Privacy policy

1Data Controller

The website lilie.fr and the CANBUILD platform (together, the “Services”) are operated by CANBUILD, a sole proprietorship operated by Clément Andrieu (SIREN 893 329 409, 54 rue d’Hautpoul, 75019 Paris) (“CANBUILD”, “we”, “us” or “our”).

For personal data processing for which CANBUILD determines the purposes and means of processing, CANBUILD acts as the data controller within the meaning of applicable data-protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Contact: hello [at] lilie.fr

For data protection requests relating to CANBUILD’s own processing activities, you may also contact:
Data Protection Contact: dpo [at] lilie.fr

Certain personal data processed through the CANBUILD platform is processed by CANBUILD on behalf of a Client. In those circumstances, the Client may act as the data controller and CANBUILD as its processor. Such processing is governed by the applicable agreement and Data Processing Agreement (“DPA”) between the Client and CANBUILD.

This Privacy Policy primarily describes processing activities for which CANBUILD acts as a controller. It does not replace or override any privacy notice, information or instructions provided by a Client in relation to processing for which that Client is the controller.

2Scope of this Privacy Policy

This Privacy Policy applies to personal data processed in connection with:

• the lilie.fr website;
• the CANBUILD platform;
• user accounts and authentication;
• platform administration and security;
• customer, participant and business contacts;
• support and communications;
• billing and contractual administration, where applicable; and
• other services or interactions that expressly refer to this Privacy Policy.

CANBUILD may process different categories of personal data depending on the relationship with the individual and how the Services are used.

3Categories of Personal Data

Depending on the circumstances, CANBUILD may process the following categories of personal data:

3.1Account and identification data

• Name and surname;
• Username or user identifier;
• Email address;
• Organisation or company name;
• Role or permissions within the platform;
• Account status.

Each user account is attached to an organisation (Client, Advertiser or Publisher).

3.2Authentication and security data

• Authentication information;
• Two-factor authentication (“2FA”) configuration and related security information;
• Login and authentication timestamps;
• IP addresses;
• Security logs;
• Information relating to access permissions;
• Records of security events and authentication attempts;
• Records of acceptance of the platform Terms of Use (user, date and time, version accepted).

CANBUILD does not store users’ passwords in readable form.

3.3Technical and usage data

Depending on the Services used, this may include:

• IP address;
• Browser and device information;
• Operating system;
• Technical identifiers;
• Connection information;
• Pages or platform functions accessed;
• Dates and times of access;
• Actions performed within the platform, including records of file imports and result downloads (user, date and time, file concerned);
• Error and diagnostic information.

3.4Business and contractual information

Where relevant, CANBUILD may process:

• Contact details of representatives of Clients, Publishers, Advertisers and other business partners;
• Company and organisational information;
• Contractual information;
• Subscription and service information;
• Billing and payment information where applicable;
• Communications and correspondence with CANBUILD.

3.5Pseudonymised email identifiers processed through campaigns

The CANBUILD platform may process email identifiers that have been transformed by the relevant participant using SHA-256 hashing without a salt before being uploaded to the platform.

These identifiers are referred to in the platform documentation as “Pseudonymised Email Identifiers”.

CANBUILD does not require participants to upload their original email addresses for the deduplication process. At import, each line of an uploaded file is automatically checked against the expected SHA-256 format; lines that do not match are rejected and are not stored. This check verifies the format of submitted values only. It does not verify that a value is the hash of an email address.

However, hashing does not necessarily make information anonymous. Where a pseudonymised identifier can be linked, directly or indirectly, to an identifiable individual, it may constitute personal data under applicable data-protection law.

Participants remain responsible for the lawfulness of the personal data they transform and submit to the platform.

4Roles of the Parties

The applicable data-protection role depends on the processing activity concerned.

4.1CANBUILD as Data Controller

CANBUILD acts as a controller where it determines the purposes and means of processing, including for example:

• managing user accounts;
• authentication and access control;
• mandatory 2FA;
• platform security;
• monitoring and preventing unauthorised access;
• maintaining technical logs;
• managing business relationships;
• handling support requests;
• contractual and billing administration;
• complying with legal obligations; and
• maintaining and operating the CANBUILD platform.

4.2CANBUILD as Data Processor

For certain campaign-related processing activities, CANBUILD may process personal data on behalf of a Client acting as controller.

In such cases:

• the Client determines the purposes and relevant instructions for the processing;
• CANBUILD processes the data in accordance with those documented instructions;
• the processing is governed by the applicable DPA;
• CANBUILD does not use Client Data for its own independent commercial purposes except where permitted by the applicable agreement or required by law.

The qualification of the parties under data-protection law depends on the actual processing activities and applicable law.

4.3Publishers and Advertisers

Publishers and Advertisers may have their own responsibilities as controllers in relation to the personal data contained in or derived from their own databases.

They are responsible for ensuring that their collection, use, transformation, submission and subsequent use of personal data complies with applicable law.

The fact that a Publisher or Advertiser uses the CANBUILD platform does not, by itself, make that party a processor of CANBUILD.

5Purposes of Processing

Where CANBUILD acts as controller, personal data may be processed for the following purposes:

• Providing and operating the Website and platform;
• Creating and managing user accounts;
• Authenticating users and enforcing access controls;
• Operating and securing mandatory 2FA;
• Managing user permissions;
• Protecting the Services against fraud, abuse, attacks and unauthorised access;
• Detecting, investigating and responding to security incidents;
• Maintaining technical logs and audit trails;
• Keeping evidence of the acceptance of the Terms of Use;
• Providing customer and technical support;
• Communicating with users and business contacts;
• Managing contractual relationships;
• Managing subscriptions, invoices and payments where applicable;
• Maintaining, troubleshooting and improving the reliability and performance of the Services;
• Complying with legal, tax, accounting and regulatory obligations;
• Establishing, exercising or defending legal claims; and
• Sending service-related communications necessary for the operation or administration of the Services.

CANBUILD does not use Client campaign data to create a general-purpose database of email identifiers across different Clients.

6Legal Bases for Processing

Depending on the circumstances, CANBUILD relies on one or more of the following legal bases under the GDPR:

6.1Performance of a contract

Where processing is necessary to:

• create and manage an account;
• provide contracted services;
• administer a subscription;
• provide customer support;
• communicate about the Services; or
• perform contractual obligations.

6.2Legitimate interests

CANBUILD may rely on legitimate interests where processing is necessary for purposes such as:

• securing and protecting the Services;
• preventing fraud and abuse;
• maintaining technical logs and audit trails;
• keeping evidence of the acceptance of the Terms of Use;
• improving reliability and performance;
• managing business relationships;
• defending legal claims; and
• ensuring the proper functioning of the business.

CANBUILD assesses and balances its legitimate interests against the rights and freedoms of individuals as required by applicable law.

6.3Legal obligations

Processing may be necessary to comply with legal obligations applicable to CANBUILD, including accounting, tax, regulatory and legal requirements.

6.4Consent

Where legally required, CANBUILD will obtain consent before carrying out processing that relies on consent.

Where processing is based on consent, consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

7Data Received Through Campaigns

CANBUILD operates a technical deduplication platform.

For campaigns involving Advertisers and Publishers, participants may submit Pseudonymised Email Identifiers generated from their own databases. When importing a file, the participant designates the Client or Clients for whose campaigns the file is imported. Once the import is completed, this designation is fixed and can be changed only through a deletion procedure.

CANBUILD may process these identifiers in accordance with the campaign configuration, the participant’s designation and applicable instructions, including:

• comparing identifiers between an Advertiser and participating Publishers;
• comparing identifiers between participating Publishers;
• applying the priority order configured for the campaign;
• removing duplicate occurrences according to the applicable campaign rules;
• generating a result for each participating Publisher; and
• making that Publisher’s own result available to that Publisher.

Result files are not stored. When a Publisher downloads its result, the file is generated at that moment and is not retained on the platform as a file. A result can be generated for 10 days after its creation and cannot be generated afterwards, whether or not it has been downloaded. Publishers are responsible for keeping the results they need after download.

A Publisher may participate in campaigns for several Clients, including Clients that may be competitors.

Participation in multiple Clients’ campaigns does not authorise CANBUILD to combine those Clients’ campaign data into a common cross-client deduplication database. Where a participant designates the same file for the campaigns of several Clients, the file is processed for each Client only on that Client’s instructions and in accordance with the participant’s designation.

CANBUILD applies logical separation between Clients and restricts access to data and results according to the applicable permissions.

8Cross-Client Separation

CANBUILD may provide services to multiple Clients, including competing Clients.

A Publisher or Advertiser may therefore participate in campaigns associated with several Clients.

Where this occurs:

• one Client does not obtain access to another Client’s campaign data;
• one Client does not obtain access to another Client’s participants’ source data or results;
• a Publisher may access its own authorised files and results associated with its participation in different Clients’ campaigns;
• an Advertiser may access its own authorised information where applicable;
• CANBUILD does not use data submitted for one Client’s campaign to perform deduplication, comparison, filtering or enrichment for another Client, except where the same participant has itself designated the same file for that other Client’s campaign;
• a file is processed only for the Clients that the participant has designated;
• data from different Clients is not intentionally combined to create a shared cross-client deduplication database.

These controls are intended to preserve confidentiality and appropriate segregation between Client environments while allowing authorised participants to use the Services across multiple business relationships.

9Data Sharing and Recipients

CANBUILD may disclose or provide access to personal data where necessary to operate its business and Services.

Recipients may include:

• Hosting and infrastructure providers;
• Cloud and storage service providers;
• Authentication and security service providers;
• Technical maintenance and support providers;
• Monitoring and logging providers;
• Payment processors, where applicable;
• Professional advisers, including legal, accounting and compliance advisers;
• Public authorities where required by law; and
• Other service providers acting on CANBUILD’s behalf where necessary for the purposes described in this Privacy Policy.

CANBUILD requires appropriate contractual, confidentiality and data-protection safeguards from service providers where required by applicable law.

CANBUILD does not sell personal data to third parties.

CANBUILD does not rent personal data for third-party marketing purposes.

10Sub-Processors

Where CANBUILD acts as a processor for a Client, CANBUILD may engage sub-processors to provide hosting, infrastructure, security, technical or other services necessary to provide the platform.

CANBUILD currently uses O2switch (Clermont-Ferrand, France) for the hosting and infrastructure of the platform, including the storage of encrypted backups. Hosting is located in France.

Pseudonymised Email Identifiers are encrypted at the application layer, and the encryption keys are rotated on a regular schedule and destroyed after a short overlap period once superseded, as described in Sections 11 and 12.

Such processing is subject to the applicable DPA and the requirements of Article 28 of the GDPR.

The relevant contractual documentation may provide additional information concerning authorised sub-processors and applicable safeguards. Any addition or replacement of a sub-processor is notified to Clients in accordance with their agreements.

11Data Retention

CANBUILD retains personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may vary depending on the type of data and purpose of processing.

As a general principle:

• User accounts: account information is retained for as long as the account exists. When a user deletes their account, or when it is deleted, the account is removed from active systems and the reference to the user in import, download and deletion records is anonymised. The data of the user’s organisation is not deleted by the deletion of a single user account.
• Organisations: when an organisation (Client, Advertiser or Publisher) is deleted, all data held within it is deleted, including its users and, for Advertisers and Publishers, its data sources and imports. For a Client, results generated for campaigns launched by that Client are also deleted.
• Campaign data processed on behalf of a Client: retained and deleted in accordance with the applicable Client instructions and DPA. Where the same import has been designated by a participant for several Clients, only the association with the Client concerned is removed when that Client requests deletion, and the data is deleted once no Client requires it.
• Records of imports and downloads and acceptance of the Terms of Use: retained for as long as the organisation concerned exists, and deleted with it.
• Security and authentication logs (including IP addresses): retained for 12 months for security, abuse prevention and incident investigation purposes, including after the deletion of a user account, and then deleted. CANBUILD’s own backup copies expire within a further 12 months and are not used other than in the event of a restoration. Logs relating to an open incident or legal claim may be retained until it is closed.
• Support and business communications: retained for as long as necessary to manage the relevant relationship and any resulting legal or contractual obligations.
• Billing and accounting records: retained for the periods required by applicable law.
• Backups of the dedicated database (identifiers, account data and campaign data) are retained for 10 days and then deleted by automatic rotation. Backups of the application, configuration and security logs are retained for up to 12 months and then deleted by automatic rotation. Data deleted from the platform is not restored from backups for processing purposes. When data processed on behalf of a Client must be deleted, the corresponding data is removed from active systems and expires from backups within the period required by the applicable DPA.
• Hosting provider backups: in addition to CANBUILD’s own backups, our hosting provider O2switch makes automatic backups of the hosting account which CANBUILD cannot disable or configure. They are retained for the provider’s backup cycle, which the provider determines and may change, and are not used by CANBUILD to restore the service for processing purposes. Account data, security logs (including IP addresses) and campaign metadata in these backups are not application-encrypted. Pseudonymised email identifiers are encrypted with keys that are not stored in these backups and that are rotated and destroyed on a regular schedule, so that they become irrecoverable earlier than the backups expire.

When personal data is no longer required, CANBUILD will delete it, anonymise it where appropriate, or otherwise securely dispose of it in accordance with applicable law.

12Data Security

CANBUILD implements appropriate technical and organisational measures designed to provide a level of security appropriate to the risks associated with the processing.

These measures may include:

• Mandatory two-factor authentication for all platform users;
• Mandatory multi-factor authentication for administrative and remote access;
• Individual user accounts;
• Role-based access controls;
• Least-privilege access;
• Authentication and credential protections;
• Logical separation of organisations and Client environments;
• Application-level encryption of pseudonymised identifiers before they are stored;
• Storage of identifiers, account data and campaign data in a dedicated database, separate from application code, configuration and security logs;
• Encryption of data in transit;
• Encrypted backups;
• Separation of encryption keys from the data they protect;
• Regular rotation of the application encryption key and destruction of superseded keys;
• Security logging and monitoring;
• Access management and periodic review;
• Confidentiality obligations for authorised personnel;
• Security incident detection and response procedures; and
• Secure deletion procedures.

No method of transmission, storage or processing can be guaranteed to be completely secure. CANBUILD continuously reviews and improves its security measures as appropriate to the risks and evolution of the Services.

13Personal Data Breaches

Where CANBUILD becomes aware of a personal data breach affecting personal data processed on behalf of a Client, CANBUILD will act in accordance with the applicable DPA and applicable law.

Where CANBUILD acts as an independent controller and a personal data breach triggers notification obligations, CANBUILD will take the measures required by applicable law.

14International Data Transfers

CANBUILD does not transfer personal data outside the European Economic Area (“EEA”).

Personal data processed by CANBUILD is hosted and processed within the EEA (France), including backups.

CANBUILD will maintain appropriate technical and organisational measures to ensure that personal data remains within the EEA. If this changes in the future, CANBUILD will update this Privacy Policy and implement any safeguards and information requirements required by applicable data-protection law before carrying out such transfers.

15Your Data Protection Rights

Subject to the conditions and limitations provided by applicable law, individuals may have the right to:

• Request access to their personal data;
• Request rectification of inaccurate or incomplete personal data;
• Request erasure of personal data;
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Object to certain forms of direct marketing;
• Request portability of personal data where the legal conditions are met;
• Withdraw consent where processing is based on consent; and
• Define instructions concerning the handling of personal data after death where provided for by applicable national law.

These rights are not absolute and may be subject to legal conditions or exceptions. In particular, the deletion of a user account does not immediately delete security logs, which are retained for the period described in Section 11 for security purposes and for the establishment, exercise or defence of legal claims.

Where CANBUILD processes personal data on behalf of a Client, requests concerning that processing may need to be directed to the relevant Client, as the controller. CANBUILD will provide appropriate assistance in accordance with the applicable DPA and applicable law.

16Exercising Your Rights

To exercise your rights or ask questions concerning CANBUILD’s processing of personal data, contact:
dpo [at] lilie.fr

Please provide sufficient information to allow CANBUILD to identify the relevant request and respond appropriately.

CANBUILD may need to verify the identity of the requester before responding to a request where reasonably necessary to protect personal data and account security.

CANBUILD will respond within the time limits required by applicable law.

You also have the right to lodge a complaint with a competent supervisory authority.

For individuals in France, the relevant supervisory authority is the Commission Nationale de l’Informatique et des Libertés (CNIL).

17Cookies and Similar Technologies

The Website and CANBUILD platform may use cookies and similar technologies.

These technologies may be used for purposes including:

• Essential website functionality;
• Authentication and session management;
• Security;
• Remembering user preferences;
• Performance and reliability;
• Measuring usage and improving the Services; and
• Other purposes where permitted by applicable law.

Where consent is legally required, non-essential cookies or similar technologies will only be used after obtaining the required consent.

Users may manage cookies through available consent mechanisms and browser settings.

Disabling certain cookies may affect the availability or functionality of some features.

Additional information concerning cookies may be provided through the applicable cookie-management interface or a dedicated Cookie Policy where applicable.

18Third-Party Services and External Websites

The Services may contain links to or integrations with third-party websites, services or applications.

Third-party services are governed by their own privacy policies and terms.

CANBUILD is not responsible for the privacy practices of third parties acting independently of CANBUILD.

Users are encouraged to review the privacy information provided by third-party services before using them.

Where a third-party provider processes personal data on CANBUILD’s behalf, CANBUILD will implement the contractual and organisational safeguards required by applicable law.

19Children’s Data

The Services are intended for business and professional use and are not directed to children.

CANBUILD does not knowingly collect personal data from children for the purpose of providing the Services.

If you believe that a child has provided personal data to CANBUILD without appropriate authorisation, please contact us at dpo [at] lilie.fr.

20Automated Decision-Making and Profiling

CANBUILD does not use personal data processed through the Services to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals, unless otherwise expressly disclosed and permitted by applicable law.

The deduplication rules applied by the platform are technical processing rules configured for a campaign and do not constitute automated decision-making concerning an individual’s rights or legal status.

21Changes to this Privacy Policy

CANBUILD may update this Privacy Policy from time to time to reflect:

• Changes to the Services;
• Changes to processing activities;
• Changes in legal or regulatory requirements;
• Changes to security measures; or
• Operational or organisational developments.

The latest version will be made available on this page and will indicate the date of the latest update.

Where required by applicable law, CANBUILD will provide additional notice or obtain consent before implementing material changes.

22Contact

For questions regarding this Privacy Policy or CANBUILD’s own processing of personal data:

For requests concerning personal data processed by CANBUILD on behalf of a Client, please refer to the relevant Client’s privacy notice or contact the Client where appropriate.