Privacy Policy

Definitions

Client: any professional or natural person capable within the meaning of articles 1123 et seq. of the Civil Code, or legal entity, who visits the Site subject to these general conditions.
Services: XXX makes available to Clients:

Content: All the elements constituting the information present on the Site, notably texts – images – videos.

Customer Information: Hereinafter referred to as "Information (s)" which correspond to all personal data likely to be held by XXX for the management of your account, customer relationship management and for analysis and statistical purposes.

User: Internet user connecting to and using the aforementioned site.

Personal Information: "Information which allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies" (article 4 of law n° 78-17 of January 6, 1978).

The terms "personal data", "data subject", "processor" and "sensitive data" have the meaning defined by the General Data Protection Regulation (GDPR: n° 2016-679)

1. Management of personal data.

The Client is informed of the regulations regarding marketing communication, the law of June 21, 2014 for confidence in the Digital Economy, the Data Protection Act of August 06, 2004 as well as the General Data Protection Regulation (GDPR: n° 2016-679).

1.1 Responsible for the collection of personal data

For Personal Data collected as part of the creation of the User's personal account and their navigation on the Site, the person responsible for processing Personal Data is: ORPI. XXX is represented by Mathieu POIRIER, its legal representative.

As the person responsible for processing the data it collects, XXX undertakes to respect the framework of the legal provisions in force. It is in particular up to the Client to establish the purposes of its data processing, to provide its prospects and clients, from the collection of their consents, with complete information on the processing of their personal data and to maintain a register of treatments in line with reality. Whenever XXX processes Personal Data, XXX takes all reasonable measures to ensure the accuracy and relevance of the Personal Data with regard to the purposes for which XXX processes them.

1.2 Purpose of the collected data

XXX is likely to process all or part of the data:

  • to allow navigation on the Site and the management and traceability of the benefits and services ordered by the user: connection and use data of the Site, invoicing, order history, etc.
  • to prevent and fight against computer fraud (spamming, hacking…): computer equipment used for navigation, IP address, password (hashed)
  • to improve navigation on the Site: connection and usage data
  • to conduct optional satisfaction surveys on XXX: email address
  • to conduct communication campaigns (sms, mail): phone number, email address

XXX does not market your personal data, which is therefore only used by necessity or for statistical and analytical purposes.

1.3 Right of access, rectification and opposition

In accordance with current European regulations, Users of XXX have the following rights:

  • right of access (article 15 GDPR) and rectification (article 16 GDPR), updating, completeness of User data, right to block or erase personal User data (article 17 of the GDPR), when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication or conservation is prohibited
  • right to withdraw consent at any time (article 13-2c GDPR)
  • right to limit the processing of User data (article 18 GDPR)
  • right to oppose the processing of User data (article 21 GDPR)
  • right to the portability of the data that the Users have provided, when these data are subject to automated processing based on their consent or on a contract (article 20 GDPR)
  • right to define the fate of User data after their death and to choose to whom XXX must communicate (or not) their data to a third party that they have previously designated

As soon as XXX becomes aware of the death of a User and in the absence of instructions from them, XXX undertakes to destroy their data, unless their conservation proves necessary for probative purposes or to fulfill a legal obligation.

If the User wishes to know how XXX uses their Personal Data, ask to rectify them or object to their processing, the User can contact XXX in writing at the following address:

XXX – XXX
4 RUE D ABLOIS 17000 LA ROCHELLE.

In this case, the User must indicate the Personal Data that they would like XXX to correct, update or delete, by identifying themselves precisely with a copy of an identity document (identity card or passport).

Requests for the deletion of Personal Data will be subject to the obligations imposed on XXX by law, in particular regarding the conservation or archiving of documents. Finally, Users of XXX can file a complaint with the supervisory authorities, and in particular the CNIL (https://www.cnil.fr/en/complaints).

1.4 Non-communication of personal data

XXX refrains from processing, hosting or transferring the Information collected on its Clients to a country located outside the European Union or recognized as "not adequate" by the European Commission without informing the client in advance. However, XXX remains free to choose its technical and commercial subcontractors on the condition that they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: n° 2016-679).

XXX undertakes to take all necessary precautions to preserve the security of the Information and in particular that it is not communicated to unauthorized persons. However, if an incident impacting the integrity or confidentiality of the Client's Information is brought to the attention of XXX, the latter must inform the Client as soon as possible and communicate the corrective measures taken. Furthermore, XXX does not collect any "sensitive data".

The User's Personal Data may be processed by subsidiaries of XXX and subcontractors (service providers), exclusively in order to achieve the purposes of this policy.

Within the limits of their respective attributions and for the purposes mentioned above, the main persons likely to have access to the data of Users of XXX are mainly our customer service agents.

2. Incident notification

Regardless of the efforts made, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot therefore guarantee absolute security. If we become aware of a security breach, we will notify the users concerned so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether at national or European level. We are committed to fully informing our clients of all matters relating to the security of their account and to providing them with all the information necessary to help them comply with their own regulatory reporting obligations.

No personal information of the user of the site XXX is published without the user's knowledge, exchanged, transferred, assigned or sold on any medium to third parties. Only the assumption of the buyout of XXX and its rights would allow the transmission of said information to the eventual purchaser who would in turn be bound by the same obligation of conservation and modification of data with respect to the user of the site XXX.

Security

To ensure the security and confidentiality of Personal Data and Personal Health Data, XXX uses networks protected by standard devices such as firewalls, pseudonymization, encryption and passwords.

When processing Personal Data, XXX takes all reasonable measures to protect them against any loss, misuse, unauthorized access, disclosure, alteration or destruction.

3. Hypertext links "cookies" and internet tags

The site XXX contains a certain number of hypertext links to other sites, set up with the authorization of XXX. However, XXX does not have the possibility to check the content of the sites thus visited, and will therefore assume no responsibility for this fact.

Unless you decide to disable cookies, you accept that the site can use them. You can deactivate these cookies at any time and free of charge from the deactivation possibilities offered to you and recalled below, knowing that this may reduce or prevent accessibility to all or part of the Services offered by the site.

3.1. "COOKIES"

A "cookie" is a small information file sent to the User's browser and saved within the User's terminal (e.g. computer, smartphone), (hereinafter "Cookies"). This file includes information such as the User's domain name, the User's Internet service provider, the User's operating system, as well as the date and time of access. Cookies in no way risk damaging the User's terminal.

XXX is likely to process the User's information concerning their visit to the Site, such as the pages consulted, the searches carried out. This information allows XXX to improve the content of the Site and the User's navigation.

Cookies facilitating navigation and/or the provision of services offered by the Site, the User can configure their browser so that it allows them to decide whether or not they wish to accept them so that Cookies are recorded in the terminal or, on the contrary, that they are rejected, either systematically or according to their issuer. The User can also configure their browser software so that the acceptance or refusal of Cookies is offered to them punctually, before a Cookie is likely to be recorded in their terminal. XXX informs the User that, in this case, it is possible that the functionalities of their browser software are not all available.

If the User refuses the registration of Cookies in their terminal or browser, or if the User deletes those registered there, the User is informed that their navigation and experience on the Site may be limited. This could also be the case when XXX or one of its service providers cannot recognize, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings or the country from which the terminal appears to be connected to the Internet.

Where applicable, XXX declines all responsibility for the consequences linked to the degraded functioning of the Site and the services possibly offered by XXX, resulting (i) from the refusal of Cookies by the User (ii) from the impossibility for XXX to record or consult the Cookies necessary for their operation due to the User's choice. For the management of Cookies and User choices, the configuration of each browser is different. It is described in the browser's help menu, which will allow the User to know how they can modify their wishes regarding Cookies.

At any time, the User can choose to express and modify their wishes regarding Cookies. XXX may also use the services of external service providers to help it collect and process the information described in this section.

Finally, by clicking on the icons dedicated to the social networks Twitter, Facebook, Linkedin and Google Plus appearing on the Site of XXX or in its mobile application and if the User has accepted the deposit of cookies by continuing their navigation on the Website or the mobile application of XXX, Twitter, Facebook, Linkedin and Google Plus may also deposit cookies on your terminals (computer, tablet, mobile phone).

These types of cookies are only deposited on your terminals if you consent to them, by continuing your navigation on the Website or the mobile application of XXX. At any time, the User can nevertheless withdraw their consent for XXX to deposit this type of cookies.

3.2. INTERNET TAGS

XXX may occasionally use Internet tags (also known as "tags", or action tags, single-pixel GIFs, transparent GIFs, invisible GIFs and one-to-one GIFs) and deploy them through a specialist web analysis partner likely to be located (and therefore store the corresponding information, including the User's IP address) in a foreign country.

These tags are placed both in online advertisements allowing internet users to access the Site, and on the various pages of it.

This technology allows XXX to evaluate the responses of visitors to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the use of this Site by the User.

The external service provider may eventually collect information on visitors to the Site and other websites thanks to these tags, compile reports on the Site's activity for the attention of XXX, and provide other services relating to the use of it and the Internet.

4. Applicable law and attribution of jurisdiction.

Any dispute in connection with the use of the site XXX is subject to French law. Except in cases where the law does not allow it, exclusive jurisdiction is attributed to the competent courts of LA ROCHELLE.