This tool is made available to you free of charge. The tool is based on information from the firm's professional analysis of RGPD compliance. However, as compliance is a dynamic process and every situation is unique, the information provided must be adapted and can in no way be considered exhaustive or accurate.
The document provided is considered as mere information. Consequently, you are solely responsible for the interpretation of the information provided, the advice you derive from it and the adaptations made for your own business activity. The use and exploitation of the tool is therefore under your sole responsibility and at your own risk.
The Publisher: The person, natural or legal, who publishes the online public communication services.
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 the data collected
In the course of using the Sites, the Publisher may collect the following categories of data about its Users :
- Civil status, identity and identification data, etc.
- Optional location data (movements, GPS data)
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 disclosure of personal data to third parties in the event of a merger/absorption
In the event that we become involved in a merger, acquisition or any other form of asset transfer, we undertake to ensure the confidentiality of your personal data and to inform you before it is transferred or subjected to new confidentiality rules.
Purpose of re-use of personal data collected
- To carry out operations relating to the management of customers concerning :
- contracts; orders; deliveries; invoices; accounting and in particular the management of customer accounts
- a loyalty programme within one or more legal entities
- customer relationship management such as satisfaction surveys, complaints management and after-sales service
- the selection of customers to carry out studies, surveys and product tests (unless the consent of the persons concerned 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 or religious opinions, sex life or health of the persons)
- The compilation of commercial statistics
- Management of people's opinions on products, services or content
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 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 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 the personal data available about the User.
Connecting with a federated identity provider
The Editor offers a fast and secure connection thanks to federated identity providers such as Google, Apple, Microsoft, Facebook, etc. We collect the profile and identification information transmitted by the identity provider.
Collection of identity data
The use of the Site requires registration and prior identification. Your personal data (name, first name, postal address, e-mail, telephone number,...) are used to carry out our legal obligations resulting from the delivery of the products and/or services, under the End User License Agreement, the Warranty Term, if applicable, or any other applicable condition. You will not provide false identifying information or create an account for another person without their permission. Your contact information must always be accurate and up to date.
Collection of identifying information
- Use of user ID only for access to services
We use your electronic identifiers only for and during the performance of the contract.
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 relating to data processing, files and freedoms, you have the possibility, at any time, of deactivating the functions relating to geolocation.
Collection of terminal data
Some of the technical data of your device are automatically collected by the Site. This information includes in particular your IP address, type and version of platform, user language. The collection of this data is necessary for the provision of the services.
Cookies are used only for the technical operation of the user account and its preferences. They are not used for advertising purposes.
Storage of technical data
Technical data is kept for the time strictly necessary to achieve the purposes mentioned above purposes mentioned above.
Data transmission and storage
Data is end-to-end encrypted during transmission. They are stored on computer servers with limited access located in controlled facilities.
Conservation period for personal data and anonymisation
- Conservation of data for the duration of the contractual relationship
Personal data that is subject to processing is not kept beyond the time necessary to fulfil the obligations defined at the time of the conclusion of the contract or the predefined duration of the contractual relationship.
- Retention of anonymised data beyond the contractual relationship / after deletion of the account
We keep personal data for the period of time strictly necessary to achieve the purposes described in these GTC. After this period, the data will be anonymised and kept exclusively for statistical purposes and will not be used in any way whatsoever.
- Deletion of data after deletion of the account
Means of purging data are put in place in order to provide for the effective deletion of data as soon as the period of conservation or archiving necessary for the achievement of the determined or imposed purposes is reached. You also have the right to delete your data 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 in as soon as possible, otherwise your data will be deleted from our databases.
- Deletion of account on request
The User may delete his or her Account at any time, by simple request to the Publisher OR through the Account deletion menu in the Account settings if applicable.
- Account deletion in the event of a breach of the TCU
If you violate any provision of the TCU 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 case 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 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
- Take reasonable steps to mitigate the negative effects and damage that may result from the incident
- Limitation of liability
In no event shall the undertakings set out in the above point relating to notification in the event of a security breach be construed as an admission of fault or liability for the occurrence of the incident in question.
In the event of a change to these TCU, we undertake not to lower the level of privacy substantially without informing the persons concerned in advance. We undertake to inform you in the event of a substantial change to these TCU, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.
Applicable law and remedies
You expressly agree that any dispute that may arise as a result of these TCU, including its interpretation or performance, shall be subject to arbitration under the rules of the mutually agreed upon arbitration platform, to which you shall 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 better control of his or her data, and retains the possibility of reusing it. This data must be provided in an open and easily reusable format.