General Data Protection Regulation (GDPR)
The Publisher : The natural or legal person who provides online public communication services.
The Site: All the sites, Internet pages and online services provided by the Publisher.
The User: The person using the Site and the services.
Type of data collected
When using the Sites, the Publisher may collect the following categories of data concerning its Users:
Civil status, identity, identification data….
Data relating to personal life (lifestyle, family status, excluding sensitive or dangerous data)
Login details (IP addresses, event logs, etc.)
Location data (moves, GPS data, GSM…)
Disclosure of personal data to third parties
No disclosure to third parties
Your data will not be shared with third parties. However, you are informed that they 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 / take-over
Preliminary information and possibility of an opt-out before and after the merger / acquisition
Should we be involved in a merger, acquisition or other form of asset disposal, we are committed to ensuring the privacy of your personal data and to informing you before it is transferred or subject to new privacy rules.
Purpose of the reuse of collected personal data
Carry out operations related to customer management concerning
- contracts; orders; deliveries; invoices; accounting and particularly the management of customer accounts
- a loyalty program within one or more legal entities;
- customer relationship management such as satisfaction surveys, complaints management and after-sales service.
- the selection of clients to carry out studies, surveys and product tests (unless the consent of the persons concerned is obtained under the conditions laid down in Article 6, these operations must not lead to profiling likely to reveal sensitive data – racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life or personal health).
The development of trade statistics
Management of requests for access, rectification and opposition rights
Managing people’s opinions on products, services or content
Aggregation with non-personal data
We may publish, disclose and use aggregate information (information about all 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 stated) and non-personal information for purposes of sector 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 an account of another service in order to cross send, that service may provide us with your profile information, login information, and any other information you have authorized for disclosure. We may aggregate information about all our other Users, groups, accounts, personal data available about the User.
Collection of identity data
Consultation of the Site does not require registration or prior identification. It can be carried out without you providing any of your personal data concerning (surname, first name, address, etc.). We do not store any personal data just for consulting the Site.
Collection of identification data
Use of the user ID only for access to services
We use your electronic credentials only for and during the execution of the contract.
Geolocation for service provision purposes
We collect and process your geolocation data to provide you with our services. We may use personal data to determine your geographical location in real time. In accordance with your right of opposition provided for by law n°78-17 of 6 January 1978 relating to data processing, files and liberties, you have the possibility, at any time, to disable the geolocalisation-related features.
Geolocation for crossing purposes
We collect and process your geolocation data to allow our services to identify crossover points in time and space with other Users of the service in order to provide you with profiles of the cross-users. In accordance with your right of opposition provided for by law n°78-17 of 6 January 1978 relating to data processing, files and liberties, you have the possibility, at any time, to disable the geolocalisation-related features. You then agree that the service will no longer be able to provide you with profiles of other Users.
Geolocation with partners available for referencing and aggregation (with opt-in)
We can collect and process your geolocation data with our partners. We undertake to anonymize the data used. In accordance with your right of opposition provided for by law n°78-17 of 6 January 1978 relating to data processing, files and liberties, you have the possibility, at any time, to disable the geolocalisation-related features.
Collection of terminal data
Collection of profiling and technical data for the purpose of providing the service
Some of the technical data of your device is automatically collected 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 essential for the provision of services.
Collection of technical data for advertising, commercial and statistical purposes
The technical data of your device is automatically collected and stored by the Site for advertising, commercial and statistical purposes. This information helps us to personalize 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 sold to third parties.
How long cookies are stored
In accordance with the recommendations of the CNIL, the maximum storage period for cookies is 13 months at most after their first placement in the User’s terminal, as well as 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 of cookies
Cookies may be used for statistical purposes, in particular to optimise the services provided to the User, by processing information concerning the frequency of access, the customisation of pages as well as the operations carried out and the consulted information. You are informed that the Editor may place cookies on your device. The cookie stores information relating to browsing on the service (the pages you have visited, the date and time of the visit…) that we can read during your subsequent visits.
Conservation of technical data
Storage period for technical data
The technical data are kept for the period strictly required to carry out the aforementioned purposes.
Time limit for storing personal data and anonymisation
Data retention for the duration of the contractual relation
In accordance with Article 6-5° of Law No. 78-17 of 6 January 1978 on data processing, personal data processed shall not be stored beyond the time needed to carry out the obligations set out when the contract was signed or the predefined duration of the contractual relation
Storage of anonymized data beyond the contractual relationship / after account deletion
We retain personal data for as long as it is strictly needed to carry out the purposes described in these T&C. Beyond this period, they will be anonymized and kept exclusively for statistical purposes and will not result in any exploitation of any kind whatsoever.
Deletion of data after account deletion
Means of data purging shall be put in place in order to provide for their effective deletion as soon as the storage or archiving period required to achieve the purposes determined or imposed has been reached. In accordance with the law n°78-17 of 6 January 1978 relating to data processing, files and liberties, you also have the right to delete your data, which you can exercise at any time by contacting the Editor.
Data deletion after 3 years of inactivity
For security reasons, if you have not logged in to the Site for over three years, you will receive an e-mail prompting you to log in as soon as possible, failing to do so, 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, simply by submitting a request to the Editor OR by using the menu to delete the Account located in the Account settings, if applicable.
Deletion of the account in the event of a breach of the TOS
In the event of a violation of one or more provisions of the TOS or any other document incorporated herein by reference, the Editor reserves the right to terminate or restrict, without prior notice and at its sole discretion, your use of and access to the Services, your account and all the Sites.
Notes in the event of a security breach detected by the Editor
Information to the User in the event of a security breach
We undertake to implement all appropriate technical and organisational measures to guarantee an appropriate level of security with regard 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 occurrence of the aforementioned risks, 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 reasonable limits to reduce the negative effects and harms that may result from the incident.
Limitation of liability
Under no circumstances may the commitments outlined in the above-mentioned point relating to notification in the event of a security breach be considered as an acknowledgement of any fault or liability with regard to the occurrence of the incident in question.
Transfer of personal data abroad
No transfer outside the European Union
The Editor undertakes not to transfer the personal data of its Users out of the European Union.
In the event of a change to these T&Cs, an agreement not to substantially reduce the privacy level without prior notice to the persons concerned
We undertake to inform you in the event of any substantial change to these T&Cs, and not to reduce the privacy level of your data substantially without informing you and seeking your consent.
Applicable law and appeal procedures
Application of French law (CNIL legislation) and court jurisdiction
These T&Cs and your use of the Site shall be governed by and construed in accordance with the laws of France, and in particular Law No. 78-17 of 6 January 1978 relating to data processing, files and liberties. The choice of applicable law does not affect your rights as a consumer under the applicable law of your location. If you are a consumer, both of us agree to be subject to the non-exclusive jurisdiction of the French courts, which means that you may bring an action relating to these T&Cs in France or in the EU country in which you are living. If you are in business, all actions against us must be brought before a court in France.
In the event of a dispute, the parties will seek an amicable solution before any legal action. In the event of failure of these attempts, any dispute regarding the validity, interpretation and/or execution of these T&Cs shall be brought before the French courts, even if there is more than one respondent or if the guarantee is called in.
The Editor undertakes to provide you with the possibility of having all your personal data returned to you upon request. The User is thus guaranteed a better control of his or her data, and has the possibility to reuse them. This data should be provided in an accessible and easily reusable format.