areas of the site will not be accessible, for which we cannot be held responsible.

11.5.2 Opposition platforms

70. Several professional advertising platforms also give you the option of refusing or accepting cookies used by their member companies. These centralised mechanisms do not block the display of advertisements, but only prevent the installation of cookies that enable us to tailor advertisements to your centres of interest.
71. For example, you can visit www.youronlinechoices.com to prevent cookies being installed on your terminal. This site is provided by digital advertising professionals grouped together within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France.
72. This will enable you to find out which companies are registered with this platform and offer you the option of refusing or accepting the cookies used by these companies to adapt the advertising likely to be displayed on your terminal to your browsing information: http://www.youronlinechoices.com/fr/controler-ses-cookies/.
73. This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralised interface enabling you to express your refusal or acceptance of cookies that may be used to adapt the advertising that may be displayed on your terminal to your browsing habits.

11.6 Protection of personal data

74. In the context of the use of cookies as described in this policy, Aleph may process personal data concerning you, as the data controller.
75. The data collected is essential for achieving the objectives pursued by each cookie. They are intended solely for use by the authorised departments of Aleph and/or the company issuing the third-party cookies.
76. Personal data collected via cookies is never kept longer than is necessary to achieve the purpose of the cookie, and in no case longer than 13 months.
77. You have the same rights as those mentioned above concerning the collection of your personal data via cookies.

12 Changes to this policy

78. We regularly update this policy in line with legal developments and any updates will be available on this page.