COOKIES CHARTER OF PENTALOG

Updated on January 11th, 2021
 

PENTALOG FRANCE is a French simplified joint-stock company (SAS), registered at the Companies Register under the No. Orléans B 400 300 190, headquartered at Château des Hauts – 1 rue des Hauts, 45380 at La Chapelle-Saint-Mesmin. PENTALOG FRANCE SAS is the mother company of PENTALOG GROUP.

As a data controller, PENTALOG FRANCE SAS, attaches great importance to the respect and the protection of its users’ privacy.

This Cookies Charter applies to all PENTALOG FRANCE SAS websites and / or all of its subsidiaries (hereinafter referred to as "PENTALOG"), unless a subsidiary publishes its own Cookie Charter.

This Cookies charter governs their use and operation on the websites https://pentalog.com  et https://pentalog.fr , including all the websites of PENTALOG GROUP within the conditions aforementioned, hereafter referred jointly or separately as the “Site” and is therefore addressed to all persons who will browse the Site, hereinafter referred to as "User (s)".

1. What is a cookie?

1.1. The National Commission for Information Technology and Freedoms ("CNIL") describes the cookie as: "A small computer file, a plotter, deposited and read for instance when consulting a website, reading an email, installing or using software or a mobile application, regardless of the type of terminal used (computer, smartphone, e-reader, video game console connected to the Internet, etc.).

The term "cookie" covers for example:

  • HTTP cookies;
  • "flash" cookies;
  • any other identifier generated by software or an operating system (serial number, MAC address, unique terminal identifier (IDFV), or any set of data used to calculate a unique fingerprint of the terminal (for example via a method of "fingerprinting";
  • access to terminal information from APIs (LocalStorage, IndexedDB, advertising identifiers such as IDFA or Android ID, access to GPS, etc.)
  • invisible pixels or "web bugs";
  • any other identifier generated by software or an operating system, for example

1.2. The cookie is thus placed temporarily in the memory of the User’s terminal ("session" cookie) or stored permanently on the hard drive ("persistent" cookie), by a web page server. Cookies cannot run programs or introduce viruses to the terminal. Cookies are uniquely assigned and can only be read by a web server in the domain that sent them.

1.3. The cookies are attributed in a unique manner and can be read only by a web server of the domain which transmitted them.

 

2. What is the applicable law to the cookies?

PENTALOG relied on the latest CNIL publications which precisely describes the legal framework applicable to cookies.

Thus, the article 5 (3) of Directive 2002/58 / EC amended in 2009 lays down the principle on the use of cookies and this principle has been transposed into French law by Article 82 of the Data Protection Act. These provisions themselves refer to articles 4.11 and 7 of the General Data Protection Regulation (or "GDPR"). And the CNIL has:

  • adopted on September 17, 2020 some guidelines relating to the application of article 82 of the law of January 6, 1978 amended, for reading and writing operations in a user’s terminal (in particular to "cookies and other tracers" ) and repealing deliberation n ° 2019-093 of July 4, 2019,
  • supplemented by a recommendation proposing practical modalities of compliance in the event of recourse to "cookies and other tracers".

PENTALOG will adhere to these provisions of current law for the use of cookies on its Site.

3. Cookies and consent, what does the law say?

With regard to the law applicable to cookies, the CNIL distinguishes two types of cookies:

3.1.  Cookies exempted from User consent

According to the CNIL "These are cookies strictly necessary for the provision of an online communication service expressly requested by the user or the tracers which aim to allow or facilitate the transmission of communication by electronic means". These cookies “do not require consent” from Users.

These cookies are including:

  • cookies keeping the choice expressed by Users on the deposit of cookies;
  • cookies intended for authentication with a service, including those intended to ensure the security of the authentication mechanism, for example by limiting robotic or unexpected access attempts;
  • cookies intended to remember the content of a shopping cart on a merchant site or to invoice the user for the product (s) and / or service (s) purchased;
  • User interface personalization cookies (for example, for the choice of language or presentation of a service), when such personalization constitutes an intrinsic and expected element of the service;
  • cookies allowing load balancing of equipment contributing to a communication service;
  • cookies allowing paid sites to limit free access to a sample of content requested by Users (predefined quantity and / or over a limited period);
  • certain audience measurement cookies when they meet certain conditions.

When these cookies are used on its Site, PENTALOG will inform Users thereof.

3.2Cookies requiring the collection of the User’s consent

According to the CNIL, this type of cookies “may for example be linked to the display of personalized or non-personalized advertising (when cookies are used to measure the audience of the advertising displayed in the latter case) or to sharing features on social networks ”.

Without consent, the User consent, cookies cannot be placed and / or read on his terminal.

4. PENTALOG’s cookies and third-party’s cookies

4.1. PENTALOG thus collects and uses cookies when Users browse on its site regardless of the device used (computer, smartphone, e-reader, video game console connected to the Internet, smart TV, etc.). Cookies may also be placed for specific reasons (eg: chat solution from a subcontractor of PENTALOG on the Site).

4.2.  In addition to PENTALOG, third parties may indeed place cookies on the Users’ terminal, for example the partners of PENTALOG, advertising agencies and other data controllers.

4.3. In all transparency, PENTALOG will indicate the issuers of cookies concerned in order to keep Users informed.

5. The purposes of the cookies used by PENTALOG

In a transparent manner, Users are informed of all types of cookies that PENTALOG is likely to collect, use or operate whether with or without their consent.

5.1. Cookies for personalizing the browsing experience (optional cookies)

These cookies are intended to improve the User experience and facilitate their research by offering them products and offers related to their areas of interest. However, this type of cookies is not essential for navigation.

These may, for example, be cookies for displaying personalized banners outside our Site, a system of service recommendations (last subject viewed, suggested reading or product or service, etc.).

These cookies will be retained at least for visits to the User’s Site and at maximum for a period not exceeding that provided for by applicable law

5.2. Essential or functional cookies

These cookies which are strictly necessary for the operation of our Site and therefore cannot be disabled. Thus, Users’ consent is not required in accordance with 3.1. However, it remains possible to oppose it by modifying the settings of the browser used by the User via his platform (see article 7.). This opposition will lead to a degradation of the navigation experience.

These cookies will be retained at least for visits to the User’s Site and at maximum for a period not exceeding that provided for by applicable law

5.3. Session cookies (e.g. on SkillValue, MyPentalog, Pentastagiu)

These are temporary cookies, their purpose is to allow PENTALOG to determine whether a User (ex: a candidate on PentaStagiu, or a freelancer on SkillValue, or a prospect on MyPentalog)  has logged in to the website on into its account; or to display a name of a User when he is logged into its account.

These cookies will be retained at least for visits to the User’s Site and at maximum for a period not exceeding that provided for by applicable law.

5.4. Targeting cookies

These cookies are used to display targeted offers to the User when browsing on the Website as well as on another site. These cookies include also audience measurement cookies and their use allows PENTALOG to obtain statistics related the use of its Website.

PENTALOG has no power of action over these cookies which are managed by other companies. Indeed, only the issuer of a cookie can read or modify the information in this cookie.

Besides, our Website hosting advertising partners is likely to send them information related to products and services consulted by the User. If that is the case, these companies must undertake to keep this data confidential as part of the French Data Protection Act (January 6, 1978) and the European data protection regulations (GDPR).

This is the case of cookies used by Google Analytics.  

See https://support.google.com/analytics/answer/2763052?hl=en for more information.

These cookies are also offered by third parties so that the User can access certain services.

E.g.:

The use of this type of cookies requires the consent of the Users. These cookies will be retained for visits to the User’s Site for a period not exceeding that provided for by applicable law. 

5.5. Cookies declaration

PENTALOG provides Users with a precise list of cookies collected on its Site in the "Cookie declaration" chapter below. For each cookie, the list provides its name, its provider (when applicable), its purpose, its retention period and its type.

6. How does PENTALOG use cookies?

6.1.  Pentalog uses cookies in order to personalize and optimize Users’ browsing and online time. Thus, during their use of the Site, cookies may be placed on their terminal.

6.2. Before each deposit of cookies on the terminal, the prior consent of the User is required for cookies not exempt from consent. This consent request is made on a banner that clearly defines essential information to enlighten the user, namely:

  • the purposes of the use of cookies
  • means of opposition to the use of cookies

The consent obtained (by clicking on the "OK" button) from the User signifies their acceptance of the use of cookies in accordance with applicable law and this Charter. Thus, in case of refusal of the User, it will be possible for him to deactivate the cookies (only the optional cookies referred on article 3.1. and requiring the consent of the User) by clicking on "More options" and by checking or by unchecking the boxes corresponding to the types of cookies indicated. However, for certain types of third-party cookies, the User will have to rely on Article 7 below. 

6.3At any time, the User can consult the effective list of cookies collected during his navigation on the Site in the chapter "Cookies declaration" below. He can if he wishes, modify his consent (by clicking on "Change your consent") or withdraw it (by clicking on "Withdraw your consent").

7. What control does a User have over cookies?

7.1. All Users are free to accept or refuse cookies at any time by modifying the settings of their Web browser. However, if cookies are refused this can impair performance and negatively influence browsing of the website.

7.2. Most browsers are configured to accept cookies by default. However, Users can delete or refuse cookies in the browser settings regardless of the platform used. However, refusing cookies can obstruct performance and negatively influence the navigation of the Site.

7.3. For more information on how to control cookies, Users can check the settings of the browser used or the platform to find out how they can control or refuse cookies, or by visiting the following pages

8. Privacy Policy

This Cookie Policy is an integral part of our Privacy Policy available at https://www.pentalog.com/privacy. Acceptance of this Charter is acceptance of our Privacy Policy.

9. Amendment of the Charter on use of Cookies

9.1. PENTALOG reserves the right to amend its Cookies Charter at any time. PENTALOG shall publish all substantial amendments on its Website visibly, and they shall be applicable from publication of them.

 

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