International Marketplace Network (IMN)
Privacy Policy
IMN places confidentiality and respect for your Data at the heart of its concerns.
We take all necessary measures to (i) provide you with clear and transparent information about how your Data will be processed, (ii) implement all necessary technical and organisational measures to protect your Data against disclosure, loss, alteration or access by an unauthorised third party, (iii) retain your Data only for the time necessary for the purposes of the specified processing and (iv) offer you the opportunity to access and modify your Data that we process at any time.
To achieve these objectives, we implement appropriate technical and organisational measures to ensure that the processing operations comply with applicable data protection law.
GLOSSARY
For a proper understanding of this privacy policy, here are some key concepts :
Cookies : A cookie is a small text file placed on the user's hard drive by the server of the visited site or by a third party server, it contains information about the navigation performed on this site.
Personal data : Any information that directly or indirectly identifies a natural person (e.g. your name, e-mail address, billing information, telephone number).
Right of access : You have the right to ask us to confirm whether or not personal data concerning you are being processed and, if so, to access such data and:
- the reasons why we hold your Personal Data;
- the categories of Data we hold;
- our use of your Personal Data;
- who has access to your Personal Data (and their location);
- where your Personal Data may be transferred;
- the length of time we keep your Personal Data;
- if you have not provided us with your Personal Data directly, how we obtained it;
- your rights under applicable laws and the possibility of limiting processing;
- the possibility of lodging a complaint with the competent supervisory authority;
- whether we use your Personal Data for automatic decision-making and how we do it.
Right to erase : You have the right to ask us to delete any personal data concerning you.
Right to Limitation : You have the right to ask an organization to temporarily freeze the use of some of your Data, particularly during the examination of your request to exercise another right.
Right of objection : You may at any time object to the use of some of your Data by an organization by stating reasons related to your particular situation.
Right to portability : You may request the communication of part of the Data you have provided us in a machine-readable format but also the transmission of this Data to a third party of your choice.
Right of rectification : You may request the rectification of inaccurate or incomplete information about yourself (e.g. an incorrect address).
Purpose : The purpose refers to the main purpose pursued when processing your Personal Data. Your Personal Data is used for specific, explicit and legitimate purposes.
Basis of the treatment : To process your Personal Data IMN has the following legal bases:
- Contract performance : we process your Personal Data when it is necessary for the performance of the contract concluded with you or for the performance of pre-contractual measures taken at your request.
- Compliance with a legal obligation : the processing of your Data may be imposed on us by the legislator. For example, the fight against terrorism.
- Our legitimate interest : the processing of your Data may be necessary to pursue our legitimate interest, including ensuring the improvement of our Platform and enabling our business to improve.
Marketplace : The marketplace is an online platform that connects independent sellers and buyers.
Data subject : This privacy policy applies to you if you are :
- merchant user, i.e. the person who created an account on the Platform,
- merchant prospect, i.e. the person who has not created an account on the Platform.
Data controller : this is the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing. IMN is for the most part responsible for most of its processing operations.
Processing : any operation or set of operations carried out or not carried out using automated processes and applied to personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, matching or interconnection, limitation, deletion or destruction.
Data transfer : Any communication, copy or movement of personal data intended for processing in a country outside the European Union.
1) DATA CONTROLLER
IMN (International Marketplace Network) is a limited liability company with a share capital of €24, registered in the Dutch Company Register under number 860334879, represented by Mehdi Tali, as Managing Director and with its registered office in Amsterdam.
IMN manages the IMN Platform (hereinafter referred to as the "Platform") and, as such, processes your personal data in various ways as controller.
2) WHAT DATA ABOUT YOU IS COLLECTED?
The information collected by IMN includes:
- Identity information - this is the information we use to ensure that you are who you say you are. This includes: first name, last name, e-mail address, telephone number, country, etc.
- Device information - this is the information we use to secure our network and improve our services and performance. This includes, for example: IP address, date and time of visit, duration of visit on our Platform, reference URL (if you arrived on our Platform via another site or an advertisement).
3) WHY DO WE PROCESS YOUR DATA?
Your Data are used for the following processing operations :
|
N° / REF |
Principal purpose |
Legal basis |
Recipient |
|
Data processing n°1 |
Management and optimization of the Platform |
Performance of the contract / Legitimate interest |
Intern Recipient : - Technical Service (EU)
Externes Recipient : - Service providers specialising in the provision of IT infrastructure (EU) |
|
Data processing n°2 |
Merchant relationship management |
Performance of the contract / Legitimate interest |
Intern Recipient : - Customer Service (EU)
Externes Recipient : - Service providers specialising in the provision of IT infrastructure (EU) |
|
Data processing n°3 |
Security management of the IT systems related to the Platform |
Legitimate interest / compliance with a legal obligation |
Intern Recipient : - Technical Service (EU) - Customer Service (EU)
Externes Recipient : - Service providers specialising in the provision of IT infrastructure (EU) |
4) HOW LONG DO WE KEEP YOUR DATA?
Your Data is collected by IMN for the time necessary to carry out the processing operations referred to in paragraph 3 of this document.
The main categories of Data collected by IMN are kept for the following periods of time.
For merchant users, the Data are kept for 5 years from the end of the commercial relationship.
For merchant prospects, the Data is kept for 3 years from the last contact.
We also describe the time limits for the expiry of cookies in paragraph 7 of the Privacy Policy.
As a general rule, we store your Data within the European Union.
However, since some of our service providers and Marketplaces are located in countries outside the European Union ("Third Countries"), we transfer some of your Data to Third Countries.
This may be the case in particular for Third Countries for which the European Commission has not assessed the level of compliance such as the United States of America.
In such a case, we ensure that this transfer is carried out in accordance with the applicable regulations and guarantees an adequate level of protection of your privacy and fundamental rights.
Upon simple request to our Data Protection Officer, we can provide you with more information about these transfers.
6) HOW TO EXERCISE YOUR RIGHTS ?
In general, to exercise your rights, please send your request (indicating your e-mail address, surname, first name, postal address and a copy of your identity document) to the IMN Data Protection Officer:
- either by email sent to contact@imnnow.com
- or by post to IMN, Personal Data Protection Officer.
We will send you a reply within a maximum of one (1) month following the date of receipt of your request. This period may be extended by two (2) additional months depending on the complexity and number of requests.
For the sake of transparency and simplicity, you will find below a table summarizing your rights according to the different processing operations.
A glossary of key terms is available at the beginning of the document.
|
Your rights |
Conditions |
Data processing concerned |
|
Right of access |
- |
All processing of personal data |
|
Right to rectification |
It is important to note that this right only applies if: - the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; - you wish to object to the processing and there are no legitimate compelling reasons for the processing or if it is a processing operation carried out for the purpose of commercial prospecting; - the personal data have been unlawfully processed. |
All processing of personal data |
|
Right to restriction of processing |
It is important to note that this right only applies if: - - you dispute the accuracy of your Data for the duration of time allowing us to verify the accuracy of the same, - - you consider that we are processing your Data unlawfully and that you require that their use be limited rather than deleted, - - we no longer need your Data for the purposes referred to in paragraph 3 but that they are still necessary for the establishment, exercise or defense of your legal rights, - in the event that you exercise your right to object during the period of verficiation as to whether the legitimate grounds we are pursuing prevail over yours. |
Processing operations based on the performance of the contract, your consent or our legitimate interest. |
|
Right to erasure |
In the event of a request to delete your Data, IMN may nevertheless keep it in the form of an intermediate archive, for the time necessary to satisfy its legal, accounting and tax obligations. |
Processing operations based on the performance of the contract, your consent or our legitimate interest. |
|
Right to object |
- |
Processing operations based on our legitimate interest. |
|
Right to data portability |
- |
Processing operations based on your consent or the execution of the contract. |
|
The right to formulate post-mortem guidelines |
You have the right to formulate specific and general post-mortem guidelines regarding the storage, deletion and communication of your Data. In the absence of any instructions, your heirs may contact IMN to - to access Data processing allowing "the organisation and settlement of the deceased's succession". - and/or to have your Account on the Platform closed and/or to oppose the further processing of your Data.
In any case, you have the possibility to inform us, at any time, that you do not wish, in the event of death, that your Data be communicated to a third party. |
All processing of personal data |
|
The right of complaint |
You can, at any time, file a complaint with the competent supervisory authority. |
All processing of personal data |
7) COOKIE MANAGEMENT
This section is dedicated to our cookie management policy on our Platform.
It allows you to learn more about the origin and use of the navigation information processed during your consultation of our Platform and your rights.
7.1 What is a cookie?
When consulting its Platform, IMN may, subject to your choices, deposit a text file on your terminal (computer, smartphone, tablet) using your browser.
This text file is a cookie. It will allow IMN, during the validity or registration of the cookie, to identify your device during your next visits.
Only the issuer of a cookie may read or modify the information contained in the cookie.
Below you will find information about cookies that may be placed on your device while you are on the Platform, either by IMN or by third parties, and how you can delete/reject the registration of these cookies on your device.
7.2 What are cookies used for on www.IMNnow.com?
There are several categories of cookies, some are issued directly by IMN, others may be issued by third party companies.
7.3 Cookies issued by IMN
7.3.1 "Essential" cookies
These cookies are essential for browsing our site and also for tracking IMN's activity.
7.3.2. Cookies " Analytics and Personalization " cookies
These cookies are not essential for browsing our site but can make it possible, for example, for you to facilitate your searches, optimize your experience, and for us to better target your expectations, improve our offer, or optimize the operation of our Platform.
7.4 Cookies issued by third party companies
The issuance and use of cookies by third parties on our Platform is subject to the privacy policies of such third parties. These cookies are not necessary for navigation on our Platform.
7.5 The choices available to you through your browser software (Internet Explorer, Firefox, Google Chrome, etc.).
You can set a cookie on your device only if you want to. Only "Essential" cookies cannot be disabled.
You can configure your browser software as you wish, so that cookies are (i) accepted and stored on your device or, on the contrary, (ii) rejected.
If your browser software is set to accept cookies on your device, cookies embedded in the pages and content you have viewed will always be saved on your device.
You can configure your browser software in such a way that (i) you are offered the option of accepting or rejecting cookies from time to time, before a cookie is likely to be saved, (ii) you systematically refuse to save cookies in your device.
Warning: Any settings you may make on your browser software regarding the acceptance or rejection of cookies may affect your Internet experience and your access to certain services that require the use of these same cookies.
For example, by refusing certain essential cookies, you may no longer be able to use the Platform.
If you choose to refuse to store cookies on your device or delete cookies stored on your device, we do not accept any responsibility for the consequences of the degraded operation of our services resulting from the inability of us to store or view the cookies necessary for their operation and that you have refused or deleted them.
8) SECURITY MEASURES
We undertake to implement appropriate technical and organisational measures to guarantee a level of security appropriate to the risk to the rights and freedoms of natural persons in the context of the processing operations referred to above.
These measures shall be defined taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing operation as well as the risks identified.
9) REVIEW AND UPDATE OF THE POLICY
This policy will be updated as necessary to meet the requirements of applicable data protection regulations. It shall be reviewed at least every three (3) years.
10/10/2019