This tool is made available to you free of charge. The tool is based on information derived 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.
Unless you request a review and validation by the Firm, the document generated is considered as mere information. Consequently, you alone are responsible for interpreting the information provided, for the advice you deduce from it and for the adaptations you make for your own commercial activity. The use and exploitation of the tool is therefore under your sole responsibility and at your own risk.
The Publisher: The natural or legal person 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.
In the course of using the Sites, the Publisher may collect the following categories of data concerning its Users:
Data relating to marital status, identity, identification, etc.
Data relating to personal life (lifestyle, family situation, excluding sensitive or dangerous data)
Connection data (IP addresses, event logs, etc.) Location data (movements, GPS, mobile phone data, etc.)
No communication 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, regulation or by virtue of a decision by a competent regulatory or judicial authority.
In the event that we take part in a merger, acquisition or any other form of transfer of assets, we undertake to guarantee the confidentiality of your personal data and to inform you before they are transferred or made subject to new confidentiality rules.
contracts; orders; deliveries; invoices; accounting and in particular the management of customer accounts
a loyalty programme within one or more legal entities;
monitoring customer relations, such as conducting satisfaction surveys, managing complaints and after-sales services
the selection of customers for studies, surveys and product tests (unless the consent of the persons concerned is obtained under the conditions set out 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 individuals)
management of technical canvassing operations (including technical operations such as standardisation, enrichment and de-duplication)
the selection of persons to carry out loyalty-building, canvassing, surveys, product testing and promotional activities. Unless the consent of the persons concerned has been obtained under the conditions laid down in article 6, these operations must not lead to the creation 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 concerned).
solicitation operations
We may publish, disclose and use Aggregate 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 the following purposes
sector 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 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, accounts, with the personal data available about the User.
Consultation of the Site does not require prior registration or identification. You can do so without providing any personal data (surname, first name, address, etc.). We do not record any personal data simply for consulting the Site.
Use of the user’s identifier only for access to services
We use your electronic identifiers only for and during the performance of the contract.
Geolocation for the purposes of providing the service
We collect and process your geolocation data in order to provide you with our services. We may use personal data to determine your geographical position in real time. In accordance with your right of opposition under the French Data Protection Act no. 78-17 of 6 January 1978, you may deactivate the geolocation functions at any time.
We collect and process your geolocation data to enable our services to identify the points at which you cross paths in time and space with other Users of the service in order to present you with the profile of the Users crossed. In accordance with your right to object as set out in law no. 78-17 of 6 January 1978 relating to data processing, data files and individual liberties, you may, at any time, deactivate the functions relating to geolocation. You acknowledge that the service will no longer be able to present you with profiles of other Users.
Geolocation made available to partners for referencing and aggregation (with opt-in) We may collect and process your geolocation data with our partners. We undertake to anonymise the data used. In accordance with your right of opposition under the French Data Protection Act no. 78-17 of 6 January 1978, you may deactivate the geolocation functions at any time.
Some of your device’s technical data is collected automatically by the Site. This
information includes in particular your IP address, Internet access provider, hardware configuration, software configuration, browser type and language, etc. The collection of this data is necessary for the provision of services.
Your device’s technical data is automatically collected and recorded by the Site for advertising, commercial and statistical purposes. This information helps us to personalise 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 sold to third parties.
In accordance with CNIL recommendations, cookies are kept for a maximum of 13 months after they are first placed on the User’s terminal, as is the period of 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.
Cookies may be used for statistical purposes, in particular to optimise the services provided to the User, based on the processing of information concerning the frequency of access, the personalisation of pages, 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.) which we can read during your subsequent visits.
You acknowledge that you have been informed that the Publisher may use cookies and authorise it to do so. If you do not wish cookies to be used on your terminal, most browsers allow you to deactivate cookies via the settings options. However, you should be aware that some services may no longer function correctly.
The Publisher may collect browsing information through the use of cookies.
Technical data is kept for the time strictly necessary to achieve the purposes set out above.
Retention period for personal data and anonymisation
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 on data processing, data files and individual liberties, personal data that is the subject of processing is not kept beyond the
the time required to fulfil the obligations defined when the contract was concluded or the predefined duration of the contractual relationship.
We retain personal data for the period strictly necessary to achieve the purposes described in these GCU. After this period, the data will be anonymised and kept exclusively for statistical purposes and will not be used in any way whatsoever.
Means of data purging are put in place to provide for the effective deletion of data as soon as the storage or archiving period required to fulfil the purposes determined or imposed has been reached. In accordance with the French Data Protection Act no. 78-17 of 6 January 1978, you also have the right to delete your data, which you may exercise at any time by contacting the Publisher.
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 on as soon as possible, failing which your data will be deleted from our databases.
The User may delete his/her Account at any time, by simple request to the Publisher OR via the Account deletion menu in the Account settings, if applicable.
If you breach any provision of the TOS 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 and without prior notice to you.
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 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;
To take the necessary measures within reasonable limits in order to reduce the negative effects and prejudices that may result from the said incident.
Under no circumstances may the undertakings set out in the point above relating to 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.
The Publisher undertakes not to transfer the personal data of its Users outside the European Union.
We undertake to inform you in the event of any substantial modification to these GCU, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.
You expressly agree that any dispute that may arise as a result of these GCU, in particular its interpretation or performance, will be referred to arbitration subject to the rules of the arbitration platform chosen by mutual agreement, to which you will adhere unreservedly.
The Publisher undertakes to offer you the possibility of having all your personal data returned to you on request. In this way, the User is guaranteed greater control over his or her data and retains the possibility of re-using it. This data must be provided in an open and easily reusable format.
