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PRIVACY POLICY


1. Preamble
The purpose of this Privacy Policy is to inform Internet Users about how their Personal Data is collected from the Site, how they are processed by the Publisher and finally the rights enjoyed by Internet Users regarding these treatments such as they are defined below.

 

2. Definitions

The following terms, whether used in the singular or the plural in this Privacy Policy, shall have the following meaning:
Intermediate Archiving: refers to the movement of Personal Data that still has an administrative interest (for example in the case of litigation and / or legal obligation) for the Publisher in a separate database, logically or physically separated and which, in any case, access is restricted. This archive is an intermediate step before the deletion of the Personal Data concerned or their anonymization;

Privacy Policy: refers to this Privacy Policy and protection of Personal Data of Internet Users implemented by the Publisher;

Personal Data (s): means (s) the personal data of the Internet collected and processed by the Publisher and as defined in the Privacy Policy;

Specific Rights: Designate the rights granted by the Regulation on Personal Data to Internet Users regarding the processing of their Personal Data;

Regulation on Personal Data: refers to Law No. 78-17 of 6 January 1978 relating to data, files and freedoms, amended by Law No. 2018-493 of 20 June 2018 on the protection of personal data , pursuant to the Community Regulation of 27 April 2016 published in the Official Journal of the European Union on 4 May 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data ( called "RGPD" for General Regulations for Data Protection);

Terminal: refers to the hardware equipment (computer, tablet, smartphone, telephone, etc.) used by the Internet user to view or view the Website and / or any other digital medium edited by a third party ;

Internet user: refers to all Internet users, visitors of the Site.
 


3. The legal bases of the treatments carried out by the Editor

In accordance with the Personal Data Regulations, the treatments designated in this Privacy Policy are supported by a specific legal basis.

The use of the website is necessarily governed by a contractual relationship between the Internet user and the Publisher, serving in particular as the legal basis for the collection and processing of the User's Personal Data by the Publisher for the proper functioning of the Website. and the realization of the associated services.

The processing of Personal Data may also be necessary to comply with a legal obligation to which the Publisher would be subject.

The processing of the Personal Data of the Internet user may finally be necessary for the purposes of the legitimate interests pursued by the Publisher or by a third party, unless the interests or the fundamental rights and freedoms of the Internet user which require a protection of Personal Data, especially when the Internet user is a child.

The processing of Personal Data of the Internet strictly necessary for purposes of fraud prevention constitute for example a legitimate interest of the Publisher.

In the event of a treatment that is based on the legitimate interest of the Publisher or a third party, the Publisher ensures that the treatment in question is necessary for the realization of its legitimate interest and assesses the consequences of this treatment on the Internet user, in particular taking into account the nature of the Personal Data processed, and the way they are processed.

The Publisher ensures in any event not to disregard the interest or fundamental rights and freedoms by allowing the Internet, at any time, to oppose all or part of the treatments described in this Privacy Policy, as to implement its Specific Rights, and this in the conditions of Article 9 below.
 


4. The finalities of the treatments carried out by the Editor

The User's Personal Data is necessary to allow him access to the Site, its use and improvement, and to allow the Publisher to make any services detailed on the Site.

The operations described below are not used to lead to the establishment of profiles likely to reveal so-called sensitive personal data such as racial or ethnic origins, philosophical opinions, political, trade union, religious, sexual life or health and do not serve nor to produce automated decisions on the part of the Editor.


5. Storage of Personal Data

The Site is hosted by the AWS Company whose contact details are available by clicking here Legal terms.

Every precaution has been taken to store the Personal Data of Internet users in a secure environment and prevent them from being distorted, damaged or unauthorized third parties having access to it. The information provided by the Internet user will never be transmitted to third parties for commercial purposes, sold or exchanged.
 


6. Collection of Personal Data on the Site

The Publisher collects the Personal Data that the Net surfer informs spontaneously on the Site.

These Personal Data are kept by the Publisher for a period of two (2) years, in active database, from their communication from the Site.

The Personal Data concerned are then kept in Intermediate Archiving for an additional period of three (3) years in accordance with the common prescription period.

If necessary, the Publisher may decide to keep this Personal Data for a longer period of legal Intermediary Filing, to meet a legal obligation (for example Article L.123-22 of the French Commercial Code which provides that accounting documents and supporting documents are kept for ten years ") or to enable him to prove a right or a contract .

Only the Personal Data designated on the Site as mandatory are essential to benefit from the services provided by the Site .
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7. Recipients or Categories of Recipients of Personal Data

The Personal Data of the Net surfer are communicated to the subcontractors of the Publisher, namely:

AYS(klixi), a simplified joint - stock company with a capital of 50,000 Euros, whose head office is located at 18, rue de Londres 75009 Paris - France, registered with the Paris Trade and Companies Register under number 535 351 472 - https : //www.klixi.io/fr/mentions-legales

Functionality: Developer and tool for management and administration of the Site by the Publisher

Non-EU data transfer and specific guarantees: No

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Amazon Web Services LLC (AWS) PO Box 81226 Seattle, WA 98108-1226 - https://aws.amazon.com

Functionality: Site Hosting

Non-EU data transfer and specific warranties: Yes - Privacy Shield

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If applicable - Stripe Payments Europe, Ltd. 1 Grand Canal Lower Street, Grand Canal Dock, Dublin, Ireland - https://www.stripe.com/en

Functionality: Payment module

Non-EU data transfer and specific guarantees: No

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If applicable - Twilio Inc. 375 Beale Street, Suite 300 San Francisco, CA 94105 - https://www.twilio.com

Functionality: Allow the Editor to exchange with the Internet user from a chat module on the Site

Non-EU data transfer and specific warranties: Yes - Privacy Shield

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If applicable - Mandrill - The Rocket Science Group, LLC 675 Ponce Ave NE Suite 5000 Atlanta, GA 30308 USA - https://mailchimp.com/

Functionality: Allow the Publisher to send email campaigns to Internet users having entered their e-mail address

Non-EU data transfer and specific warranties: Yes - Privacy Shield

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If applicable - TextMagic - TEXTMAGIC LTD, Salisbury House Cambridge Road Station CB1 2LA United Kingdom, Reg Reg No: GB851556810, Company No: 05286521 - https://www.textmagic.com

Functionality: Allow the Editor to send SMS campaigns to Internet users having entered their telephone number

Non-EU data transfer and specific guarantees: No
 

8. The rights of Internet users

In accordance with the Regulation on Personal Data, the Internet user may, at any time, benefit from the following Specific Rights from / to / from:
* access (Article 39 of Law No. 78-17 of 6 January 1978 relating to data, files and freedoms),
* rectification (Article 40 of Law No. 78-17 of 6 January 1978 relating to data, files and freedoms),
* erasure (Article 40 of Law No. 78-17 of 6 January 1978 relating to data, files and freedoms),
* limitation of a treatment (Article 40 of Law No. 78-17 of 6 January 1978 relating to computers, files and freedoms),
* portability (article 20 of the RGPD),
* opposition (Article 38 of Law No. 78-17 of 6 January 1978 relating to data, files and freedoms),
* post-mortem directives (article 40-1 of the law n ° 78-17 of January 6th, 1978 relating to data processing, files and freedoms),
 

8.1 Access rights

The Internet user has the possibility to obtain from the Publisher the confirmation that the Personal Data concerning him are or are not processed and, when they are, access to the said Personal Data as well as the following information:
* the purposes of the treatment;
* categories of Personal Data;
* the recipients or categories of recipients to whom the Personal Data has been or will be communicated;
* when possible, the retention period of the Personal Data considered or, when this is not possible, the criteria used to determine this duration;
* the existence of the right to ask the Publisher for the correction or deletion of Personal Data, or a limitation of the processing of his Personal Data, or the right to object to such processing;
* the right to lodge a claim with the CNIL;
* when the Personal Data are not collected from the Internet, all available information as to their source;
* the existence of automated decision-making, including profiling, and, at least in this case, useful information regarding the underlying logic, and the significance and expected consequences of this treatment for the Internet user

When the Personal Data is transferred to a third country or to an international organization, the Internet user has the right to be informed of the appropriate warranties with regard to this transfer.
The Publisher provides a copy of the Personal Data that is being processed.
The Publisher may require the payment of reasonable fees based on the administrative costs for any additional copy requested by the Internet user.
When the Internet user submits his application electronically, the information is provided in an electronic form in common use, unless he requests otherwise.
The right of the Internet user to obtain a copy of his Personal Data must not infringe the rights and freedoms of others.
 

8.2 Rights of rectification

The Internet user has the opportunity to obtain from the Publisher, as soon as possible, the correction of the Personal Data concerning him which are inaccurate. It also has the possibility to obtain incomplete Personal Data to be completed, including providing a supplementary declaration.

8.3 Clearing rights

The Internet user may obtain from the Publisher the deletion, as soon as possible, of Personal Data concerning him when one of the following reasons applies:
* Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed by the Publisher;
* The Internet user has withdrawn his consent for the processing of these Personal Data and there is no other legal basis for the processing;
* The Internet user exercises his right of opposition in the conditions recalled below and there is no compelling legitimate reason for the treatment;
* Personal Data has been subject to unlawful processing;
* Personal Data must be erased to fulfill a legal obligation;
* Personal Data has been collected from a child.

8.4 Rights to the limitation

The Internet user has the possibility to obtain from the Publisher the limitation of the processing of his Personal Data when one of the following reasons applies:
* The Publisher verifies the accuracy of the Personal Data following the contest by the Internet user of the accuracy of the Personal Data,
* The treatment is illegal and the Internet user opposes the erasure of Personal Data and instead requires the limitation of their use;
* The Publisher no longer needs Personal Data for the purposes of processing but these are still necessary for the Internet user to find, exercise or defend rights in court;
* The Internet user objected to the processing in the conditions described below and the Publisher checks to know if the legitimate reasons prevail over the alleged reasons.

8.5 Right to portability of Data

The Internet user has the possibility to receive from the Publisher the Personal Data concerning him, in a structured format, commonly used and readable by machine when:
* the processing of Personal Data is based on consent, or on a contract and
* the treatment is performed using automated methods.

When the Internet user exercises his right to portability, he has the right to have the Personal Data transmitted directly by the Publisher to another controller he designates when it is technically possible.
The right to the portability of the Personal Data of the Internet user must not infringe the rights and freedoms of others.
 

8.6 Right to object

The Internet user may object at any time, for reasons related to his particular situation, to a processing of Personal Data concerning him based on the legitimate interest of the Publisher. The latter will then no longer process the Personal Data, unless it shows that there are compelling and legitimate reasons for the treatment that prevails over the interests and rights and freedoms of the Internet, or may retain them for the finding, exercise or defense of rights in court.

8.7 Post-mortem guidelines

The Internet user has the possibility of communicating to the Publisher of the directives relating to the conservation, the erasure and the communication of his Personal Data after his death, which directives can also be registered with a "digital trusted third party" certified ". These guidelines, or a kind of "digital will", may designate a person to carry out the instructions; failing this, the heirs of the Internet user will be designated.

In the absence of any directive, the heirs of the Internet can contact the Editor in order to:
* access to the processing of Personal Data allowing "the organization and settlement of the estate of the deceased";
* to receive communication of "digital assets" or "data resembling family memories, transmissible to heirs";
* have the user's account closed on the Website if necessary and oppose further processing of his Personal Data.

In any case, the Internet user has the possibility to indicate to the Editor, at any time, that he does not wish, in the event of death, that his Personal Data be communicated to a third party.


9. Exercise of the Specific Rights of Internet Users

These rights may be exercised, at any time, with the Publisher whose details are indicated in the legal notice Legal terms.

For the purposes of asserting his rights under the conditions referred to above and in the event that the Publisher has doubts about the author of the request, the Publisher may ask the latter to justify his identity by mentioning his surname, first name, e-mail address and accompany his application with a copy of a valid ID.

A response will be sent to the user within one (1) month maximum of the date of receipt of the request.

If necessary, this deadline may be extended by two (2) months by the Publisher who will give notice to the Internet and this, given the complexity and / or the number of requests.

In the event of a request by the Internet user to delete his Personal Data and / or in the exercise of his right to solicit the erasure of his Personal Data, the Publisher may however retain it in the form of Intermediate Archiving, and this for the time necessary to fulfill its legal obligations, or for probative purposes during the applicable limitation period.