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.

Nature of the data collected

As part of the use of the Sites, the Publisher may collect the following categories of data concerning its Users:

Communication of personal data to third parties

No communication to third parties.

Your data are not communicated to third parties. However, you are informed that it may be disclosed in application of a law, a regulation or by virtue of a decision of a competent regulatory or judicial authority.

Prior notice for the communication of personal data to third parties in the event of a merger / takeover

Collection of opt-in (consent) prior to the transmission of data following a merger / acquisition

In the event that we take part in a merger, acquisition or any other form of transfer of assets, we undertake to obtain your prior consent to the transmission of your personal data and to maintain the level of confidentiality of your personal data to which you have consented.

Purpose of the reuse of collected personal data

The development of commercial statistics

Aggregation of data

Aggregation with non-personal data

We may publish, disclose and use aggregated information (information relating to all of our Users or to specific groups or categories of Users that we combine in such a way that an individual User can no longer be identified or mentioned) and non-personal information for the purposes of industry and market analysis, demographic profiling, promotional and advertising purposes and other commercial purposes.

Aggregation with personal data available on the User’s social accounts

If you connect your account to an account of another service in order to make cross-sendings, said service may communicate to us your profile information, connection, as well as any other information that you have authorized the disclosure of. We may aggregate information relating to all our other Users, groups, accounts, with the personal data available on the User.

Collection of identity data

Free consultation

Consultation of the Site does not require registration or prior identification. It can be done without you communicating any personal data concerning you (last name, 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 ID only for access to the services

We use your electronic identifiers only for and during the execution of the contract.

Collection of terminal data

No collection of technical data

We do not collect or store any technical data from your device (IP address, Internet service provider, etc.).

Cookies

Duration of storage of cookies

In accordance with the recommendations of the CNIL, the maximum duration of storage of cookies is 13 months maximum after their first deposit in the User’s terminal, as is the duration of the validity of the User’s consent to the use of these cookies. The lifespan 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 provided to the User, based on the processing of information concerning the frequency of access, the personalization of 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 have consulted, the date and time of consultation, etc.) that we can read during your subsequent visits.

User’s right to refuse cookies

You acknowledge having 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 deactivate cookies by going through the settings options.

Storage of technical data

Duration of storage of technical data

Technical data is stored for the period strictly necessary to achieve the purposes referred to above.

Period of retention of personal data and anonymization

Retention of data for the duration of the contractual relationship

In accordance with Article 6-5° of Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, personal data subject to processing are not retained beyond the time necessary to perform the obligations defined when concluding the contract or the predefined duration of the contractual relationship.

Retention of anonymized data beyond the contractual relationship / after deletion of the account

We retain personal data for the period strictly necessary to achieve the purposes described in these T&Cs. Beyond this period, they will be anonymized and retained for exclusively statistical purposes and will not give rise to any exploitation of any nature whatsoever.

Deletion of data after account deletion

Data purging methods are implemented to provide for effective deletion as soon as the retention or archiving period necessary to achieve the determined or imposed purposes is reached. In accordance with Law No. 78-17 of January 6, 1978, relating to information technology, files and freedoms, you also have the right to delete your data, which 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 authenticated yourself on the Site for a period of three years, you will receive an email inviting you to log in as soon as possible, otherwise your data will be deleted from our databases.

Account deletion

Account deletion upon request

The User may delete his Account at any time, by simple request to the Publisher OR via the Account deletion menu in the Account settings, if applicable.

Account deletion in the event of a violation of the T&Cs

In the event of a violation of one or more provisions of the T&Cs or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict, without any prior warning and at its sole discretion, your use and access to the services, your account and all Sites.

Indications in the event of a security breach detected by the Publisher

Information to the User in the event of a security breach

We undertake to implement all appropriate technical and organizational measures to guarantee an appropriate level of security regarding the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.

In the event that we become aware of illegal access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the realization of 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 thereof.

Take the necessary measures within reason to reduce the negative effects and damages that may result from said incident

Limitation of liability

Under no circumstances may the commitments defined in the point above relating to notification in the event of a security breach be equated with any recognition of fault or liability for the occurrence of the incident in question.

Transfer of personal data abroad

No transfer outside the European Union.

The Publisher undertakes not to transfer its Users’ personal data outside the European Union.

Modification of the T&Cs and the privacy policy

In the event of a modification of these T&Cs, we undertake not to substantially lower the level of confidentiality without first informing the persons concerned

We undertake to inform you in the event of a substantial modification of these T&Cs, and not to substantially lower the level of confidentiality of your data without informing you and obtaining your consent.

Applicable law and methods of appeal

Application of French law (CNIL legislation) and jurisdiction of the courts

These T&Cs and your use of the Site are governed by and interpreted in accordance with the laws of France, and in particular with Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms. The choice of applicable law does not affect your rights as a consumer in accordance with 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 can bring an action relating to these T&Cs 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 any legal action. If these attempts fail, all disputes regarding the validity, interpretation and/or execution of these T&Cs must be brought, even in the event of multiple defendants or a third-party claim, before the French courts.

Data portability

The Publisher undertakes to offer you the possibility of having all of the data concerning you returned to you upon simple request. The User is thus guaranteed better control over his data and retains the possibility of reusing it. This data must be provided in an open and easily reusable format.