The Publisher: The person, physical or moral, 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 the services.
NATURE OF THE COLLECTED DATA :
Within the framework of the use of the Sites, the Editor is likely to collect the following categories of data concerning its Users: Data of civil status, identity, identification…
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
No disclosure to third parties :
Your data will not be communicated 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 COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES IN CASE OF MERGER/ABSORPTION
Collection of opt-in (consent) prior to the transmission of data following a merger / acquisition :
In the event that we take part in a merger, acquisition or any other form of disposal of assets, we undertake to obtain your prior consent to the transmission of your personal data and to maintain the level of confidentiality of your personal data to which you have consented.
PURPOSE OF REUSING THE PERSONAL DATA COLLECTED
Carry out operations related to the management of clients concerning :
- contracts, orders, deliveries, invoices, accounting and in particular the management of accounts receivable
- a loyalty program within an entity or several legal entities ;
- customer relationship management, such as satisfaction surveys, complaints management and after-sales service management
- the selection of customers to carry out studies, surveys and product tests (except with the consent of the persons concerned collected under the conditions provided for in Article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data
- racial or ethnic origins, philosophical, political, trade union or religious opinions, sexual life or health of persons)
The organization of contests, lotteries or any promotional operation with the exception of online gambling and games of chance subject to the approval of the Online Gaming Regulatory Authority.
The management of unpaid bills and litigation, provided that it does not concern infractions and/or does not lead to the exclusion of the person from the benefit of a right, a service or a contract.
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 referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other business purposes.
Aggregation with personal data available in the User’s corporate accounts:
If you connect your account to an account of another service for the purpose of cross mailings, that service may provide us with your profile information, login information, and 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 to the User.
COLLECTION OF IDENTITY DATA
Use of a pseudonym :
The use of the Site requires registration without prior identification. It can be carried out without you communicating any personal data concerning you (surname, first name, address, etc.). You can use the pseudonym of your choice.
Collection of identification data :
Use of the user’s identifier only for access to the services.
We use your electronic identifiers only for and during the performance of the contract.
TERMINAL DATA COLLECTION
No collection of technical data :
We do not collect and keep any technical data of your device (IP address, Internet service provider…).
Cookie retention time :
In accordance with the recommendations of the CNIL, the maximum retention period for cookies is 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 optimize the services rendered to the User, from the processing of information concerning the frequency of access, the personalization of pages as well as the operations performed and the information consulted.
You are informed that the Publisher is likely to deposit 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.
PRESERVATION OF TECHNICAL DATA
Retention period of technical data :
The technical data are kept for the duration strictly necessary to achieve the purposes mentioned above.
TIME LIMIT FOR STORING PERSONAL DATA AND ANONYMIZATION
Retention of data for the duration of the contractual relationship :
In accordance with article 6-5° of the law n°78-17 of January 6, 1978 relating to data processing, files and liberties, personal data subject to processing are not kept beyond the time necessary to perform the obligations defined at the conclusion of the contract or the predefined duration of the contractual relationship.
Retention of anonymized data beyond the contractual relationship / after deletion of the account :
We store personal data for the period of time strictly necessary for the fulfillment of the purposes described in these TOU. Beyond this period, the data will be anonymized and stored exclusively for statistical purposes and will not be used for any other purpose whatsoever.
Deletion of data after deletion of the account :
Means of data purging are put in place in order to provide for the effective deletion of data as soon as the retention or archiving period necessary to achieve the purposes determined or imposed is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, the files and freedoms, you have moreover a right of suppression on your data which you can exert constantly by contacting the Editor.
Deletion of data after 3 years of inactivity :
For security reasons, if you have not authenticated yourself on the Site for a period of three years, you will receive an e-mail inviting you to connect as soon as possible, otherwise your data will be deleted from our databases.
Deleting the account on demand :
The User has the possibility to delete his Account at any time, by simple request to the Publisher OR through the Account deletion menu present in the Account settings if necessary.
Deletion of the 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 CASE OF A SECURITY FLAW DETECTED BY THE PUBLISHER
Information of the User in case of a security breach :
We undertake to implement all appropriate technical and organizational measures to guarantee a level of security appropriate to the risks of accidental, unauthorized 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 the limits of reasonableness in order to reduce the negative effects and prejudices 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
Transfer of data to countries with an equivalent level of protection:
The Publisher undertakes to comply with the applicable regulations relating to data transfers to foreign countries and in particular according to the following terms and conditions:
- The Publisher transfers the personal data of its Users to countries recognized as offering an equivalent level of protection.
- The Publisher transfers the personal data of its Users outside countries recognized by the CNIL as having a sufficient level of protection: The Publisher has obtained authorization from the CNIL to proceed with this transfer.
To know the list of these countries: CNIL – Data protection in the world
In case of modification of the present TOS, commitment not to lower the level of confidentiality substantially without prior information of the persons concerned:
We undertake to inform you in the event of a substantial modification of these TOU, and not to substantially lower the level of confidentiality of your data without informing you and obtaining your consent.
APPLICABLE LAW AND TERMS OF RECOURSE
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.
The Publisher undertakes to offer you the possibility of having all the data concerning you restored to you on simple 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.