Security and protection of personal data
This tool is made available to you free of charge. The tool is based on information derived from the firm’s professional analysis of EPM compliance. However, since compliance is a dynamic process and any situation is unique, the information provided should be tailored and should not be considered exhaustive or accurate.
Unless you request a review and validation by Cabinet, the generated document is considered to be information only. Consequently, you are solely responsible for the interpretations made of the information provided, the advice you derive from it and the adaptations made for your own commercial activity. The use and operation of the tool is therefore under your sole responsibility and at your own risk.
The Publisher : The person, natural or legal person, who publishes communication services to the public online.
The Site :All the sites, web pages and online services offered by the Publisher.
The User : The person using the Site and the services.
Nature of data collected
Within the framework of the use of the Sites, the Publisher is likely to collect the following categories of data concerning its Users:
Marital status data, identity data, identification data…
Connection data (IP addresses, event logs …)
Disclosure of personal data to third parties
No disclosure to third parties
Your data will not be disclosed to third parties. You are informed, however, that they may be disclosed pursuant to a law, a regulation or a decision of a competent regulatory or judicial authority.
Prior information for the disclosure of personal data to third parties in the event of a merger / takeover
Prior information and the possibility of opting out before and after the merger/acquisition
In the event that we take part in a merger, acquisition or any other form of asset disposal, we undertake to guarantee the confidentiality of your personal data and to inform you before it is transferred or subject to new confidentiality rules.
Purpose of the re-use of the personal data collected
Carry out operations relating to the management of clients concerning
- contracts; orders; deliveries; invoices; accounting and in particular the management of accounts receivable
- a loyalty programme within one or more legal entities ;
- lecustomer relationship management, such as conducting satisfaction surveys, managing complaints and after-sales service
- the selection of customers to carry out studies, surveys and product tests (except with the consent of the data subjects collected 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 origin, philosophical, political, trade union or religious opinions, sexual life or health of persons)
The development of trade statistics
Managing people’s opinions on products, services or content
Aggregation with non-personal data
We may publish, disclose and use aggregated 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 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 in the User’s corporate accounts
If you connect your account to an account of another service for the purpose of cross-mailing, that service may provide us with your profile information, login information, and any other information you have authorized to be disclosed. We may aggregate information about all of our other Users, groups, accounts, and personal data available to the User.
Collection of Identity Data
Consultation of the Site does not require prior registration or identification. It can be carried out without you communicating any personal data concerning you (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 user ID only for access to services
We use your electronic identifiers only for and during the execution of the contract.
Collection of terminal data
Collection of profiling 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, but is not limited to, 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 services.
Collection of technical data for advertising, commercial 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 to personalize and continually improve your experience on our Site. We do not collect or store any personal data (surname, first name, address, etc.) that may be attached to technical data. The data collected may be resold to third parties.
Cookie retention time
In accordance with the recommendations of the CNIL, the maximum retention period for cookies is a maximum of 13 months 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 lifetime of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.
Cookies may be used for statistical purposes, in particular to optimise the services rendered to the User, from the processing of information concerning the frequency of access, the personalisation 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 the consultation…) that we will be able to read during your subsequent visits.
Technical data maintenance
Retention period of technical data
The technical data are kept for the time strictly necessary to achieve the purposes referred to above.
Time limit for storing personal data and anonymisation
Retention of data for the duration of the contractual relationship
In accordance with article 6-5° of law n°78-17 of 6 January 1978 relating to data processing, data files and liberties, personal data subject to processing shall not be retained beyond the time necessary for the performance of the obligations defined at the time of the conclusion of the contract or the predefined duration of the contractual relationship.
Storage of anonymised data beyond the contractual relationship / after deletion of the account
We keep personal data for the time strictly necessary to achieve the purposes described in these TOS. Beyond this period, they will be anonymised and kept for exclusively statistical purposes and will not be used for any other purpose whatsoever.
Deletion of data after account deletion
Means shall be put in place to purge data in order to provide for their effective deletion as soon as the retention or archiving period necessary for the fulfilment of the purposes determined or imposed is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, files and liberties, you also have a right of deletion on 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 on the Site for a period of three years, you will receive an e-mail inviting you to connect as soon as possible, otherwise your data will be deleted from our databases.
Account deletion on request
The User has the possibility to delete his Account at any time, by a simple request to the Editor OR through the Account deletion menu present in the Account settings if necessary.
Deletion of the account in case of violation of the TOS
If you violate any provision(s) of the TOS or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict, without prior notice 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 of the User in case of a security breach
We undertake to implement all appropriate technical and organisational measures to guarantee 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 illegal access to your personal data stored on our servers or those of our service providers, or 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;
- Take the necessary measures within reason to minimize the negative effects and harm that may result from the incident.
Limitation of liability
Under no circumstances can the commitments defined in the above point relating to notification in the event of a security breach be assimilated to any admission of fault or liability for the occurrence of the incident in question.
Transfer of personal data abroad
No transfers outside the European Union
The Publisher undertakes not to transfer the personal data of its Users outside the European Union.
In case of modification of the present TOS, commitment not to substantially reduce the level of confidentiality without prior information of the persons 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 terms of recourse
You expressly agree that any dispute that may arise from these TOS, including its interpretation or execution, will be subject to an arbitration procedure subject to the rules of the arbitration platform chosen by mutual agreement, to which you will adhere without reservation.
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. These data must be provided in an open and easily reusable format.