Privacy policy

General Advice and Warnings

This tool is offered for free and is based on a professional analysis of GDPR compliance. However, since compliance is a dynamic process and every situation is unique, the information provided must be adapted. It should not be considered exhaustive or completely accurate.

Unless you specifically request a review and validation by the firm, the generated document is considered a simple informational guide. Therefore, you are solely responsible for how you interpret the information, the advice you derive from it, and any adaptations you make for your own business activities. Use of this tool is entirely at your own risk.

Definitions

The Publisher (L’Éditeur): The person or entity that publishes online communication services.

The Site (Le Site): All websites, internet pages, and online services offered by the Publisher.

The User (L’Utilisateur): The person using the Site and its services.

Data Collection

Types of Data Collected
When using the Sites, the Publisher may collect the following data categories about its Users:
Civil status, identity, and identification data.
Connection data (IP addresses, event logs, etc.).

Identity Data Collection
Free Consultation: Browsing the Site does not require registration or prior identification. You can do so without providing any personal identifying information (name, address, etc.). We do not record any personal data for simple Site visits.

Identification Data Collection
User ID: We use your electronic identifiers only for and during the execution of the contract.

Device Data Collection
No Technical Data Collected: We do not collect or store any technical data from your device (IP address, internet service provider, etc.).

Data Communication and Aggregation

Communication to Third Parties
No Third-Party Communication: Your data is not shared with third parties. However, you are informed that it may be disclosed if required by law, regulation, or a decision from a competent regulatory or judicial authority.

Prior Information in case of Merger/Acquisition: If we are involved in a merger, acquisition, or any other form of asset transfer, we commit to ensuring the confidentiality of your personal data. We will also inform you before your data is transferred or subjected to new privacy rules.

Prior Notice (Merger/Acquisition)

Prior Notice for the Communication of Personal Data to Third Parties in the Event of a Merger / Acquisition

Prior Notice and Opt-out Possibility
Before and After the Merger / Acquisition

In the event that we take part in a merger, acquisition, or any other form of asset transfer, we commit to guaranteeing the confidentiality of your personal data and to informing you before they are transferred or subjected to new privacy rules.

Purpose of the Re-use of Collected Personal Data

Purpose of the Re-use of Collected
Personal Data

The management of technical prospecting operations (which notably includes technical operations such as normalization, enrichment, and deduplication)

The selection of individuals for the purpose of carrying out loyalty programs, prospecting, surveys, product testing, and promotional actions.

Unless the data subject’s consent is obtained under the conditions provided for 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, religious opinions, sexual life, or 1health of individuals)

The execution of solicitation operations

The development of commercial statistics

The organization of contests, sweepstakes, or any promotional operation, excluding online gambling and chance games subject to the approval of the Online Gaming Regulatory Authority

Data Aggregation

Aggregation with Non-Personal Data: We may publish, disclose, and use aggregated information (data about all our Users, or specific groups, combined in a way that no individual can be identified). This is for purposes like industry analysis, demographic profiling, and promotional activities.

Aggregation with Personal Data from Social Accounts: If you connect your account to another service for cross-posting, that service may share your profile and connection information, as well as any other information you have authorized to be disclosed. We may then aggregate this information with data about our other Users, groups, and accounts.

Data Usage

Purpose of Personal Data Reuse

Data is collected to perform operations related to:
Prospecting Management: This includes technical operations such as data normalization, enrichment, and deduplication.

Audience Selection: Selecting individuals for loyalty programs, prospecting, surveys, product testing, and promotions. Unless consent is obtained, these operations will not lead to the creation of profiles containing sensitive data (e.g., racial or ethnic origins, political or religious opinions, health).

Solicitation Operations

Commercial Statistics

Contest and Promotion Organization (excluding online gambling subject to regulation).

Collection of Identity Data

Free Consultation / Open Access
Accessing the Site does not require prior registration or identification. It can be done without you providing any nominative data concerning you (name, surname, address, etc.). We do not record any nominative data for the mere consultation of the Site.

Collection of Identification Data

Use of the User Identifier only for Service Access
We use your electronic identifiers only for and during the execution of the contract.

Collection of Device Data

No Collection of Technical Data
We do not collect or store any technical data from your device (IP address, Internet Service Provider…).

Cookies

Cookie Retention Period: In accordance with CNIL recommendations, the maximum retention period for cookies is 13 months after they are first placed on the User’s device, just as the validity period 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 after this period.

Purpose of Cookies: Cookies can be used for statistical purposes, particularly to optimize the services provided to the User, based on the processing of information concerning access frequency, page personalization, as well as the operations performed and the information consulted. You are informed that the Publisher may place cookies on your device. The cookie records information related to navigation on the service (the pages you have viewed, the date and time of the consultation…) that we may read during your subsequent visits.

User’s Right to Refuse Cookies: You acknowledge that you have been informed that the Publisher may use cookies and you authorize it. If you do not want cookies to be used on your device, most browsers allow you to disable cookies through the settings options. However, you are informed that some services may no longer function correctly.

Possible Association of Cookies with Personal Data: The Publisher may be led to collect browsing information through the use of cookies.

Data Retention and Deletion

Technical Data Retention: Technical data is retained for the duration strictly necessary to achieve the purposes mentioned above in accordance with Article 6-5° of Law No. 78-17 of January 6, 1978, relating to data processing, files and freedoms.

Retention Period for Personal and Anonymized Data: Personal data is not kept beyond the time necessary to fulfill the obligations defined upon conclusion of the contract or the predefined duration of the contractual relationship. Beyond this period, it will be anonymized and kept for statistical purposes only and will not be used in any way.

Data Deletion after Account Deletion: Data purge mechanisms are put in place to ensure effective deletion once the retention or archiving period necessary for the fulfillment of the determined or imposed purposes has been reached. In accordance with the law, you also have a right to have your data deleted, which you can exercise at any time by contacting the Publisher.

Data Deletion 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 on Request: The User has the possibility to delete their account at any time, by simple request to the Publisher OR through the account deletion menu present in the Account settings, if applicable.

Account Deletion in Case of CGU Violation: In case of a violation of one or more provisions of the CGU or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict your use and access to the services, your account, and all Sites without any prior warning and at its sole discretion.

Security Breach Notification

User Information in Case of Security Breach: We commit to implementing all appropriate technical and organizational measures to guarantee a level of security adapted to 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 an illegal or unauthorized access to your personal data stored on our servers or those of our service providers, or an unauthorized access resulting in the risks identified above, we commit to:
o Notifying you of the incident as soon as possible.
o Examining the causes of the incident and informing you.
o Taking the necessary measures within reasonable limits to mitigate the negative effects and damage that may result from the said incident.

Limitation of Liability: Under no circumstances can the commitments defined in the point above regarding notification in the event of a security breach be assimilated to any acknowledgment of fault or responsibility for the occurrence of the incident in question.

Data Transfer and Policy Changes

Transfer of Personal Data Abroad: The Publisher undertakes not to transfer the personal data of its Users outside the European Union.

Modification of the CGU and Privacy Policy: In the event of a substantial modification of these CGU, we commit not to lower the level of confidentiality in a substantial way without first informing the individuals concerned and obtaining your consent.

Applicable Law and Recourse

Application of French Law (CNIL legislation) and Jurisdiction of the Courts: These CGU and your use of the Site are governed by and interpreted in accordance with the laws of France, and in particular Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms. The choice of applicable law does not affect your rights as a consumer in accordance with the law applicable in 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 CGU in France or in the EU country where you live. If you are a professional, all actions against us must be brought before a court in France.

Dispute Resolution: In the event of a dispute, the parties will seek an amicable solution before any legal action. Should these attempts fail, all challenges to the validity, interpretation, and/or execution of these CGU must be brought, even in the event of multiple defendants or a third-party claim, before the French courts.

Data Portability

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