PERSONAL DATA

Definitions

The Publisher: The person, natural or legal, who publishes the online public communication services.
The Site: All the sites, Internet pages and online services offered by the Publisher.
The User: The person using the Site and the services.

1- Nature of collected data

When using the Sites, the Publisher may collect the following categories of data
about its Users:
:
Personal data, identity data, identification data...
Connection data (IP addresses, event logs...)

2- Disclosure of personal data to third parties

No disclosure to third parties
Your data will not be disclosed to third parties. However, you are informed that
your data may be disclosed in application of a law, a regulation or by virtue of a decision of a competent regulatory
or judicial authority.

3- Prior information for the communication of personal data to third parties in case of merger / absorption

Collection of opt-in consent for data transfer following a merger
acquisition

In the event that we become involved in a merger, acquisition or other form
we will obtain your prior consent to the transfer of your personal data
and maintain the level of confidentiality of your personal data to which you have consented.

4- Aggregating 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 so that an
individual User can no longer 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 another service's account 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. We may aggregate information about all of our other Users,
groups, and accounts with the personal data available about the User.

5- Identity data collection

Free consultation
Consultation of the Site does not require registration or prior identification. It can be done without
you communicating any personal data about yourself (name, first name, address, etc.). We do not
ecord any personal data for the simple consultation of the Site.

6- Collection of identification data

Use of the user's ID only for access to the services
We use your electronic identifiers only for and during the execution of the contract.

7- Terminal data collection

Collection of profiling and technical data for
service delivery purposes

Some of your device's technical data is automatically collected 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.
Collecte des données techniques à des fins publicitaires, commerciales et statistiques
Les données techniques de votre appareil sont automatiquement collectées et enregistrées par le
Site, à des fins publicitaires, commerciales et statistiques. Ces informations nous aident à
personnaliser et à améliorer continuellement votre expérience sur notre Site. Nous ne collectons ni
ne conservons aucune donnée nominative (nom, prénom, adresse…) éventuellement attachée à
une donnée technique. Les données collectées sont susceptibles d’être revendues à des tiers.

8- Cookies

Duration of the conservation of cookies
In accordance with the recommendations of the CNIL, the maximum duration of conservation of cookies is 13 months
after their first deposit in the terminal of the User, 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 optimize the services rendered to
he User, based on the processing of information concerning the frequency of access, the personalization of
he pages as well as 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 consulted, the date and time
of the consultation, 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 device, most browsers allow you to disable
cookies through the settings options.

9- Technical data storage

Duration of technical data retention
The technical data are kept for the time strictly necessary to achieve
the purposes mentioned above.

10- Retention period of personal data and anonymization

Data retention for the duration of the contractual relationship
According to article 6-5° of the law n°78-17 of January 6, 1978 relating to data processing, files and
freedoms, the personal data being the subject of a treatment are not preserved beyond the
time necessary to the execution of the obligations defined at the time of the conclusion of the contract or of the predefined duration
of the contractual relation.
Retention of anonymized data beyond the contractual relationship / after account
deletion

We keep personal data for the time strictly necessary to achieve the purposes
described in this Privacy Policy. After this period, the data will be anonymized and
kept exclusively for statistical purposes and will not be used in
any way whatsoever.
Deleting data after account deletion
Data purging means are set up in order to provide for their effective deletion 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, the files and freedoms,
you have moreover a right of suppression on your data which you can exert constantly by
taking contact with the Editor.
Data deletion after 3 years of inactivity
For security reasons, if you have not logged in to the Site for a period of three years,
you will receive an e-mail inviting you to log in as soon as possible, otherwise your data will be
deleted from our databases.

11- Account deletion

Deletion of account on request
User may delete their Account at any time by simply requesting the Publisher OR by using
the Account deletion menu in the Account settings if applicable.
Account deletion for violations of the Privacy Policy
If you violate any provision(s) of the Privacy Policy or any other
document incorporated herein by reference, Publisher reserves the right to terminate or restrict, without
prior notice and in its sole discretion, your use of and access to the Services, your account
and all Sites.

12- Indications in case of a security breach detected by the Publisher

Information to the User in case of a security breach
We undertake to implement all appropriate technical and organisational measures in order
to guarantee a level of security appropriate to the risks of accidental, unauthorised or illegal access,
disclosure, alteration, loss or destruction of personal data concerning you. 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 unauthorized 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;
To take the necessary measures within the limits of reasonableness in order to reduce the negative effects and prejudices
that may result from the said incident.
Limitation of liability
Under no circumstances may the commitments defined in the above point concerning notification in the event of a security breach be
assimilated to any recognition of fault or responsibility for the occurrence of
the incident in question.

13- Transfer of personal data abroad

No transfer outside the EU
The Publisher undertakes not to transfer the personal data of Users outside
the European Union.

14- Modification of the privacy policy

In case of modification of this Privacy Policy, commitment not to lower the
level of privacy substantially without prior information of the persons
concerned

We will inform you of any material changes to this Privacy
Policy, and will not lower the level of confidentiality of your data substantially without
informing you and obtaining your consent.

15- Droit applicable et modalités de recours

Application of French law (CNIL legislation) and jurisdiction of the courts
This Privacy Policy and your use of the Site shall be 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 data processing, files and
liberties. 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 this Privacy Policy in France or in the EU country in which you
live. If you are a business person, all actions against us must be brought in 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, any disputes regarding the validity, interpretation and/or execution of the Privacy Policy
must be brought before the French courts, even in the event of multiple defendants or
third-party claims.

16- Data Portability

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 reusing them. This data must be provided in an open
and easily reusable format