The mission of Le Télégramme is to inform its readers daily about local life using all existing and future information media: website, mobile application, tablet application, watch or television…
Le Télégramme is concerned about the protection and confidentiality of personal data and is committed to ensuring the best level of protection for your personal data in accordance with current regulations on the protection of personal data, applicable in Europe (GDPR) and in France.
The purpose of this privacy policy is to inform you about the practical measures and commitments taken by Le Télégramme to ensure the respect and protection of your personal data when using our services.
It applies to all services (web applications, mobile applications, connection services, etc.) published and provided by Le Télégramme from the various Sites and Applications.
It concerns all visitors to our Sites and users of our Services (“Users”).
The terms “we” and “us” refer to Le Télégramme and the Services we provide.
The terms “You” and “your” refer to all Subscribers and Users of our Services or visitors to our Sites or Applications. The term “Partners” defines our professional partners (these are partner organizations through which we can provide comprehensive information and appropriate information). For any further details on the definitions of capitalized terms, you can refer to our current T&Cs.
1 – Identity of the data controller
Le Télégramme, a simplified joint-stock company with capital of €7,573,303, whose registered office is located at 7 voie d’Accès au Port, 29600 MORLAIX, registered with the BREST Trade and Companies Register under number B 423 754 241, represented by Edouard COUDURIER. Le Télégramme acts as data controller.
Le Télégramme acts as joint controller of 366 SAS for processing related to the marketing of digital advertising space on this website and the mobile application. Joint responsibility has been defined in accordance with Article 26 of the GDPR.
2 – Purpose of processing and legal basis
The processing implemented by Le Télégramme meets explicit, legitimate and specific purposes.
Contact
Our Services allow you to be put in touch with our Partners, the list of which is available on request from the DPO: [email protected]
Depending on the Services and Applications you use, we use your data to suggest to you and others, opportunities offered by our Partners (geolocalized information, promotion and contextual advertising) and more generally information related to your interests.
Advertising Display
We also process, with your permission, your data in order to offer advertisements and articles tailored to your interests.
For example, we use this data to offer you articles or advertisements about businesses located near you. This is also how we target our mobile notifications.
At any time, you can unsubscribe from alerts by clicking on the link in the message received or unchecking the corresponding box in your personal space.
Email campaign management
The processing we do of your data allows us to know you better, to recommend Services targeted to your needs or corresponding to previous requests to be put in contact with our Partners and thus to improve the effectiveness of our Applications and Services to better satisfy you.
We can therefore offer you Newsletters so that you are regularly informed about certain thematic or local sections.
You can unsubscribe from these Services at any time by clicking on the link in the message received or unchecking the corresponding box in your personal space.
Offering a high-performance range of services
We also use your data to develop or upgrade new services that may better meet your needs. These services are part of the purpose of our personal data processing, namely the continuous improvement of our digital information media.
Better understand your expectations regarding reading our articles or using our Services.
Your responses to our surveys, when you choose to respond, allow us to collect quantitative or qualitative information in our field of activity in order to produce anonymized statistical elements on reading habits or the services used or expected.
We may also take your responses into account in order to improve the operation of our Applications and Sites but also the quality of the paper newspaper and the services related to it (delivery, reception).
Creation of new services
If we carry out further processing of your data for purposes other than those described in our privacy policy, we will inform you. These new purposes will be compatible with the purposes described here and, failing that, we will seek your consent.
No personal data concerning you is transmitted to our Partners without your consent.
Personalized advertising
The processing for which Le Télégramme and 366 act as joint controllers is identified by an asterisk (*).
Display advertisements to visitors to the Le Télégramme website based on their browsing habits, interests, sections visited, and sites visited using the same service providers (retargeting).
- Selection and optimization of advertising campaign sales by our advertising agency (366)*.
- Creation of segments and profiles by our advertising agency (366)*.
- Implementation of the advertising call by our advertising agency (366)*.
- Generation of a unique identifier by our advertising agency (366), assigned on publisher sites*.
- Campaign tracking and statistics by our advertising agency (366)*.
- Ensure security, prevent fraud, and debug, technically deliver ads or content through our advertising network (366)*.
- Setting up tracking in affiliate links to establish a commission.
3 – Data Collected
Le Télégramme ensures that it only processes personal data that is strictly necessary for the purposes detailed above. In addition to the information necessary for establishing contact (such as your first and last name, email address, etc.), only information useful for improving your reader experience will be collected and processed.
The data you provide to us
The data we process is first of all the data you provide to us via our subscription forms.
This is your identification data and contact data that allows us to deliver the newspaper to you, to invoice our services or to operate the sites and mobile applications (for example by displaying your first and last name in your reactions to articles).
The mandatory nature of the data collected is notified to you at the time of collection by a message. Providing certain data is mandatory only when it is necessary for us to process your request or required by our Partners to respond appropriately to your request.
If the mandatory data is not provided, we will not be able to provide you with the Service you require.
Please note that our services are all the more effective if you regularly provide and update your information, particularly when it comes to changes of address or contact details.
We take care not to collect or transmit to our Partners data that is not necessary for them to process your requests or refine their selection of relevant profiles.
In some cases, you will be redirected directly to the website of our Partners with whom you will interact directly. You will then have to review and accept (where required) the Partner’s provisions relating to personal data prior to validating your connection. In this case, Le Télégramme is not responsible for the processing of personal data that will be subsequently carried out by the Partner in its capacity as data controller.
We undertake never to ask for so-called sensitive information (racial or ethnic information, political opinions, religious or philosophical opinions, trade union membership, health, sexual orientation).
Personal data of minor children
Le Télégramme refuses to collect data from minor children. In the event of a Member lying about their date of birth and more particularly in the event of fraudulent certification of their majority, the parents of the minor child are invited to notify Le Télégramme by sending an email to [email protected] , in order to request the deletion of the data. Le Télégramme undertakes to delete all personal data concerning the minor child as soon as possible.
Usage data of our services
We also establish your profile based on your use and navigation on our Sites and our Applications.
This includes the IP address or connection devices used, your browsing data, Cookie data (see Cookies section below), the number of our page views, the number of visits to our Sites and applications, as well as visitor activity on them and their frequency of return (see Third-party Data section below).
Third-party data
We receive personal data about you when you use our Partners’ services or your consent to the use of certain cookies.
Our goal is to better understand how our Sites and applications are used and to measure our audience and the effectiveness of our Services in order to best adapt them to your needs.
We do not collect any third-party data that you may write or post on third-party partner sites. We also do not collect any comments that third parties may make about you on partner platforms.
4 — Utilization of UTIQ technology
Utiq technology is provided by Utiq SA/NV, a European company. It is designed to protect your personal data by giving you choice and control, while facilitating online activities on websites like ours.
Utiq works with partner telecom operators (see the list here ) who help make the technology work.
Utiq technology can only be activated if you are using a compatible internet connection (1) provided by a telecom operator listed below, in the countries where our technology is available.
(1)Compatible internet connection: In some countries where we operate, Utiq technology can only be activated on mobile connections, while in other countries it also works on home connections (e.g. Wi-Fi).
Please find here the list of compatible internet connections by country and by partner telecom operators.
This technology is disabled by default. It can only be enabled if you consent and are using a compatible internet connection provided by one of our partner telecom operators.
We, Le Télégramme, and our advertising agency 366 (the joint data controllers) use Utiq technology on our websites and the French regional daily press websites operated by companies in the 366 group.
When you consent to its activation, Utiq provides us with marketing identifiers. They help us understand your browsing habits and link your visits to our websites (only those for which you consent to the use of Utiq technology).
We use them for our digital activities, such as personalizing advertising or content and analytics on our websites using Utiq technology and subject to your consent. These identifiers are also shared with our advertising platforms when necessary for our marketing and analytics activities.
If you enable Utiq technology on our websites (list available on the “Manage Utiq” pages of each of our websites), we may use it to understand your browsing habits on these sites (those for which you have given your consent).
Utiq technology is linked to the internet connection.
Therefore, all people using the same connection and who have consented will be assigned the same identifier. In general:
- For a household connection (e.g. Wi-Fi), personalization will be based on the browsing of household members who have consented.
- For a mobile connection, personalization will be based solely on the mobile owner’s browsing.
We, Le Télégramme, and our advertising agency 366, act as joint controllers with Utiq for certain processing steps. Under our joint controller agreement:
- We collect your consent to activate Utiq technology, which includes the data processing carried out by Utiq and your telecom operator for the purpose of this activation.
- We provide a dedicated link at the bottom of each of our websites (“Manage Utiq”) to provide you with information about the technology and controls available to you.
- Utiq provides you with a portal (“ consenthub ”) to facilitate the exercise of your data protection rights and allow you to easily manage Utiq consents. At any time. In one place.
- Although you may exercise your rights with respect to each of the data controllers, Utiq remains the primary point of contact for any questions or requests you may have in relation to Utiq technology.
You can revoke Utiq consents (2) in various ways:
- On the consenthub: To revoke all Utiq consents on all websites using Utiq technology, go to the Utiq portal (“ consenthub ”)
- On partner websites: You can revoke each Utiq consent on the websites where you have given it, by visiting the “Manage Utiq” page accessible at the bottom of each website.
Utiq technology is based on your internet connection. Therefore, if you use other connections, you will need to manage consents on each connection separately.
Alternatively, you always have the option to delete your browsing history and data via your browser settings. This will remove all your Utiq consents from your browser. All your data stored in the Utiq platform will also be deleted within the period indicated in the Utiq Privacy Policy .
For more information, please consult the Utiq Privacy Policy .
(2) This includes Utiq consents given by you, but also, in the case of a shared internet connection, those given by members of your household.
5 – Recipients of the data collected
Your personal data is only used by identified and authorized persons taking into account the purposes described in this personal data protection policy.
Le Télégramme undertakes never to transmit your personal data to third parties for reasons unrelated to these purposes.
Therefore, your data is only transmitted to the categories of people listed below:
- Our Partners if and only if you have asked us to
We systematically inform you of this transfer by the means of communication you have chosen;
- Telegram authorized services (technical implementation team, customer relations monitoring team)
- Our technical service providers: hosting, unformatted data extraction service, email sending service, IT audit and security provider
We draw your attention to the use of social media buttons such as “Log in via…”. Using these buttons simplifies the entry of your data to fill out a form in some cases. This is a convenience offered.
Using these buttons may result in the collection of personal data by the social networks concerned even before Le Télégramme has collected your personal data.
You are invited to configure access and confidentiality of your data directly on the social networks used.
Use of these social media buttons is at your own initiative and under your sole responsibility. Le Télégramme is not responsible for the processing of your data by these third-party social media networks.
6 – Communication
Depending on the Services used or your preferences, we will contact you by email, by publications on our Sites or Applications, by SMS, instant messaging, push notifications or by any other means of communication that you have sent to us.
7 – Security of Collected Data
All collected data is processed in a manner that ensures appropriate security, which translates into a logical and physical security policy and security measures specifically adapted to our activities. Various audits are carried out within our infrastructures.
Telegram’s technical teams are aware of the GDPR and consideration of personal data protection is omnipresent during the design and operation of sites and applications.
Thus, the following principles govern the development of sites and applications, both at the technical infrastructure level (secure redundant hosting, security and access control policy), and from an application point of view (development of sites and applications):
- Secure data collection
- Storage ensuring data integrity and confidentiality
- Securing development environments
- Securing data access
- Regular training for our technical teams
- Voluntary limitation of subcontracting (infrastructure, services and development) and intervention on anonymized test data sets
We process personal data within secure infrastructures located in the European Union. Our applications are subject to regular audits to ensure a high level of security.
8 – Data retention
Your data is retained for a maximum of 3 years from the last date of interaction with our services.
The data is then anonymized and can be used for statistical purposes.