Personal data protection policy

(document last updated on 2018 October 1st.)

As part of its activities and in accordance with the regulations applicable in Europe, particularly the EU General Data Protection Regulation, the SERVICE EDITOR is committed to ensuring the protection, confidentiality and security of the personal data of its USERS, as well as to respecting their privacy.

The Personal Data Protection Policy applies to the data collection and processing performed on its online Websites and online applications for smartphones, tablets and other mobile devices (the "Apps").

Our Websites and Apps are not intended for minors unless authorised by their legal representatives.

The Personal Data Protection Policy may be subject to changes. It is specified that the SERVICE EDITOR may amend the Personal Data Protection Policy at any time, including to adapt it to current legislation. USERS are made aware of these modifications simply through their publication online. We recommend that you regularly check the current version available.

The Personal Data Protection Policy sets out the principles and methods of the data processing.

Principles of data and privacy protection

1. Fair collection of the personal data of its customers, prospects and users

The data is collected in a fair and transparent way. The SERVICE EDITOR is prohibited from collecting personal data without first informing the persons concerned, including what their data is used for.

The SERVICE EDITOR collects this data in order to:

provide the services requested by its USERS,
meet the management needs of its USERS.

2. Use of the personal data of its customers, prospects and users

The SERVICE EDITOR uses the data of natural persons for purposes of authentication, providing subscribed services and suggesting offers tailored to the needs of its customers, prospects and visitors. To this end, the SERVICE EDITOR is likely to carry out statistical studies based on this data.

The SERVICE EDITOR complies with the legal framework in force concerning the protection of personal data and the conditions of security and confidentiality. The SERVICE EDITOR only communicates the personal data to its authorised service providers and ensures that they meet strict conditions of confidentiality, use and protection of this data.

The SERVICE EDITOR is prohibited from communicating the personal data to business partners without informing its USERS and without having offered them the opportunity to exercise their right to object.

3. Necessary measures to ensure the security of the personal data of its customers, prospects and users

The SERVICE EDITOR ensures the protection of the personal data entrusted to it, from the design stage and throughout the lifecycle of the services of the Websites or Apps.

It implements security measures appropriate to the degree of sensitivity of the data in order to protect personal data against malicious intrusion, any loss, alteration or disclosure to unauthorised third parties.
The information system, servers and networks that it uses to process and store personal data have security and protection systems (data encryption, firewall, redundancy, backup, etc.).
It guarantees the security of the information exchanged in transactions or payments.
It only issues access permissions for its information system to those who need them to perform their duties.
It educates its employees on the protection of the personal data made available to them as part of their duties and ensures that they comply with the rules in force and company's ethics.
It requires its suppliers to adhere to these same principles of protection.

Data protection at the SERVICE EDITOR

1. What data is collected and how?

By browsing our Websites or using our Apps and services, the SERVICE EDITOR, its service providers or business partners may collect data subject to your prior consent.

Some data is communicated to us directly by you, such as your first and last names, email address, password, phone number, complaints or opinions you might share with us.

This information is provided when:

you create an account on our Website or Apps,
you participate in a game or competition,
you contact us and fill out a form,
you write a comment,
you subscribe to one of our newsletters.

Some data, subject to your prior consent, may be collected automatically as a result of your actions on the Websites and Apps through cookies or similar technologies such as IP address, connection and browsing data, your preferences and hobbies, and general geographic location.

This information is provided whenever you browse our Websites and Apps.

2. What are the purposes of the data collected about you?

We use the collected data to:

Provide content and services which:

recognise you when you return to browse our Websites or use our Apps;
respond to your requests expressed on our Websites and Apps, including on forms;
offer you Services and personalised content according to your general geographic location (country);
allow you to write comments about the content of our Websites and Apps;
customise the display of content and Services;
send you newsletters and push notifications, news alerts;

Advertise our content and services, and those of our partners, which:

offer content tailored to your interests and carry out targeted advertising;
send communications and analyse their effectiveness;

Perform studies and analyses on our content and services in order to:

better understand the users of our Websites and Apps;
perform data analysis and statistical studies to develop and improve our Websites or Apps;

To ensure the security of your data.

3. Who are the recipients of the data collected?

The data collected on the Sites and Apps are intended for the SERVICE EDITOR.

They may be transmitted or accessed by the service providers of the SERVICE EDITOR in the context of performing processing, data analysis and computer services.

The SERVICE EDITOR requires its service providers to only use your personal data to manage the services entrusted to them, in accordance with the regulations applicable for the protection of personal data and confidentiality of this data.

4. Where is your personal data stored?

Your personal data is stored inside the European Union, either in our databases or in those of our service providers.

In some cases, and mainly for technical reasons, data may be stored on servers located outside the European Union.

5. Data transfers outside the EU

Due in particular to the international dimension of the SERVICE EDITOR, some of our partners are located outside the European Union. The data collected may therefore be transferred to countries outside the European Union which have different personal data protection legislation from those inside the European Union.

In this case, the SERVICE EDITOR implements the means to ensure the security and confidentiality of such data and ensures that the transfer meets the legal framework: the transfer to a country ensuring a sufficient level of protection, signature of contractual clauses issued by the European Commission, or any other regulatory or contractual means to ensure a sufficient level of protection.

The SERVICE EDITOR strictly requires its partners to only use your personal data to manage or provide the services requested, and also asks its partners to always act in compliance with the applicable laws on personal data protection and pay particular attention to the confidentiality of such data.

Transfers outside the European Union may be carried out, in particular, as part of our subsequent activities such as computer services on the SERVICE EDITOR’s systems.

6. How and for how long is your data stored?

The SERVICE EDITOR implements all administrative, technical and physical measures to protect personal data.

Personal data is stored for the duration required for the processing purposes for which it was collected except where retention for a longer duration is required by law, regulations or for trial purposes.

Examples:

Purpose(s)	Data	Storage duration
Business contacts	First and last name, company, email address, message	12 months from the last exchange
To report a problem, make a comment or suggestion about the Websites or Apps	First and last name, email address, name and version of the browser used, message	12 months from the last exchange

7. What are your rights?

The SERVICE EDITOR is committed to respecting the exercising of all of the rights of its USERS with regard to access, correction, additional information and objection. The persons concerned also have limitation, portability and erasure rights (right to be forgotten).

The SERVOCE EDITOR has appointed a Data Protection Officer, who is the principal contact for the protection of personal data, both within our organization as well as in its relations with the persons concerned.

People can exercise their rights by sending a request accompanied by proof of identity by visiting the ad-hoc section at the SERVICE EDITOR Website.

Where your request for right of access, rectification or objection relates to the data collected by a partner of the SERVICE EDITOR, we invite you to contact that partner, in their capacity as controller.