Politique de confidentialité

Definitions :
The Publisher: The person, natural or legal, who publishes the online public communication services. 
The Site: All sites, 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
Connection data (IP addresses, event logs, etc.) 
Location data (movements, GPS data, GSM data, etc.) 


Communication of personal data to third parties
No communication to third parties
Your data will not be disclosed to third parties. However, you are informed that they may be disclosed in application of a law, a regulation or by virtue of a 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 are involved in a merger, acquisition or any other form of transfer of assets, we undertake to provide prior information and opt-out
of assets, we are committed to ensuring the confidentiality of your personal data and to informing you before your personal data is transferred or subjected to new confidentiality rules.


Purpose of the re-use of personal data collected To carry out operations relating to prospecting
– the management of technical prospecting operations (this includes technical operations such as standardisation, enrichment and deduplication)
– the selection of persons to carry out loyalty, canvassing, surveys, product testing and promotional activities. Unless the consent of the persons concerned is obtained under the conditions laid down 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 persons)
– the carrying out of solicitation operations
 
Aggregation of data
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 in such a way that an individual User cannot 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 an account on another service 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 with us. We may aggregate information about all of our other Users, groups, and accounts with available personal data about the User.


Collection of Identity Data
Free consultation
Consultation of the Site does not require registration or prior identification. It can be carried out without you providing any personal data about yourself (surname, first name, address, etc.). We do not record any personal data for the simple consultation of the Site.
Collection of identification data


Use of the user’s identifier only for access to the services
We use your electronic identifiers only for and during the execution of the contract.
 
Geolocation
Geolocation for the purpose of providing the service
We collect and process your geolocation data in order to provide our services to you. We may make use of personal data for the purpose of determining your geographical position 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, to deactivate the functions relating to geolocation.

Geolocation for crossover purposes
We collect and process your geolocation data in order to enable our services to identify the points of intersection in time and space with other Users of the service in order to present you with the profile of the crossed Users. In accordance with your right to object as provided for by law n°78-17 of 6 January 1978 relating to information technology, 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 undertake to anonymise 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, to deactivate the functions relating to geolocation.


Collection of terminal data
Collection of profiling data and technical data for the purpose of providing the service: 
Some of the technical data of your device 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, marketing and statistical purposes:
The technical data of your device is 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, etc.) that may be attached to technical data. The data collected may be sold to third parties.


Cookies
How long cookies are kept : 
In accordance with the recommendations of the CNIL, the maximum retention period for cookies is 13 months after they are first deposited in the User’s terminal, as is 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, based on the processing of information concerning the frequency of access, the personalisation of pages, 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, etc.) which the Publisher may store on your computer.
The cookie records information about your browsing on the service (the pages you have visited, the date and time of the visit, etc.) which we can read during your subsequent visits.


User’s right to refuse cookies
You acknowledge that you have been informed that the Publisher may use cookies. If you do not want cookies to be used on your terminal, most browsers allow you to disable cookies through the settings options.


Retention of technical data
Duration of the retention of technical data
Technical data is kept for the time strictly necessary to achieve the purposes mentioned above.


Storage period for personal data and anonymisation
No retention of data
We do not retain any personal data beyond the time you are connected to the service for the purposes described in these TOS.


Data deletion after account deletion
Means of data purging are set up in order to provide for the effective deletion of data as soon as the retention or archiving period 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, files and freedoms, you also have a right to delete your data that you can exercise at any time by contacting the Publisher.


Deletion of data after 3 years of inactivity
For security reasons, if you have not logged on to the Site for a period of three years, you will receive an e-mail inviting you to log on as soon as possible, otherwise your data will be deleted from our databases.

Account deletion
Deletion of account on request
The User may delete his or her Account at any time, by simple request to the Publisher OR by using the Account deletion menu in the Account settings if applicable.


Account deletion in the event of a breach of the TOS
If you violate any provision of the TOS or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict your use of and access to the Services, your Account and all Sites at its sole discretion without prior notice.
Indications in the event of a security breach detected by the Publisher


Informing the User of a Security Breach
We undertake to implement all appropriate technical and organisational measures to ensure a level of security appropriate 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 unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorised access resulting in the risks identified above, we undertake to


– Notify you of the incident as soon as possible;
– Examine the causes of the incident and inform you of them;
– Take reasonable steps to mitigate the negative effects and harm that may result from the incident


Limitation of liability
In no event shall the undertakings set out in the above section relating to notification of security breaches be construed as an admission of fault or liability for the occurrence of the incident in question.


Applicable law and remedies
No transfer outside the European Union
The Publisher undertakes not to transfer the personal data of its Users outside the European Union.


Changes to the TOU and Privacy Policy
In the event of a change to the TOS, we will not lower the level of privacy substantially without first informing the individuals concerned
We undertake to inform you in the event of a substantial change to these TOU, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.


Applicable law and methods of recourse
Application of French law (CNIL legislation) and jurisdiction of the courts
These GTUs and your use of the Site are governed by and construed in accordance with the laws of France, and in particular with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms. Your choice of law does not affect your rights as a consumer under the applicable law of your place of residence. If you are a consumer, you and we agree to submit to the non-exclusive jurisdiction of the French courts, which means that you may bring an action relating to these TOU in France or in the EU country in which you live. If you are a professional, 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 taking any legal action. If these attempts fail, all disputes concerning the validity, interpretation and/or execution of these GTUs must be brought before the French courts, even in the event of multiple defendants or third-party claims.


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 re-using them. This data must be provided in an open and easily reusable format.

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