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PRIVACY POLICY
OCTOPIA
Table of contents
1. OCTOPIA’S COMMITMENTS RELATED TO PERSONAL DATA PROTECTION ................................... 2
1.1. OCTOPIA ...................................................................................................................................... 2
1.2. OCTOPIA’S COMMITMENTS ....................................................................................................... 2
2. PROCESSING OF PERSONAL DATA BY OCTOPIA ............................................................................ 3
2.1. AS A DATA CONTROLLER ............................................................................................................ 3
2.2. AS A DATA PROCESSOR OF THE SELECTED MARKETPLACE ....................................................... 5
2.3. AS A DATA PROCESSOR OF THE USER ........................................................................................ 6
3. HOW LONG ARE YOUR DATA RETAIN? .......................................................................................... 8
4. HOW TO EXERCISE YOUR RIGHTS? ................................................................................................. 8
5. TRANSFERS OUTSIDE THE EUROPEAN UNION ............................................................................... 9
6. SECURITY MEASURES ...................................................................................................................... 9
7. COOKIES .......................................................................................................................................... 9
7.1 WHAT IS A COOKIE? ........................................................................................................................ 10
7.2 TYPE AND PURPOSES OF COOKIES ................................................................................................. 10
7.3 LIABILITIES REGARDING COOKIES .................................................................................................. 10
7.4 MANAGEMENT OF COOKIE’S DEPOSIT .......................................................................................... 11
8. REVIEW AND UPDATE OF THE PRIVACY POLICY .......................................................................... 12
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1. OCTOPIA’S COMMITMENTS RELATED TO PERSONAL DATA PROTECTION
1.1. OCTOPIA
OCTOPIA (hereinafter « OCTOPIA »), registered in the Trade and Companies Register of Saint-Etienne
under number 880 150 289, provides to professional sellers (hereinafter the “Users”) a technical
solution of intermediation (hereinafter “OCTOPIA Solution”), allowing the Users to register on Cdiscount
marketplace and on other marketplaces (hereinafter the “Selected Marketplaces”), clients of OCTOPIA,
in order to commercialize their products to customers or professional customers on the Selected
Marketplaces (hereinafter the “Purchasers”).
Furthermore, the Solution OCTOPIA allows Users to manage their activities on the Selected
Marketplaces on which they are registered and in particular to create their products, manage their
stocks, their prices, their invoicing and process their orders.
OCTOPIA’S data protection officer (hereinafter “DPO”) ensures the compliance of personal data
processing carried out by OCTOPIA.
You may contact OCTOPIA’S DPO:
- By email to dpo@octopia.com
- By postmail to OCTOPIA, Data Privacy Officer (Délégué à la protection des données
personnelles), 120-126 quai de Bacalan, 33067 BORDEAUX Cedex.
1.2. OCTOPIA’S COMMITMENTS
This Privacy Policy applies if you are:
- Users of the OCTOPIA Solution;
- A professional seller contacted by OCTOPIA’s teams and have not yet created a user account
on OCTOPIA Solution (hereinafter “Prospects”);
- A Purchaser;
- An Internet user (hereinafter “Web User”) browsing the website www.octopia.com
(hereinafter the “Website”);
It is essential to OCTOPIA to ensure the confidentiality and respect of your personal data (hereinafter
“Personal Data”). OCTOPIA protects your privacy by ensuring protection, confidentiality, non-alteration,
availability and security of your Personal Data.
OCTOPIA makes every effort to (i) provide a clear and transparent information on how Personal Data
are processed, (ii) apply technical and organisational measures needed to protect Personal Data in
accordance with applicable data protection laws and (iii) retain Personal Data only during the time
necessary for the purposes of processing.
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2. PROCESSING OF PERSONAL DATA BY OCTOPIA
2.1. AS A DATA CONTROLLER
OCTOPIA, as a Data Controller, processes Personal Data of Prospects, Users and Website Users for the following purposes:
Purpose Legal basis Data subject Personal Data Recipient
Registration, Performance of contract Prospects Identification Data: N° SIREN, corporate form OCTOPIA internal recipient
administrative and Users of the society, society name, first and last
accounting name of directors, etc.
management of Contact Data: email, phone number, etc.
User accounts on Data related to professional life
OCTOPIA Solution, Economic and financial Data: RIB, IBAN, etc.
management of
User request
Control of User Legal obligation Prospects Identification Data: N° SIREN, corporate form OCTOPIA external recipients:
registration on Users of the society, society name, first and last - CRM software publisher
OCTOPIA Solution name of directors, etc. - Electronic money institution (CNOVAPAY)
[KYC] Contact Data: email, phone number, etc.
Data related to professional life
Economic and financial Dat : RIB, IBAN, etc.
Management of Legitimate interest Prospects Contact Data: email, phone number, etc. OCTOPIA internal recipient
commercial Users OCTOPIA external recipients:
prospection of - CRM software publisher
Prospects and
Users)
Provision of the Legitimate interest Users Identification Data: N° SIREN, corporate form OCTOPIA internal recipient
« Fullfilment » offer of the society, society name, first and last OCTOPIA external recipients:
name of directors, etc. - C-Logistics
Contact Data: email, phone number, etc. - Service providers specializing in transport and
delivery
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- Service providers specializing in software
publishing enabling collection and customer
orders and printing of transport label
Quality control of Performance of contract Users Identification Data OCTOPIA internal recipient
OCTOPIA Solution / Legitimate interest Purchasers Contact Data: email
Users Delivery Data: tracking number and tracking
link
Discussions related to customer relationship
management
History of Users
Management and Legitimate interest / Users Identification Data OCTOPIA internal recipient
opitmization of consent Web Users Navigation Data
OCTOPIA Solution Segmentation Data OCTOPIA external recipients:
and Website: - Tracking and audience measures service
Analysis of provider
navigation path, - Analysis and segmentation of web users
identification of service provider
massive
connections,
exclusion of
irrelevant IP
addresses, audience
measures,
personalization of
Website and offers,
advertising
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2.2. AS A DATA PROCESSOR OF THE SELECTED MARKETPLACE
Purpose Legal basis Data subject Personal Data Recipient
Hosting and Performance of contract Users Depending on the technical malfunction: OCTOPIA internal recipient
maintenance of Purchasers Identification Data
OCTOPIA Solution Contact Data OCTOPIA external recipients:
Order Data - Hosting and maintenance Service Provider
Management of Performance of contract Purchasers Identification Data: first and last name OCTOPIA internal recipient
orders and Contact Data: address (city, country), e-mail
Purchasers Data (crypted or nor dependant on the sales
communication to channel), telephone number
Users Order Data : number of order, date of order,
delivery method, product code, price/sale,
quantity
Management and Performance of contract Users Depending on the technical malfunction or OCTOPIA internal recipient
provision of Purchasers claim:
communication Identification Data OCTOPIA external recipients:
channel between Contact Data - Customer relationship management solution
Purchasers and Order Data service provider
Users - Publishing communication solutions service
provider
Claims and Performance of contract Users Depending on the claim: OCTOPIA external recipients:
litigation Purchasers Identification Data - Management of Users account solution
arbitration Contact Data service provider
[OPTIONAL] Order and delivery Data
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2.3. AS A DATA PROCESSOR OF THE USER
Purpose Legal basis Data subject Personal Data Recipient
Management, Performance of contract Purchasers Identification Data: first and family name OCTOPIA internal recipient
execution Contact Data: invoice and delivery addresses,
monitoring of telephone number, email (crypted or not OCTOPIA external recipients:
Purchasers’ order depending on the sales channel) - C-Logistics
[OPTIONAL: - Service providers specializing in transport and
shipping delivery
management – only - Service providers specializing in software
for Users who publishing enabling collection and customer
subscribed orders and printing of transport label
OCTOPIA’s
« Fulfilment » offer]
Management of Performance of contract Users Identification Data: first and family name, OCTOPIA internal recipient
customer Purchasers Users authorized contact, carrier authorized
relationship contact OCTOPIA external recipients:
[OPTIONAL] Contact Data: address (city, country), email, - Customer relationship management solution
phone number Service provider
Order and delivery Data: number of order, - Service provider specializing in interconnection
date of order, delivery method, product of information systems
code, price/sale, quantity - Service providers specializing in transport and
delivery
- C-Logistics
Editing of invoices Performance of contract Users Identification Data: first and family name, OCTOPIA internal recipient
on behalf of third Purchasers Users authorized contact, carrier authorized
parties contact OCTOPIA external recipients:
[OPTIONAL] Contact Data: address (city, country), email, - Editing of invoices solution Service provider
phone number
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Order and delivery Data: number of order,
date of order, delivery method, product
code, price/sale, quantity
Communication of Performance of contract Prospects Identification Data : OCTOPIA external recipients:
OCTOPIA Solution / Legitimate interest Users Contact Data : address, email - Selected Marketplaces of OCTOPIA Solution
Users to Selected
Marketplaces for
selection purposes
Any processing of Personal Data not specified above is under the User’s responsibility as Data Controller.
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3. HOW LONG ARE YOUR DATA RETAIN?
OCTOPIA retains Personal Data to allow you to use OCTOPIA Solution on a continuous basis, for as long
as necessary to carry out the processing operations above mentioned and to comply with legal
requirements.
The retention period of Personal Data varies depending on the purpose of processing. OCTOPIA retains
and deletes Personal Data in accordance with applicable law.
Typology of Processing Retention period
Processing relating to Web Users 13 months from Data collection
Processing relating to Prospects 3 years from last contact with the Prospect
Processing relating to Users 5 years from the end of the commercial relationship
4. HOW TO EXERCISE YOUR RIGHTS?
4.1. REQUESTS ADRESSED TO OCTOPIA, ACTING AS DATA CONTROLLER
4.1.1. YOUR RIGHTS
Regarding your Personal Data, you can exercise the following rights:
- Right of access;
- Right to rectification;
- Right to erasure (except if Personal Data are necessary to provide the services or for
compliance with legal obligation or for establishment, exercise or defence of legal claims) ;
- Right to restriction of processing;
- Right to data portability;
- Right to object;
- Right to define guidelines relating to the fate of your Personal Data after your death, with a
trusted third party, certified and responsible for ensuring that your wishes are respected in
accordance with the requirement of the legal framework;
You have the right to object, on grounds relating to your particular situation, to processing of Personal
Data which is based on OCTOPIA’s legitimate interest. OCTOPIA shall no longer process Personal Data
unless OCTOPIA demonstrates compelling legitimate grounds for the processing which override your
interests, rights, and freedoms or for the establishment, exercise, or defence of legal claims.
You have the right to object to any processing related to commercial prospection without grounds
relating to your particular situation.
4.1.2.EXERCISE OF YOUR RIGHTS
You can exercise your right:
- By email to dpo@octopia.com ;
- By postmail to OCTOPIA, Data Privacy Officer (Délégué à la protection des données
personnelles), 120-126 quai de Bacalan, 33067 BORDEAUX Cedex.
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For requests that reach the Data Protection Officer by email or postmail, please indicate the email
address attached to your User account (or use it in the case of an email) as well as your full name. In the
event that you are unable to find the email address attached to your User account or in the event of
serious doubts about your identity, additional information relating to your identity may be requested in
accordance with Article 12 of the GDPR.
OCTOPIA shall 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.
After contacting us, if you consider that your rights over your personal data have not been respected,
you can submit a complaint to the Commission nationale de l’informatique et des libertés (3 place de
Fontenoy - TSA 80715 – 75334 Paris cedex 07 ; phone number : +33 1 53 73 22 22).
4.2. REQUESTS ADRESSED TO OCTOPIA, ACTING AS DATA PROCESSOR
On principle, all request to exercise right addressed to OCTOPIA and relating to processing carried out
by OCTOPIA on behalf of a data controller (Selected Marketplace or User) will be communicated to the
data controller for processing of the request and/or validation.
5. TRANSFERS OUTSIDE THE EUROPEAN UNION
As a general rule, OCTOPIA stores your Personal Data within the European Union.
However, since some of our service providers and Selected Marketplaces are in countries outside the
European Union ("Third Countries"), OCTOPIA might transfer some of your Data to Third Countries. This
may be the case 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 (in particular by using standard contractual clauses of the European
Commission)
Upon simple request to our Data Protection Officer, we can provide you with more information about
these transfers.
6. SECURITY MEASURES
OCTOPIA undertakes to implement appropriate technical and organisational measures to guarantee a
level of security appropriate to the risk regarding the rights and freedoms of data subjects concerned
by 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.
7. COOKIES
This section is dedicated to the management of cookies:
- On OCTOPIA Solution;
- The Website;
This section informs about the use of navigation information processed during your use of the OCTOPIA
Solution and/or Website and the rights you have regarding cookies management.
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7.1 WHAT IS A COOKIE?
A cookie is a text file that is placed on your computer’s hard drive, subject to permission requested, by
websites which are browsed. Cookies are used to make website work more efficiently. Some cookies
are necessary for a better functioning of Websites. Other cookies are used to identify the website users
and improve OCTOPIA Solution and/or the Website depending on Website Users’ browsing.
Cookies cannot give access to information about you that you do not want to share. Cookies have a
limited lifetime and are deleted by browsers once the retention period has expired. Only the issuer of
cookies is able to read or modify information contained in the cookies.
7.2 TYPE AND PURPOSES OF COOKIES
Different types of cookies are used regarding the purposes pursued. The main courant type of cookies
are :
Cookies strictly necessary to
the use and functioning of These cookies are necessary to the functionning of the
the OCTOPIA Solution OCTOPIA Solution and/or the Website and its features,
and/or Website (or exempt from obtaining consent.
« essential cookies »)
These cookies are used (i) to measure the audience of the
OCTOPIA Solution and/or the Website or (ii) to test different
« Audience measurement » versions in order to optimize editorial choices according to
cookies their respective performances. Some of these cookies might
be considered as « essential cookies » and thus exempted
from the collection of consent.
Advertising cookies allow to display, in real time, the content
most suited to your interest (thanks to your recent browsing)
rather than generic content.
Advertising cookies These advertising content may contain cookies issued by
OCTOPIA, its service providers or by third parties (for the
latter) who have associated a cookie with the advertising
content of an advertiser.
7.3 LIABILITIES REGARDING COOKIES
• Cookies issued by OCTOPIA and/or OCTOPIA’s subcontractors
OCTOPIA is responsible for the issuance and use of cookies on OCTOPIA Solution and/or Website.
Certain types of cookies (« essential » or « audience measurement » cookies) are exempt from consent.
• Cookies issued by third-parties
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The issuance and use of cookies by third parties on the OCTOPIA Solution and/or Website are subject
to the privacy policies of these parties. These cookies are not necessary for browsing the OCTOPIA
Solution and/or Website.
The OCTOPIA Solution and/or the Website may integrate technologies of advertising partners which
allow the recognition of your computer and your navigation data in order to display advertisement
adapted to your interest in depending on your navigation.
These advertising partners collect your navigation data to:
- Allow us to display advertising of our products or services or Users’ products or services on
third websites and/or applications;
- Allow websites or advertiser to display advertising of their product or service on OCTOPIA
Solution and/or Website;
You can manage the deposit of cookies on your navigation terminal in accordance with the procedure
described below.
For further information about the technologies used by the advertising partners, please refer to their
privacy policy:
- Facebook;
- Twitter;
- Google +;
7.4 MANAGEMENT OF COOKIE’S DEPOSIT
In accordance with directive 2002/58/CE of July 12, 2002, OCTOPIA collects your prior consent to the
deposit of cookies, except for “essential” and “audience measurement” cookies.
• Browsing settings
The settings of each browser software are different: please refer to the menu of your browser software
for further explanation and appropriate settings.
Internet http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
Explorer™
Safari™ https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
Chrome™ http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
Firefox™ http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
Opera™ http://help.opera.com/Windows/10.20/fr/cookies.html
Warning: Any setting of your browser software regarding the acceptance or refusal of cookies may affect
your Internet experience and access to certain services requiring the use of cookies. If you choose to
refuse cookies in your terminal or if you delete cookies recorded in your terminal, OCTOPIA cannot
undertake any liability regarding the consequences related to degraded functioning of the services.
• Smartphone settings
IOS https://support.apple.com/fr-fr/HT201265
Android https://support.google.com/chrome/topic/3434352
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• Management cookies tool
The information banner relating to cookies, which appears at your first connection to the OCTOPIA
Solution and/or Website, informs you of the use of cookies. OCTOPIA uses a consent management
platform which allow the Website Users to configure their choices regarding deposit of cookies.
To access to the list of cookies used and configure your choices, please click on the consent management
platform of the OCTOPIA Solution and/or Website.
• Opposition list to cookies’ deposit
In order to block the collect and use of information about you by advertising companies that display
personalized advertising, you can access to the following sites :
• NAI : http://www.networkadvertising.org/choices/
• EDAA http://www.youronlinechoices.com/
• DAA : http://optout.aboutads.info/?c=2&lang=EN
8. REVIEW AND UPDATE OF THE PRIVACY POLICY
This privacy policy might be update as necessary to meet the requirements of applicable laws.
March 3rd, 2021
OCTOPIA’s DPO
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