Privacy policy
Head of organization Contact information :
Thomas KERJEAN, CEO Mailinblack
4 place Sadi-Carnot – 13002 Marseille, France
Tel : +33 4 88 60 07 80
Data Protection Officer (DPO) Contact Information: PINT Avocats
297 AV du Mistral – 13600 La Ciotat, France
Tel : +33 4 42 70 07 03
As of 20/04/2023
MAILINBLACK is committed to protecting the privacy of its Internet users. The purpose of this Privacy Policy is to inform and present to customers, Internet users and candidates the manner in which MAILINBLACK handles personal data collected in its capacity as data controller within the framework of the use of its website and its various solutions.
The contact details of MAILINBLACK are listed in the legal notice.
For the purposes of this Privacy Policy, we have defined the following terms:
- Co-contractor: means the customers, partners, resellers and suppliers of MAILINBLACK with whom MAILINBLACK has signed a contract.
- Internet user: indicates all the people navigating on the present Internet website published by MAILINBLACK.
- Prospects: refers to all potential and current customers, partners, retailers and suppliers of MAILINBLACK.
- Candidate: refers to persons wishing to apply for a job or internship offer published by MAILINBLACK or via a spontaneous application
1. Description of the processing operations: which personal data processing operations and why?
– Personal data concerning the Co-contractors collected during the conclusion and execution of a contract
MAILINBLACK collects and processes the personal data of the Co-contractor (his legal representative and contact persons) for the conclusion and execution of the contract as follows
| Subject matter of the processing | Conclusion and execution of the contract | |
| Personal data collected | Civility, first and last name; job title; business contact information (address, email address, phone number); support tickets, history of requests, exchanges on the help center, comments from sales representatives related to the follow-up of the commercial relationship | |
| Purposes of the processing | Management of contracts and co-contractors: contracts, orders, deliveries, invoices, accounting, management of customer accounts, requests, follow-up of the customer or supplier relationship, management of requests and complaints, technical support and exchanges on the help center |
Data retention for accounting and tax purposes Retention of data for evidentiary purposes (for the exercise or defense of legal rights) |
| Legal basis | Execution of the contract |
Invoices: legal obligations (accounting and tax) Other data kept for evidentiary purposes: legitimate interests of MAILINBLACK for the exercise or defense of its legal rights |
| Retention and archiving period | Retention during the term of the contract | Archiving for a period of 5 years from the end of the relationship and 10 years for invoices |
The compulsory or optional nature of the data input is specified at the time of collection. The compulsory communication of certain personal data has a contractual character and is necessary to MAILINBLACK to implement the purposes above specified.
– Personal data collected for prospecting purposes
MAILINBLACK collects and processes the personal data of its Prospects (the legal representative and the contact persons) as follows
| Subject matter of the processing | Prospection |
| Personal data collected |
Civility, name, first name, phone number, function, email address (collected by MAILINBLACK or the reseller) Billing address, job title, Linkedin profile, Linkedin URL, address, postal code, city. Information requests and exchanges Response to the “Request a Quote” / “Get a Demo” forms Answer to the form “Become a Reseller |
| Purposes of the processing |
Sending information or promotional emails Creation of a contact file Management of information requests, particularly those sent via forms, and follow-up of the relationship Recontacting the Prospect Carrying out statistical studies on Prospects and Co-contractors |
| Legal basis | Legitimate interests of MAILINBLACK within the framework of its commercial activity and prospecting |
| Retention period | Retention for 3 years from the last contact from the Prospect unless the Prospect objects.. |
The compulsory or optional nature of the data entry is specified at the time of collection. The compulsory communication of certain personal data is necessary to MAILINBLACK to implement the above-mentioned purposes.
– Personal data concerning the Internet user collected through cookies and tracers
Data concerning the Internet user may be collected by means of cookies and tracers used on this website published by MAILINBLACK under the conditions explained here.
– Personal data about the Candidate collected when sending an application
MAILINBLACK collects and processes personal data about Candidates as follows:
| Subject matter of the processing | Sending an application or responding to a job offer | ||
| Personal data collected |
Name and surname, business or personal contact data, address, telephone number, email address, work-related data (CV, qualifications); Professional data, e.g. date and place of birth or family situation (optional); Target position, message |
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| Purposes of the processing | Search for relevant profiles (spontaneous application and response to a job offer) | Management of recruitment procedures in conjunction with the hierarchies of the Candidates to be recruited: reception and registration of applications sent to MAILINBLACK, pre-selection of Candidates, sorting and classification of CVs and cover letters, replies to Candidates for a job or an internship, completion of compulsory formalities and completion of the administrative file of successful candidates | Enrich the MAILINBLACK CV library with the agreement of the Candidate. |
| Legal basis | Legitimate interests of MAILINBLACK in the context of its recruitment activity |
Legitimate interests of MAILINBLACK in the context of its recruitment activity Execution of pre-contractual measures taken at the request of the Candidate (if the Candidate is selected) |
Candidate’s Consent |
| Retention and archiving period |
The data is kept for the time necessary to complete the recruitment process. Successful candidate: The data will be integrated into the candidate’s administrative file and kept for the applicable retention period (up to 5 years after the end of the employment relationship) Data of the unsuccessful Candidate who does not want his or her data to be kept in the MAILINBLACK CV library: 3 months after MAILINBLACK’s decision to refuse Data of the unsuccessful Candidate wishing to have his/her data kept in the MAILINBLACK CV library: 2 years from the last contact The data concerning the candidates may be kept in an intermediate archive for evidentiary purposes in order to protect against possible actions for discrimination, for a period of 5 years from the end of the recruitment process. |
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The data listed above is mandatory because it is necessary for MAILINBLACK to implement the above-mentioned purposes.
2. Recipients of personal data
Person in charge of the treatment: the person in charge of the treatment of these data is the company MAILINBLACK, whose complete coordinates appear in the legal mentions of the Internet site.
Recipients: In compliance with the purposes set forth above, the personal data of the Co-contractor, Prospect or Internet user may be communicated to MAILINBLACK personnel in charge of commercial management and to MAILINBLACK’s technical suppliers acting as subcontractors (host, messaging provider, chat, management tools and marketing service providers), and if necessary, to its consultants.
With respect to Candidates, in compliance with the purposes set forth above, personal data may be communicated to MAILINBLACK personnel in charge of recruitment and, where applicable, to the manager of the position in question, and to MAILINBLACK’s technical suppliers acting as subcontractors (host, e-mail provider, recruitment management tool), and, where applicable, to its consultants.
In the event of a positive outcome to the recruitment process, in order to finalize the recruitment, the human resources department will be required to transmit some of the information collected to the organizations informed of the hiring (in particular, unemployment insurance, health insurance, retirement, mutual insurance).
Data may be transferred outside the European Union by MAILINBLACK’s subcontractors. They are based on an adequate level of protection or sufficient guarantees, in particular the European Union’s standard contractual clauses of June 4, 2021 (documents available upon written request to MAILINBLACK).
3. Rights of the Co-contractor, prospect, Internet user and Candidate on their personal data
The persons whose data are collected by MAILINBLACK have at any time, the following rights on their personal data:
- Right of access: to obtain confirmation of the processing of his/her personal data as well as a certain amount of information on the processing, it being understood that this information is in any case given in the present personal data protection policy ;
- Right of rectification: obtain the rectification of his personal data when they are inaccurate or incomplete;
- Right to erasure (“right to be forgotten”): obtain the erasure of personal data when they are no longer necessary for the purposes for which they were collected or in case of opposition to the processing of their personal data. The right to erasure is not enforceable in the cases provided for in Article 17.3 of the GDPR. In particular, this right is not available as long as the Co-contractor, the Internet user or the Candidate wishes to use the solution and benefit from the services subscribed to, these personal data being necessary to MAILINBLACK for the management of the contract and the provision of the service.
- Right to the limitation of the processing: to obtain the limitation of the processing of one’s personal data in particular in case of dispute of the accuracy of the data, when the period of conservation of the data has come to an end but the person whose data are processed still needs to keep these personal data for the establishment, the exercise or the defense of a right in justice;
- Right to portability: to obtain the communication of personal data communicated to MAILINBLACK in a readable format, or to ask MAILINBLACK to transmit the communicated personal data to another data controller;
- Right of opposition: to oppose at any time, for reasons relating to his personal situation, the processing of his personal data based on the legitimate interests of MAILINBLACK, except for compelling reasons of MAILINBLACK;
- Right to withdraw consent: withdraw consent for data processing based on it, with the withdrawal of consent being applicable for the future;
- Right to lodge a complaint: lodge a complaint with the Commission Nationale de l’Informatique et des Libertés if the person whose data is processed considers that the processing carried out by MAILINBLACK constitutes a violation of his/her personal data;
- Right to define the directives concerning the fate of his personal data after his death.
These rights can be exercised at any time with MAILINBLACK:
- By email at the following address: dpo@mailinblack.com
- By post at the following address: 4 Place Sadi Carnot – 13002 Marseille – France
- Our data protection officer : PINT Avocats – dpo@mailinblack.com