The mission of Le Télégramme is to inform its readers on a daily basis about local life using all existing and future information media: website, mobile application, tablet application, watch or television, etc.
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 the regulations in force on the protection of personal data, applicable in Europe (GDPR) and in France.
This privacy policy aims 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 “our” 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 complete information and appropriate information elements). For any other details on the definitions of terms in capital letters, 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 in 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 regarding the processing related to the marketing of digital advertising spaces on this website and the mobile application. Joint responsibility has been framed 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 contact with our Partners, the list of which is available on request from the DPO: dpo@letelegramme.fr
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 offer you articles or advertisements on businesses located near you thanks to this data. This is also how we direct 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.
Management of email campaigns
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 can be regularly informed about certain thematic or local topics.
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 to them, 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 operations for which Le Télégramme and 366 act as joint controllers are identified by an asterisk (*).
Display advertisements to visitors to the Le Télégramme website based on their browsing habits, interests, sections visited, 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 the connection (such as your first and last name, email address, etc.), only information that is 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 your contact data allowing 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 on your reactions to articles).
The mandatory nature of the data collected is indicated to you during 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 want.
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 they do not need to process your requests or refine their selection of relevant profiles.
In some cases, you will be redirected directly to the site of our Partners with whom you will interact directly. You will then have to consult and accept (when required) the provisions of the Partner relating to personal data prior to the validation of your connection. In this case, Le Télégramme is not responsible for the processing of personal data that will be carried out subsequently by the Partner in its capacity as data controller.
We undertake to never ask for so-called sensitive information (racial or ethnic information, political opinions, religious or philosophical opinions, union membership, health, sexual orientation).
Personal data of minor children
Le Télégramme refuses to collect data of minor children. In the event of a lie by a Member concerning his/her date of birth and more particularly in the event of fraudulent certification of his/her majority, the parents of the minor child are invited to notify Le Télégramme by sending an email to dpo@letelegramme.fr , 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 the services of our Partners 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 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 is only enabled 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 activated if you consent to it and you use a compatible internet connection provided by one of the 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 sites operated by companies of 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 the personalization of 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.
Thus, all people using the same connection and having 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, the personalization will be based solely on the navigation of the mobile owner.
We, Le Télégramme and our advertising agency 366 act as joint data controller 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 to 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: where 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. So, if you use other connections, you will have 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 the Utiq consents you have given, 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
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…”. In some cases, using these buttons simplifies the entry of your data to complete a form. This is a convenience offered.
The use of these buttons may result in the collection of personal data by the social networks concerned even before Le Télégramme has collected your personal data.
We invite you to configure access and confidentiality of your data directly on the social networks used.
The use of these “social network” buttons is done at your initiative and under your full responsibility. Le Télégramme is not responsible for the processing of your data that will be done by these third-party social 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 Data Collected
All data collected is processed in such a way as to ensure 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.
The Télégramme’s technical teams are aware of the GDPR and consideration of the protection of personal data is omnipresent at the time of 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.
Data categories | Purposes | Retention periods |
Data relating to a prospect | ||
Data set | Creation and management of a prospect file | 3 years from the collection of data or the last contact from the prospect |
Data relating to an active customer | ||
Data set | Customer account management | For the entire duration of the contractual relationship |
Data relating to an inactive customer | ||
Data relating to the execution of the contract | Management of customer accounts, subscriptions, porting, invoicing, payments. | 10 years after the end of the contract or the last contact from the inactive customer |
Identification and contact data – Paper client | Sending information about the development of our publication and our offers | 3 years after the end of the contract or the last contact from the inactive customer |
Identification data – Digital subscribers | Sending information about the development of our publication and our offers | 3 years after the end of the contract or the last contact from the inactive customer |
Identification and contact data – Newsletter subscribers | Sending information on the development of our publications and our offers | 3 years from unsubscription or last contact from the customer |
Identification and contact data – Digital registrants | Sending information on the development of our publications and our offers | 3 years from unsubscription or last contact from the customer |
Data generated by tracers | ||
Data relating to your browsing on the Télégramme online services online | Operation and optimization of services Attendance measurements. Personalization of content and advertisements | 13 months maximum |
9 – Your rights
In application of the regulation, you have a right of access, rectification, deletion, opposition and a right to portability relating to all data concerning you.
You also have the right to limit the processing of your personal data. Every person also has the right not to be subject to individual decision-making based exclusively on automated processing such as profiling. If you have consented to the processing of personal data, you can withdraw your consent at any time.
For example, you are free to update or remove at any time the data you submitted when you registered on the site.
These rights can be exercised with the Data Protection Officer by post or email accompanied by a copy of your identity document to the following addresses:
- by email: dpo@letelegramme.fr
- by mail: Le Télégramme – Data Protection Officer – 7, port access road – 29672 Morlaix cedex
You also have the right to define guidelines regarding the fate of your personal data in the event of death.
You have the right to lodge an appeal with the National Commission for Information Technology and Civil Liberties (CNIL).
10 – Contact
For all requests for information concerning the personal data protection policy implemented by Le Télégramme, you can contact the Data Protection Officer – 7, voie d’accès au port – 29672 Morlaix cedex
11 – Tracer management policy
For the sake of clarity, we specify how our Telegram Sites and applications use cookies.
We do not use any third-party cookies that are unrelated to the purposes pursued by our Sites and Applications. Our job is to inform you on a daily basis and we do not use your visits to promote third parties outside of these purposes. Our Site is only a place for information and discussion on the lives of Bretons in particular and on national and international news in general.
When you browse our site, cookies are placed on your computer, tablet or smartphone. The information below will help you better understand how cookies work and how to use current tools to configure them.
What is a cookie?
Cookies are commonly used on the Internet. A cookie is a small text file containing information that is stored on your device (e.g. computer, tablet or mobile phone) and that allows you to benefit from a better user experience. We use two types of cookies: persistent cookies and session cookies. A persistent cookie allows us to identify you as an existing user so that you can return or consult our Services without having to re-enter your identifier. Once logged in, a persistent cookie remains in your browser and will be read when you return to one of our Sites. Session cookies only exist for the duration of the session (usually the duration of a website visit or browser session).
What are our cookies used for?
The cookies we issue are used to:
- Recognize your browser from visit to visit to remember your preferences
- Help us personalize the content and advertisements presented to you while you are visiting the site
- Measure your activity on the site across the board and thus enable us to offer an experience that is always better adapted to readers’ expectations.
Functional cookies (mandatory)
These cookies ensure the proper functioning of the Le Télégramme website and enable its optimization. The website cannot function properly without these cookies. Some cookies are also placed for the display and counting of non-personalized contextual advertisements.
Targeting cookies
We may use cookies to display targeted offers both on our applications and outside of them when you browse another Site. A cookie can also be used to know if after having seen content on our sites and applications, a User has subsequently visited our Partner’s site (and for example filled out a form). The purpose of this cookie is to measure our audience and to offer targeted ads from our Partner either by visiting our Sites and applications or by having visited them.
Similarly, our partners may use a cookie to determine whether we have displayed an ad, to know its performance, or to give us more details about your interaction with the content (for example the ad) on which the Cookie was placed. You can find all our partners via the “Our cookies” tab in the left menu.
How to manage cookies?
There are several options available to you for managing cookies. Any settings you may make may change your Internet browsing and your access conditions to certain services requiring the use of Cookies. You can choose at any time to express and modify your wishes regarding cookies, by the means described below.
- Setting up your browser
Change my cookie settings
For Chrome: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
For Internet Explorer: https://windows.microsoft.com/en-US/windows-vista/Block-or-allow-Cookies
Pour FireFox : https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent?redirectlocale=fr&redirectslug=G%C3%A9rer+les+cookies
For Opera: http://help.opera.com/Windows/10.20/en/cookies.html
- Opt-out links for audience measurement cookies (statistics)
For cookies placed by Piano Analytics: https://www.letelegramme.fr/opt-out/
Audience segmentation cookies are used to measure site traffic, but also to offer you content that matches your reading habits. By cutting these cookies, you prevent certain parts of the site from functioning normally.
- Opt-out links for sharing cookies
For cookies placed by Facebook: https://fr-fr.facebook.com/help/cookies
For cookies placed by Twitter: https://support.twitter.com/articles/20170518-utilisation-des-cookies-et-des-technologies-similaires-par-twitter
For more information on cookies, you can visit the CNIL website at this address: https://www.cnil.fr/vos-droits/vos-traces/les-cookies/
12 – Moderation of social networks Le Télégramme
Social media moderation is carried out by the service provider Bodyguard. It analyzes, moderates, deletes or hides the content and potentially the personal data available during your interactions on Le Télégramme social media.
The personal data that may be processed are as follows: content and identification data, such as the name, first name, user name and unique identification number of people consulting Le Télégramme’s social networks, as well as personal data contained in the content and/or comments published.
The data is kept for the entire duration of the service.
Technical and organizational measures have been implemented by Bodyguard to ensure the protection of personal data.
GDPR rights are mentioned in Article 8 hereof.
13 – VCP Sponsorship
The information collected in the VCP sponsorship form is recorded in a computerized file by Le Télégramme. Personal data will be processed in accordance with the following purposes:
- Receive, organize and process sponsorships (legal basis: consent collected by the subscriber);
- Contact sponsored persons to ensure that they meet the criteria to be a VCP (legal basis: contract);
- Ensure monitoring of the VCP service (legal basis: contract);
- Send the gift voucher to the subscriber if applicable (legal basis: contract).
Data marked with an asterisk in the questionnaire must be provided. Otherwise, the VCP sponsorship form will not be valid. The data collected will be communicated to the marketing and sales department of Le Télégramme.
The data is kept for the duration of the processing of the forms and for the 4 weeks of activity of the sponsored VCP. At the end of this time, the VCP data will be kept for its period of activity and in accordance with legal obligations. The subscriber’s data will be kept for the period of his subscription and in accordance with legal obligations.
The subscriber must obtain the explicit and prior consent of the sponsored person before sending the form.
Data subjects may rectify, request erasure, exercise the right to limit processing, withdraw consent to data processing at any time at the following address: dpo@letelegramme.fr . If you believe, after contacting Le Télégramme, that your Data Protection rights have not been respected, you can file a complaint with the CNIL.
14 – Affiliate links and data processing
An affiliate link is a link to a website that has been encoded with a tracking cookie. These cookies allow us to know how you arrived on our Site, and if you made a purchase there after clicking on a link from one of our partners. They also allow us to be able to remunerate them, if purchases were made thanks to them.
Cookies will be stored for a maximum period of 13 months. You can change your consent at any time by clicking on “Manage cookies” at the bottom of this site.
14.1 – Third-party site affiliate links on the site www.letelegramme.fr
Some links integrated on this website are affiliate links. By clicking on the link you accept the deposit of cookies. Le Télégramme, the digital marketing agency and the advertisers are jointly responsible for the processing of your personal data when you click on an affiliate link. The digital marketing agency and the advertiser will process your personal data in the event of a purchase on the advertiser’s website.
The list of digital marketing agencies is: Effinity, Amazon, Awin, Kwanko.
14.2 – Affiliate links from third-party sites redirecting to the site www.letelegramme.fr
Some links on affiliate websites are affiliate links and may redirect you to this website. By clicking on the link you agree to the deposit of cookies.
Le Télégramme, the digital marketing agency and the advertisers are jointly responsible for the processing of your personal data when you click on an affiliate link. The digital marketing agency and Le Télégramme will process your personal data in the event of a purchase on this website.
The list of digital marketing agencies is: Effinity.
15 – Update of the data protection policy
Our privacy policy may be modified or amended at any time.