Art. 1 - Notification & Definition of Personal Data
During the course of your use of our Website, we might have to request you to provide us with some of your Personal Data or have access to such Personal Data.
For the purpose of this Policy, "Personal Data" shall mean any and all information that permit to identify an individual, directly or indirectly, such as but not limited to name, first name, nickname, pseudonym, photograph, physical and/or email address, phone number, birth date, in particular by reference to identification numbers, data exchanged with this Website, and any other related personal information that you would decide to share with us.
Art. 2 - Purpose of the present Policy
The purpose of the present Policy is to inform you on the means and aims of collection and handling of your Personal Data, in due compliance with your personal rights.
To this end, please be informed that we would comply with the requirements of the French "Computer and Freedom" Law number 78-17 dated as of January 6th, 1978 and of the EU General Data Protection Regulation ref 2016/679 (together, the "GDPR"), in their latest versions, and any regulatory enactment thereof.
Art. 3 - Identity of the Data Controller
The Data Controller (as defined under the GDPR) in charge of ensuring the rightful collection, management, processing and storage of Personal Data is PhinC Development, a "SARL" ("limited liability company") organised and existing under French laws, registered with the RCS of Évry (France) under number 508 730 587, with its registered offices located at:PhinC Development
5 rue Henri Auguste Desbruères
Genopole Campus 1
91030 ÉVRY CEDEX
Art. 4 - Purposes of collection, processing and storage of your Personal Data
Your Personal Data are collected for one or more of the following purposes:
- Managing your access to and use of some of our services on our Website platform,
- Managing our services toward our clients, the Website users and prospects, such as answering to requests, implementation and follow-up of agreements, cost estimates, provision of services, invoicing and customer relationship;
- File creation and follow-up of our website users, clients and prospects;
- Providing you with newsletters, solicitation messages and/or advertisements. In the case you do not want to receive such information, you would be able to exercise your right of refusal during the collection of your Personal Data and at any time afterward;
- Participation studies and commercial statistical analysis on our website, offers and services;
- Arranging any promotional activities;
- Follow-up of comments and inputs (opinions, advices, reviews, …) related to our solutions, services and contents;
- Handling potential delinquencies and litigations relating to the use of our products and services;
- Complying with our legal and regulatory obligations.
During the collection of Personal Data, you would be informed which Personal Data is mandatory and which is optional. We may also inform you about the non-obvious consequences of a lack of answer from your side.
Art. 5 - Other Personal Data Recipients and Processors
The following individuals and entities may have access to and process your Personal Data:
Our company’s and its affiliates’ employees, agents, representatives and their IT providers and subcontractors having a need-to-know for the aforementioned purposes.
Auditors, officers, public institutions and committees, other authorities, agencies, jurisdictions and any similar entities controlling our company (such as but not limited to accounting and other regulatory compliance matters), as may be required by law or in order for us to demonstrate compliance with our contractual and/or legal obligations, undertakings and rights.
Art. 6 - No other commercial transfers of Personal Data
As a principle, your Personal Data will not be transferred for any other commercial purposes to any other third parties than those mentioned above, except otherwise instructed by you.
Art. 7 - Duration of Personal Data storage
Art. 7.1 - Personal Data related to the management of our clients and prospects
Your Personal Data will not be stored for more than strictly necessary for the needs of our commercial relationship with you. Notwithstanding, as mentioned above, pieces of Personal Data might be stored for further periods for evidence purpose and/or in order to comply with legal or regulatory obligations, notably, with regard to proof of facts, of rights, of obligations, of agreements and/or other understandings, up to the legal storage requirements or prescription in force.
With regard to potential prospective operations toward our clients, their Personal Data may be stored for a period of up to three (3) years as from the expiry of the last commercial relationship.
Personal Data related to a non-client prospect may be stored for a period of up to three (3) years as from their collection or as from the last contact with such prospect.
Upon expiry of such storage period, we might contact you in order for you to decide to receive or not any further commercial solicitations.
Art. 7.2 - Identity Documents
In case you exercise your right to access and/or to correction with regard to your Identity Documents, such Personal Data may be stored for one (1) year or any further period of time required by applicable law(s). In case you exercise your right to object, such data may be stored for three (3) year or any further period of time required by applicable law(s).
Art. 7.3 - Personal Data related to credit and payment instruments
Financial transactions may be subcontracted to a payment services provider which is responsible for their proper execution and security.
For the purpose of those services, such a service provider may have access to your Personal Data relating to your payment instruments, which it collects and stores in our name and for our sole profit. We have no access to such Personal Data.
Such data are solely stored as purchase and payment tools, for the duration of your inscription on our Website and, until you perform your last transaction.
Your consent to such storage is given by clicking on the appropriate box in our Website.
Data related to your credit card verification number are solely stored for the duration of the transaction.
In case you oppose to the storage of your Personal Data related to your payment instruments numbers, as mentioned above, such data would be destroyed once the transaction is executed.
In any case, the data that needs to be stored for legal and/or evidence purposes, would be stored, as intermediate archives, for the period(s) prescribed by law.
Art. 7.4 - Handling of objection lists to propection
The information permitting us to comply with your right to object would be stored for three (3) years as from your request of objection.
Art. 7.5 - Audience measurement system analytics
Identified or identifying information permitting the traceability and visitation of users of our Website would be stored for the purposes stated in the heading for a maximum duration of six (6) months.
Art. 8 - Security
We secure your Personal Data with all useful precautions and appropriate organizational and technical measures in order to ensure the protection of its safety, integrity and confidentiality, and notably, to prevent misrepresentation, damages and/or access by unauthorized third parties.
Art. 9 - Cookies
Cookies are files under text format, generally encrypted, and stored in your web browser. They are created when a user’s browser upload a website: the website send information to the browser, which creates a file under text format. Each time the user comes back on the same website, the browser retrieves such a file and send it to the server on which the website is hosted.
We may distinguish between two types of cookies, depending on their purposes: technical cookies and advertising cookies.
- Technical cookies are used all along your website experience in order to improve and execute some functions. For instance, a technical cookie may save answers to a form or the preferences of a user with regard to language or website layouts, if such options are available.
- Advertising cookies may be created by the browsed Website and also by other websites that are publishing adverts, announcements, widgets or other items displayed on the current webpage, for various purposes, such as but not limited to target advertisement (i.e.: advertising depending on the browsing history of the user).
- We use technical cookies techniques that are recorded and stored in your browser for a period of less than six (6) months.
- We do not use advertising cookies. Notwithstanding, in case we would use such tools in the future, we would inform you of such and you would be able to disable such items.
We are using Google Analytics (or any similar software), as audience measurement analytical tool. This cookie allows us to measure the number of visits on our Website, the number of pages hit and the visitors’ activities. Your IP address is also collected in order for us to solely determine the city from which you are connected. The storage duration of such cookie is stated above under article 7.5.
We hereby remind you, to all intents and purposes, that you may object to the storage of cookies by directly configuring your browser, being stated that those operations might affect your browsing experience and compromise the proper operations of the Website.
Art. 10 - Consent
By providing us with your Personal Data, you formally consent to the collection, use, processing and storage of your Personal Data according to the disposals of the present Policy and in compliance with the applicable laws.
Art. 11 - Exercise of Personal Data Rights
In compliance with the GDPR in their last version, you are reminded that you are entitled to request for exercising your legitimate Personal Data subject’s rights, including but not limited, to the right of access, the right of rectification, the right of erasure and to object to its collection, use and storage, the right to restriction of processing, the right to data portability and the right not to be subject to an automated individual decision (including profiling), at any time and by any mean, notably, directly, through an online request or by simply contacting the following address(es):
- Webmail: firstname.lastname@example.org
5 rue Henri Auguste Desbruères
Genopole Campus 1
91030 ÉVRY CEDEX
Art. 12 - Amendment
We reserve the right to modify this Policy, at any time, in part or in full and at our sole option. Those modifications would enter into force upon the publication of the new amended Policy herein. By using this website after the effective date of such amended Policy, you formally acknowledge and consent to its terms and conditions. Otherwise, notably in case you do not agree upon it, you shall not access to this Website..
Art. 13 - Effective Date of this Policy
The present Policy is effective as of January 1st, 2019.
Translation and modification of Jurismatic template provided under Creative Commons licence BY-NC-SA 3.0 FR