In order to receive information about your Personal Data, the purposes and the parties the Data is shared with, contact the Owner.
Netino is NOT the Owner of the Personal Data. The Owner of the Personal Data is the company’ owner of the Facebook page. Netino act only as a Data Processor subcontractor of the Owner.
On the following the term:
- Client or Owner or Data Controller mean the Client of Netino who ask Netino to manage their Facebook page on behalf of them.
- Data Processor (or Netino) mean Netino who is not the owner of the Personnal Data, do not collect these data, and only receive a copy of the Personnal Data for the only purpose of doing the data processing that the Netino’s Client asked.
Owner and Data Controller
The Client of Netino.
Netino, 4 avenue de l’Opéra, 75001 Paris, France
Owner contact email: firstname.lastname@example.org
Property of the Personal Data
Personal Data stay the property of our Client so Netino is NOT the Owner of the data. Netino do not collect data. Netino only receive a copy of the Personal Data from the Client, or from Facebook, for the purpose of the data processing and follow the rules of the Client.
Purpose of the Facebook Application
Application is used by the Clients of Netino (business company). The purpose of the application is to help companies to manage their Facebook page: i.e moderate their pages to remove inappropriate contents and answer to user’s questions on their pages.
Application is not used by user but only by companies or employees of these companies.
Application is not used for Facebook user profile but only for Facebook company pages.
Purposes of the data processing and storing of Personal Data
Personal Data are only used for the purpose of the moderation.
They are NOT used for marketing or commercial action.
Personal Data are only stored by the Data Processor for the purpose of the data processing requested by our Client (the Owner).
Types of Data collected
The Owner does not provide a list of Personal Data types collected.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Mode and place of processing the Data
Methods of processing
The Owner and the Data Processor (Netino) takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, sub-contractor, mail carriers, hosting providers, IT companies) appointed, if necessary, as Sub-Data Processors by the Owner.
Legal basis of processing
The Owner and the Data Processor may process Personal Data relating to Users if one of the following applies:
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Personal Data are processed at the Data Processor operating offices and in any other places where the parties involved in the processing are located.
Personal Data are located and processed in Europe. Some limited and partial transfer outside of the European Union can take place for the purpose of the data processing.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Personal Data are usually kept available for 13 months.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Publish_pages & Publish_action & Manage_pages & Publish_action
This include the right to remove an inappropriate comment, publish a new comment/post on the Client’s page on behalf of the owner of the pages.
This include the right to read private message and post an answer to a private message on behalf of the owner of the pages.
The rights of Users & Access rights
Access right is managed by the Client who is the Owner not by Netino who is the Data Processor. Netino do not manage access right but if the Owner (our Client) receive a request from a User and if the Client ask Netino, the Personal Data of this user will be removed from the copy of the Personal Data that Netino host.
Users may exercise certain rights regarding their Data. They must ask the Owner for using this rights.
In particular, Users have the right to do the following:
- Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. But Users may not oppose to the reviewing of their comments for moderation purpose.
- Access their Data.Users have the right to learn if Data is being processed by the Owner & Data Processor, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner & Data Processor.
- Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.
Any request must be submitted to the Owner and not to the Data Processor. The Owner will transmit to the Data Processor the request and ask him to do the required action.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided on the Facebook page of the Owner. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Netino, the Data Processor do not manage the User rights.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services or the Facebook page of the Owner.
The User declares to be aware that the Owner or Data Processor may be required to reveal personal data upon request of public authorities.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information on the Facebook page of the Owner.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The means by which the Personal Data of the User is collected and processed.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).