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Privacy Policy

Privacy

Definitions:

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

Nature of the data collected

In the course of using the Sites, the Publisher may collect the following categories of data about its Users:

Civil status, identity and identification data…

Data relating to personal life (lifestyle, family situation, excluding sensitive or dangerous data)

Connection data (IP addresses, event logs…)

Location data (movements, GPS data, GSM…)

Disclosure of personal data to third parties

No communication to third parties

Your data will not be disclosed to third parties. You are informed, however, that it may be disclosed pursuant to a law, regulation or decision of a competent regulatory or judicial authority.

Prior information for the communication of personal data to third parties in the event of a merger / absorption

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

In the event that we become involved in a merger, acquisition or other form of asset transfer, we are committed to maintaining the confidentiality of your personal data and to informing you before your personal data is transferred or subjected to new privacy rules.

Purpose of the re-use of the personal data collected

Carry out operations related to the management of clients concerning

  • contracts; orders; deliveries; invoices; accounting and in particular accounts receivable management
  • a loyalty program within a legal entity or entities;
  • monitoring customer relations, such as satisfaction surveys, complaint management and after-sales service
  • the selection of customers to carry out studies, surveys and product tests (except with the consent of the persons concerned obtained 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, sex life or health of the persons)


Carry out operations related to prospecting

  • Management of technical prospecting operations (including technical operations such as normalization, enrichment and de-duplication)
  • selection of people to carry out loyalty, prospecting, survey, product test and promotion actions. Except with the consent of the persons concerned obtained 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, sex life or health of the persons)
  • the realization of solicitation operations


The development of business statistics

The transfer, rental or exchange of its customer and prospect files

The updating of its canvassing files by the organization in charge of managing the opposition list to telephone canvassing, in application of the provisions of the consumer code

The organization of contests, lotteries or any promotional operation with the exception of online gambling subject to the approval of the Autorité de Régulation des Jeux en Ligne

Management of requests for access, rectification and opposition rights

The management of unpaid bills and disputes, provided that they do not involve offences and/or do not result in the exclusion of the person from a right, a service or a contract

Management of people’s opinions on products, services or content

Data aggregation

Aggregation with non-personal data

We may publish, disclose and use Aggregate Information (information about all of our Users or specific groups or categories of Users that we combine so 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 on the User’s social accounts

If you connect your account to another service’s account for the purpose of cross-mailing, that service may share your profile information, login information, and any other information you have authorized to be shared. We may aggregate information about all of our other Users, groups, and accounts with the personal data available about the User.

Collection of identity data

Registration and prior identification for the provision of the service

The use of the Site requires registration and prior identification. Your personal data (name, first name, postal address, e-mail, telephone number,…) are used to perform our legal obligations resulting from the delivery of the products and/or services, under the End User License Agreement, the Warranty Term, if applicable, or any other applicable condition. You will not provide false personal information or create an account for another person without their permission. Your contact information must always be accurate and up to date.

Geolocation

Use of the user’s identifier for the purpose of proposing contacts and commercial offers

We use your electronic credentials to search for existing relationships by login, email address or services. We may use your contact information to allow others to find your account, including through third party services and client applications. You can upload your address book so that we can help you find people in our network or to allow other Users in our network to find you. We may make suggestions to you and other Network Users from contacts imported from your address book. We are likely to partner with companies that offer incentives. To support this type of promotion and incentive, we may share your email ID.

Geolocation

Geolocation for service delivery purposes

We collect and process your geolocation data in order to provide you with our services. We may use personal data to determine your location in real time. In accordance with your right of opposition provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, of deactivating the functions relating to geolocation.

Geolocation for cross-referencing purposes

We collect and process your geolocation data to enable our services to identify points of intersection in time and space with other Users of the service in order to present you with a profile of the intersecting Users. In accordance with your right of opposition provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, of deactivating the functions relating to geolocation. You acknowledge that the service will no longer be able to present you with profiles of other Users.

Geolocation with provision of partners for referencing and aggregation (with opt-in)

We may collect and process your geolocation data with our partners. We are committed to anonymizing the data used. In accordance with your right of opposition provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, of deactivating the functions relating to geolocation.

Collection of terminal data

Collection of profiling and technical data for service delivery purposes

Some of your device’s technical data is collected automatically by the Site. This information includes your IP address, Internet Service Provider, hardware configuration, software configuration, browser type and language… 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 are automatically collected and recorded by the Site, for advertising, commercial and statistical purposes. This information helps us personalize and continually improve your experience on our Site. We do not collect or store any personal data (name, first name, address…) that may be attached to a technical data. The data collected may be sold to third parties.

Cookies

Cookie retention time

In accordance with the recommendations of the CNIL, the maximum duration of conservation of cookies is 13 months after their first deposit in the terminal of the User, as well as the duration of the validity of the consent of the User 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 of cookies

Cookies may be used for statistical purposes, in particular to optimize the services rendered to the User, based on the processing of information concerning the frequency of access, the personalization of the 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 can read during your subsequent visits.

Right of the User to refuse cookies, deactivation resulting in a degraded functioning of the service

You acknowledge that you have been informed that the Publisher may use cookies, and authorize the Publisher to do so. If you do not want cookies to be used on your device, most browsers allow you to disable cookies through the settings options. However, you are informed 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 navigational information through the use of cookies.

Technical data retention

Length of time technical data is kept

The technical data are kept for the time strictly necessary to achieve the purposes mentioned above.

Retention period for 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 freedoms, the personal data being the subject of a treatment are not preserved beyond the time necessary to the execution of the obligations defined at the time of the conclusion of the contract or of the predefined duration of the contractual relation.

Retention of anonymized data beyond the contractual relationship / after account deletion

We keep personal data for the time strictly necessary to fulfill the purposes described in these T&Cs. After this period, they will be anonymized and kept for statistical purposes only and will not be used in any way whatsoever.

Deleting data after account deletion

Means of data purging are put in place to provide for the effective deletion of data once the period of retention or archiving necessary for the achievement of the determined or imposed purposes 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.

Data deletion after 3 years of inactivity

For security reasons, if you have not logged in to 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

Deletion of the account on request

User may delete his or her Account at any time by simply requesting the Publisher OR by using the Account deletion menu in the Account settings if applicable.

Account deletion in case of TOS violation

If you violate any provision of the TOS or any other document incorporated herein by reference, Publisher reserves the right to terminate or restrict, without prior notice and in its sole discretion, your use of and access to the Services, your account and all Sites.

Indications in case of a security breach detected by the Editor

Informing the User in case of a security breach

We undertake to implement all appropriate technical and organizational measures to guarantee a level of security adapted 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 unlawful access to your personal data stored on our servers or those of our service providers, or unauthorized access resulting in the risks identified above, we will:

  • Notify you of the incident as soon as possible;
  • Examine the causes of the incident and inform you;
  • Take reasonable steps to mitigate any adverse effects and damages that may result from such incident


Limitation of liability

Under no circumstances may the commitments defined in the above point concerning notification in the event of a security breach be assimilated to any recognition of fault or responsibility 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 the transfer of data to foreign countries, in particular as follows:

  • The Publisher transfers Users’ personal data 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 an adequate level of protection: The Publisher has obtained an authorization from the CNIL to proceed with this transfer.

For a list of these countries: CNIL – Data protection around the world

Modification of the T&Cs and the privacy policy

In case of modification of the present TOS, commitment not to lower the level of confidentiality in a substantial way without prior information of the persons concerned

We undertake to inform you in the event of a substantial change to these T&Cs, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.

Applicable law and methods of appeal

Arbitration clause

You expressly agree that any dispute arising out of these TOU, including its interpretation or performance, shall be subject to arbitration under the rules of the mutually agreed upon arbitration platform, to which you shall unconditionally agree.

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. This data must be provided in an open and easily reusable format.

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