Privacy Policy – Security and protection of personal data

Definitions :

• The Publisher: The person, natural or legal, who publishes communication services to the public online.
• The Site: All the sites, web pages and online services offered by the Publisher.
• The User: The person using the Site and services.

Nature of data collected

In the context of the use of the Sites, the Publisher may collect the following categories of data concerning its Users:

Vital statistics, identity, identification data…

Personal life data (lifestyle, family situation, excluding sensitive or dangerous data)

Connection data (IP addresses, event logs…)

Disclosure of personal data to third parties

No disclosure to third parties Your data will not be disclosed to third parties. You are informed, however, that they may be disclosed in application of a law, a regulation or pursuant to a decision of a competent regulatory or judicial authority.

Prior information for the disclosure of personal data to third parties in the event of a merger/acquisition

Prior information and opt-out before and after the merger/acquisition

In the event that we take part in a merger, acquisition or any other form of asset disposal, we undertake to guarantee the confidentiality of your personal data and to inform you before it is transferred or subjected to new confidentiality rules.

Purpose of the reuse of the personal data collected

Carry out operations relating to the management of clients concerning

– contracts; orders; deliveries; invoices; accounting and in particular accounts receivable management

– a loyalty programme within one or more legal entities ;

– customer relationship management such as customer satisfaction surveys, complaints management and after-sales service

– the selection of customers to carry out studies, surveys and product tests (except with the consent of the data subjects collected under the conditions laid down in Article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data – racial or ethnic origin, philosophical, political, trade union or religious opinions, sexual life or health of persons)

Carry out operations relating to prospecting

– the management of technical prospecting operations (including technical operations such as standardization, enrichment and deduplication)

– the selection of people to carry out loyalty actions, canvassing, surveys, product testing and promotions. Except with the consent of the data subjects collected under the conditions laid down in Article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origin, philosophical, political, trade union or religious opinions, sexual life or health of persons).

– the carrying out of solicitation operations

Data aggregation

Aggregation with Non-Personal Data We may publish, disclose and use aggregated information (information about all of our Users or specific groups or categories of Users that we combine in such a way that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other business purposes.

Aggregation with personal data available on the User’s corporate accounts If you connect your account to an account of another service in order to make cross mailings, the said service may communicate your profile information, login information, as well as any other information you have authorized to be disclosed. We may aggregate information about all of our other Users, groups, accounts, and personal data available about the User.

Collection of Identity Data

Free consultation Consultation Consultation of the Site does not require registration or prior identification. It can be carried out without you having to communicate any nominative data concerning you (surname, first name, address, etc). We do not record any personal data for the simple consultation of the Site.

Collection of identification data

Use of user ID only for access to services We use your electronic identifiers only for and during the execution of the contract.

Terminal data collection

Collection of profiling data and technical data for the purpose of providing the service Some of the technical data of your device is collected automatically by the Site. This information includes your IP address, Internet Service Provider, hardware configuration, software configuration, browser type and language, etc. The collection of this data is necessary for the provision of the services.

Collection of technical data for advertising, commercial and statistical purposes The technical data of your device is automatically collected and recorded by the Site for advertising, commercial and statistical purposes. This information helps us to customize and continually improve your experience on our Site. We do not collect or store any personal data (surname, first name, address, etc.) that may be attached to technical data. The data collected may be resold to third parties.

Cookies

Cookie retention period In accordance with the recommendations of the CNIL, the maximum retention period for cookies is a maximum of 13 months after their first deposit in the User’s terminal, as is the duration of the validity of the User’s consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.

Purpose cookies Cookies may be used for statistical purposes, in particular to optimise the services rendered to the User, based on the processing of information concerning the frequency of access, the personalisation of pages as well as the operations carried out and the information consulted.

You are informed that the Publisher may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of the consultation…) that we will be able to read during your subsequent visits.

Right of the User to refuse cookies, as deactivation will result in a degraded functioning of the service You acknowledge that you have been informed that the Publisher may use cookies, and authorize it to do so. If you do not wish cookies to be used on your device, most browsers allow you to disable cookies by going through the setting options. However, please be aware that some services may no longer function properly.

Possible association of cookies with personal data to enable the operation of the service The Publisher may collect navigation information through the use of cookies.

Retention of technical data

Retention period of technical data Technical data is retained for the time strictly necessary to achieve the purposes referred to above.

Period of retention of personal data and anonymisation

Retention of data for the duration of the contractual relationship In accordance with Article 6-5° of Law n°78-17 of 6 January 1978 relating to data processing, files and liberties, personal data subject to processing shall not be retained beyond the time necessary for the performance of the obligations defined at the time of the conclusion of the contract or the predefined duration of the contractual relationship.

Retention of anonymised data beyond the contractual relationship / after deletion of the account We retain personal data for the time strictly necessary to achieve the purposes described in these TOU. Beyond this duration, they will be anonymized and kept exclusively for statistical purposes and will not give rise to any exploitation of any kind whatsoever.

Deletion of data after deletion of the account Means of purging data are put in place in order to provide for its effective deletion as soon as the retention or archiving period necessary to achieve the determined or imposed purposes is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, files and liberties, you also have a right of deletion on your data which you can exercise at any time by contacting the Publisher.

Deletion of data after 3 years of inactivity For security reasons, if you have not authenticated on the Site for a period of three years, you will receive an e-mail inviting you to log in as soon as possible, otherwise your data will be deleted from our databases.

Account deletion

Account deletion on request The User has the possibility to delete his Account at any time, by simple request to the Editor OR through the Account deletion menu present in the Account settings if necessary.

Deletion of account in case of violation of the TOS In case of violation of one or more provisions of the TOS or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict without prior notice and at its sole discretion, your use and access to the services, your account and all Sites.

Indications in the event of a security breach detected by the Publisher

User information in the event of a security breach We undertake to implement all appropriate technical and organisational measures to guarantee a level of security appropriate to the risks of accidental, unauthorised or illegal access, disclosure, alteration, loss or destruction of your personal data. In the event that we become aware of illegal access to your personal data stored on our servers or those of our service providers, or unauthorized access resulting in the realization of the risks identified above, we undertake to :

– Notify you of the incident as soon as possible;

– Examine the causes of the incident and inform you;

– Take the necessary measures within reason to mitigate the negative effects and harm that may result from the said incident.

Limitation of liability Under no circumstances can the commitments defined in the above point relating to notification in the event of a security breach be assimilated to any admission of fault or liability for the occurrence of the incident in question.

Transfer of personal data abroad

No transfer outside the European Union The Publisher undertakes not to transfer the personal data of its Users outside the European Union.

Changes to the TOS and Privacy Policy

In case of modification of these TOS, commitment not to lower the level of confidentiality substantially without prior information of the persons concerned We undertake to inform you in case of substantial modification of these TOS, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.

Applicable law and remedies

Arbitration Clause: You expressly agree that any dispute that may arise from these TOS, including its interpretation or execution, will be subject to arbitration proceedings under the rules of the arbitration platform chosen by mutual agreement, to which you will adhere without reservation.

Data portability

Data portability The Publisher undertakes to offer you the possibility of having all your data returned to you on request. The User is thus guaranteed a better control of his data, and keeps the possibility of reusing them. These data must be provided in an open and easily reusable format.