Privacy policy

The purpose of this policy is to provide transparent information about the processing of personal data carried out by the Société Civile des Producteurs de Phonogrammes en France (SPPF). In the following, the term “You” or “Your” refers to any individual concerned by the processing described in this notice.

Why and how does the SPPF process your personal data?

Information relating to the processing of personal data carried out by the SPPF in its member areas is set out in their own respective privacy policies.

  • You are a prospective member

The SPPF may process your personal data for the purposes of managing your membership application.

The collection of information is limited to the personal data provided by the applicant during their online membership application, including, in particular : 

  • Your company’s identification number;
  • Proof of identity;
  • The certificate and form designating a natural person;
  • Your contact details;
  • Powers of attorney (mandates);
  • Declarations of phonograms and/or music video recordings;
  • Your bank details (IBAN);
  • Your contribution to the SPPF’s share capital
 
Failure to provide this data will make it impossible to submit your membership application to the SPPF’s Board of Directors. 
 
The legal basis for membership operations is the performance of pre-contractual measures with a view to entering into collective management agreements (mandatory and/or optional), and compliance with the provisions of the French Intellectual Property Code. 
 
Your personal data is processed by the various SPPF departments and may also be disclosed to other collective management organizations or to the competent authorities in connection with the defense of intellectual property rights. It may also be processed through tools provided by service providers (email and hosting providers). In this case, data transfers outside the EU may take place. The SPPF undertakes to transfer this data only under the standard contractual clauses adopted by the European Commission. 
 

Your personal data is retained for the duration of your relationship with the SPPF, extended by the applicable limitation period (five years, unless interrupted).

  • You are applying for a job or an internship

The SPPF may process your personal data for the purpose of managing recruitment operations (receiving applications, conducting interviews, making hiring decisions). It also maintains a CV database in order to build a pool of candidates.

The collection of your personal data is limited to your CV, cover letter and, where applicable, diplomas. The information you provide may be verified and supplemented with publicly available information (in particular on professional networks). Failure to provide this data will make it impossible to consider you for recruitment.

The legal basis for recruitment operations is the performance of pre-contractual measures with a view to entering into an employment contract. The lawfulness of maintaining a CV database is based on the SPPF’s legitimate interest in building a pool of skills to facilitate future recruitment.

Your personal data is processed internally (management and line manager). It may also be collected by recruitment agencies engaged by the SPPF.

Unless you are hired, your personal data is deleted no later than 2 years after our last contact.

For these operations, data transfers outside the EU may take place. The SPPF undertakes to transfer this data only under the standard contractual clauses adopted by the European Commission.

When you visit the SPPF website, the following cookies may be placed on your computer:

Category

Cookies

Description

Duration

Functional

PHPSESSID

Cookie required for the website to function properly.

For the duration of the session
 

IN_ASS

Session cookie for the “Member” portal. It allows your account settings to be retained.

120 days

Audience measurement

_pk_ses.XXXXX

Cookie used for the temporary storage of your visit data (if Matomo audience measurement is active).

30 minutes
 

_pk_id.XXXXX

Cookie used to store your unique visitor ID (if Matomo audience measurement is active).

13 months
 

GetLocalTimeZone

Cookie used to collect the host’s time zone.

For the duration of the session

Functional cookies allow the site’s services to operate optimally. These cookies are placed on the basis of the SPPF’s legitimate interest in being able to communicate clearly about its activities.

Audience measurement cookies are used to analyze web activity. They provide information on visitor numbers and traffic, and help to compile statistics to measure the site’s or page’s performance. These cookies are placed on the basis of the SPPF’s legitimate interest in measuring its site’s activity.

The SPPF may also process your data in order to respond to your requests. When you leave a comment on our site, the data entered in the comment form, as well as your IP address and your browser’s user agent, are collected to help detect spam comments. An anonymized string created from your email address (also known as a hash) may be sent to the Gravatar service to check whether you use it (https://automattic.com/privacy/). You will also be offered the option of saving your name, email address and website in cookies so that you do not have to re-enter this information the next time you leave a comment. These cookies expire after one year. After your comment is approved, your profile picture will be publicly visible next to your comment.

The SPPF provides buttons enabling you to follow us on social media (Twitter, Instagram, Facebook). These social networks place cookies when you log in on SPPF’s web pages.

Depending on their respective needs, all or part of this data may be shared with:

  • SPPF staff responsible for publishing content and the technical administration of the website;
  • SPPF staff responsible for processing requests received via the contact form;
  • SPPF’s IT department staff
 
  • You are a recipient of communications

The SPPF may process your data to keep you informed about its activities (communications, events and newsletters). This communication may also take place via social media.

These communications are sent using the Brevo email solution, a sub-processor engaged by the SPPF. Emails sent through this service contain a tracking pixel that measures their open rate. This pixel collects information such as the date and time the email was opened and the type of device used.

These operations are based on the SPPF’s legitimate interest in staying in contact with you. Where the open-rate measurement carried out using the tracking pixel is strictly limited to deliverability purposes (identifying inactive addresses, maintaining the mailing list), it is likewise based on the SPPF’s legitimate interest. However, where this measurement is intended to optimize our communication campaigns, personalize their content, or adjust their frequency, it is based on your prior consent, obtained when you subscribed to our communications. You may object at any time to processing related to the sending of communications, and in particular withdraw your consent to the tracking pixel or object to its use, by unsubscribing via the link provided in those communications, or by contacting the SPPF at dpo@sppf.com.

Depending on their respective needs, all or part of this data may be shared with staff responsible for communication activities, as well as with Brevo, our technical service provider for sending emails and measuring email audience.

For communication operations, data transfers outside the EU may take place. The SPPF undertakes to transfer this data only under the standard contractual clauses adopted by the European Commission.

What are your rights and how to exercise them?

Subject to due proof of your identity, you have the right to access, rectify, restrict, erase, object to the processing of your data, the right to define in advance guidelines on the processing of your data after your death, as well as the right to data portability, which you may exercise:

– by email to dpo@sppf.com;

– or by post to :

SPPF (Protection of personal data)

63, boulevard Haussmann – 75008 Paris (France)

You can update your data on the website www.sppf.com under “Member Access”.

You may file a complaint regarding the processing of your personal data with the French Data Protection Authority (Commission Nationale Informatique et Libertés -CNIL) – www.cnil.fr – 3 place de Fontenoy, 75007 Paris (www.cnil.fr/fr/cnil-direct/question/844).