Privacy Policy

1. Definitions

Recipient:
Refers to the natural or legal person, public authority, agency, or any other body that receives communication of personal data, whether or not it is a third party.
Personal data:
Refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the “Data Subject”). An “identifiable natural person” is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Data Protection Officer:
Refers to the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing.
Third-party service provider:
Refers to the natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller.
Data processing
Refers to any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means. This includes collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

2. Who are we?

COMECT SAS (hereinafter referred to as the “Company” or “we” or “myDid” in this policy) is a simplified joint-stock company with its registered office at 8 chemin des Floralies 13090 Aix-en-Provence, registered under RCS number 983871807 in Aix-en-Provence.

The Company operates publicly accessible websites at the following URLs: https://coursebadges.com, https://mydid.com, and the mobile application available in app stores.

The publication director is Frédéric Martin.
The Company’s main activity is the creation, development, marketing, and operation of secure applications, software, and platforms for mobile phones, smartphones, tablets, computers, and related devices, particularly in the field of new technologies.

2.2 These applications are intended to:

Provide users with information enabling them to discover the Company’s business and services, as well as its news (events, publications, etc.);
Provide features and/or information enabling users to contact the Company and present the services offered by the Company, its completed and upcoming projects, and the team working on these projects;
Provide users with an online account and access to a platform and various related services as detailed in our terms and conditions.
The Company also manages pages presenting its activities, allowing it to publish content on social media and interact with internet users.

When you explore the Site, interact on pages administered by the Company on social networks, or generally during your exchanges with the Company, the latter may collect and process Personal Data concerning you. This applies to the management of the activities it carries out on its own behalf, acting as Data Controller. Whether you are a customer, prospect, contact, internet user, candidate, supplier, service provider, or partner, potential or current, you are also referred to as “you” or “the data subject(s)” or “the user(s)” in this policy.

In this context, the Company complies with the principles set out in the legal and regulatory provisions on the protection of personal data, in particular within the framework of Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (“GDPR”) and Law 78-17 of January 6, 1978 on information technology, files, and civil liberties (known as the “Data Protection Act”), as well as the provisions of the French Data Protection Authority (CNIL). GDPR“) and Law 78-17 of January 6, 1978 on information technology, files, and freedoms (known as the ”Data Protection Act”) and its implementing decrees.

3. Collection methods

3.1 Your Personal Data is collected directly from you or indirectly from third parties.

3.1.1. By browsing the Site, interacting with it, or providing information in data collection forms, you consent to the collection of your Personal Data. This also includes your exchanges with the Company and the sharing of Site content via social media sharing buttons. In summary, your Personal Data is collected directly from you in these circumstances.

3.1.2. However, your Personal Data may also be collected through third parties. We may enrich or collect information about you from third-party sources, such as social media, public data, websites, or other staff members or contacts within your company.

In the context of our recruitment activities, we use the information you provide us, as indicated in your resume, and may also use third parties such as recruitment agencies, previous employers, or various sources of information to evaluate your application or professional profile.

In order to comply with certain legal or regulatory obligations, the collection of your Personal Data is mandatory for the use of certain features.
If processing is subject to your consent, the provision of data is optional, but failure to provide it could hinder the processing.
If data processing is necessary for the performance of a contract, the communication of data is necessary for that purpose.
If the data processing is based on our legitimate interests, the disclosure of data is necessary, and failure to disclose it could hinder the processing.

In the case of form fields with mandatory data, asterisks indicate the required fields, and the consequences of failure to provide the information are specified. Data not marked as mandatory is optional.

3.2 Except for specific legal obligations, we do not collect so-called “special” Personal Data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or genetic, biometric, health, sexual life, or sexual orientation data.

3.3 Data of minors or protected adults: Our services are reserved for adults with legal capacity. The use of the Site by minors or incapacitated persons is not authorized, and the Company cannot be held liable for the consequences of processing their Personal Data. However, exceptions may be made for the processing of Personal Data of minors aged at least fifteen years old in the context of applications for job offers or internships.

4. Data collected, purposes, processing

As the data controller, we may process your personal data for the following purpose:

4.1.1 Management, processing, and follow-up of requests for information and exchanges with users, or its contacts in the broad sense:

Purpose of processing: We process your personal data for the purpose of processing, managing, and following up on any contact or information requests you may submit. This includes interactions via the Website and exchanges on our social media pages (including the management, processing, follow-up, and possible moderation of your messages or comments). In general, these activities are intended to ensure the processing, management, and follow-up of requests, as well as the responses to be provided. This data is also used for the purpose of managing relationships with our contacts as a whole.
Data processed: The data processed includes identity (title, last name, first name), username or pseudonym/alias, contact details if necessary (including postal address, telephone number, email address), position and company affiliation if applicable, as well as contact requests, requests for information or documentation, and correspondence exchanged.
Legal basis for processing: The processing of your personal data in this context is deemed necessary for the pursuit of the Company’s legitimate interests, in particular to respond to your requests, to enable you to benefit from the features offered on the Website, and more generally, to manage and monitor its relationships with its contacts.
Data retention period: Data is retained for the period necessary to respond to your request or to manage your relationship with the Company. In the event of termination of the relationship, the data may be retained for a period of three years from the end of your relationship with the Company or from your last contact with us. This retention is intended in particular for the management of relationships with our contacts in a broader context, including for prospecting purposes.

4.1.2 How we manage our relationships with our customer users:

Purpose of Processing: We collect personal data from our customers and/or our contacts at our customers for the purpose of managing our pre-contractual, contractual, and post-contractual relationships. This includes providing, managing, and monitoring online accounts, managing the services provided, executing contracts, payments and transactions, associated billing/accounting, and overall customer relationship management. We also use this data to manage and monitor customer accounts, process complaints, manage disputes and unpaid bills, and to carry out studies, analyses, reports, and statistics, particularly for commercial purposes.
Data processed:

Identity (title, last name, first name, username, date of birth)
Contact details (email address, postal address, phone number, etc.)

Legal basis for processing: The processing of customers’ personal data is primarily necessary for the performance of pre-contractual measures taken at the customer’s request or for the performance of a contract concluded with the customer. The sub-purposes related to the management and monitoring of customer relations as a whole are necessary for the pursuit of the Company’s legitimate interests in ensuring effective management. With regard to the personal data of our customers’ contacts, the processing is based on our legitimate interests in managing and monitoring our customer relations, in particular for the organization and execution of the tasks or services entrusted to us.
Data retention period: Data is retained for the duration of our relationship with customers and then, where applicable, for a period of three years from the end of the relationship with the Company or from the last contact with us. This retention is intended to manage our customer relationships in a comprehensive manner, including for prospecting purposes. In a specific case, if the user has not logged into their online account for three years and provided that no assets are held in that account, the Company will close and delete the account and associated data, while reserving the right to retain some of this data for other purposes in accordance with the terms and conditions specified in this paragraph.
Other Data Controllers: Users are informed that, when using the services accessible via the Site, their personal data may be processed by third parties involved in these services. These third parties are entities independent of the Company, solely responsible for the processing of their own personal data. The Company has no power of determination or control over such processing. Consequently, users are invited to consult the personal data protection policies of these entities and any documentation made available by them concerning the processing of personal data that they carry out.

4.1.3 Management of our relationships with our partners, service providers, and suppliers:

Purpose of Processing: We collect personal data concerning our current and/or potential partners, as well as their staff members, and more generally our contacts at our partners. This collection is intended to seek out new partners, manage, follow up on, and respond to partner requests, quotes, or service proposals, as well as manage our relationships with them. This includes managing and monitoring the execution of contracts, orders/services entrusted, deliveries, invoices, payments and transactions, associated accounting, in particular the management and monitoring of partner accounts, the overall partner relationship, and any complaints or pre-litigation/litigation.
Data processed: The data processed includes identity (title, surname, first name), contact details (email address, postal address, telephone number, etc.), the affiliated company and position, information on partnership requests, quotes and service proposals, details of orders/services/contracts, payment data and means of payment, etc. etc.), company affiliation and position, information on partnership requests, quotes and service proposals, details of orders/services/contracts, data relating to payments and means of payment, data relating to transactions, data relating to contract and relationship monitoring, and data relating to invoices.
Legal basis for processing: For the personal data of individual partners, processing is generally necessary for the performance of pre-contractual measures taken at their request or of a contract concluded with the Company. With regard to the personal data of contacts at partners, processing is based on the Company’s legitimate interests in managing and monitoring its relationships with its partners, in particular for the organization and proper performance of the tasks or services entrusted to them. The sub-purposes related to the search for new partners and the management and monitoring of relations with partners as a whole are also necessary to pursue the legitimate interests of the Company. For the personal data of other data subjects (staff members/contacts at our partners), processing is based on the Company’s legitimate interests in managing and monitoring its relationships with its partners, with a view to organizing and properly performing the tasks or services entrusted to them. Finally, the management of invoices and the associated bookkeeping may result from the Company’s legal obligations.
Data retention period: Data is retained for the duration of the pre-contractual, contractual, or commercial relationship with the Company.

4.1.4 Events

Purpose of Processing: We may process personal data concerning you in connection with the organization and monitoring of the events we offer, including planning presentations, managing, processing, and monitoring registrations, responding to inquiries, etc.
Data processed: The data processed includes identity, contact details, position and company affiliation, as well as information on registrations and participation in events.
Legal basis for processing: In general, the processing of your personal data in this situation is necessary for the organization and management of events, and is therefore based on the performance of a contract to which you are a party.
Data retention period: Data is retained for the period necessary to organize and monitor the event. Thereafter, where applicable, it may be retained for a period of three years from the end of your relationship with the Company or your last contact with us. This retention is intended to manage our relationships with our contacts in general, particularly for prospecting purposes.

4.1.5 Mailing and telephone solicitation:

Purpose of Processing: We may process the personal data of our customers, prospects, and, more generally, our contacts for the purpose of carrying out our commercial, communication, solicitation, prospecting, loyalty, or marketing operations. This includes technical operations such as segmentation and targeting by mail or telephone, in particular to send them information by means such as email or SMS. This information may relate to product and service offers that may be of interest to them, news and/or activities on our part, other prospecting information or documents, as well as studies, surveys, promotions, or satisfaction surveys.
Data processed: The data processed includes identity and contact details.
Legal basis for processing: This processing is based on the pursuit of our legitimate interests in promoting our products and services on the market and carrying out communication activities. It is important to note that the recipient of such marketing communications has the right to object to them at any time, without having to provide a reason or explanation.
Data retention period: Personal data is retained for a period of three years from the date of collection or the end of our relationship, or from the last contact made by the data subject to us. For example, for a customer, the period begins from a transaction or the use/performance of a service, the end of a service contract, the general terms and conditions that bind us, or the last contact made by the customer. For a prospect, the period begins from the last contact made by the prospect, whether it be an online request, an email or postal letter, a phone call, or even a click in an email sent to them by the Company, etc.

4.1.6 Prospecting and solicitation by email:

Purpose of Processing: We may process the personal data of our customers, prospects, and, more generally, our contacts for the purpose of carrying out our commercial, communication, solicitation, prospecting, loyalty, or marketing operations by email. This includes technical operations such as segmentation and targeting. We use this method to send information such as product and service offers that may be of interest to the individual, information about our news and/or activities (e.g., newsletters), other prospecting documents, as well as studies, surveys, promotions, or satisfaction surveys. We may also analyze the performance of our prospecting campaigns using tracking information relating to actions taken in the emails we send.
Data processed: The data processed includes identity, email address, and data relating to actions performed in emails (opens, clicks, etc.).
Legal basis for processing: When such operations do not require the prior consent of the persons concerned (i.e., in cases where they are intended for professionals at a professional email address related to their profession, or for customers regarding products or services similar to those already provided by us), the Processing is carried out on the basis of our legitimate interests in promoting our products and services on the market. It should be noted that the recipient has the right to object to this at any time. In other cases, Processing is based on the consent of the person concerned. The person has the option of refusing to give their consent or withdrawing it at any time, without having to provide a reason or explanation.
Data retention period: Personal data is retained for a period of three years from the date of collection or the end of our relationship, or from the last contact made by the data subject to us. For example, for a customer, the period begins from a transaction or the use/performance of a service, the end of a service contract, the general terms and conditions that bind us, or the last contact made by the customer. For a prospect, the period begins from the last contact made by the prospect (online request, email or postal mail, phone call, or click in an email sent by the Company, etc.).

4.1.7 Use of cookies or similar technologies:

Purpose of Processing: When you use the Site and, more generally, our digital media (excluding social networks or social network-related features), we process your personal data for the purpose of tracking your browsing activity. This includes conducting and compiling studies, analyses, reports, and statistics, as well as managing and monitoring the proper functioning of our Site, including its security, and improving the user experience. We also collect personal data to provide certain services or features on the Site, as well as to track and measure the Site’s audience and performance. Personal data may also be collected and processed to display advertisements to you on the Site or on third-party sites, which may be targeted (or behavioral or programmatic advertising), based on your profile, browsing history, location, and interactions with the websites you visit. The use of cookies or other similar technologies is subject to your consent and is therefore optional.
Data processed: The data processed includes session, connection, and Internet browsing data, including information about your browser or device and its configuration. This also includes history and traffic and browsing information on the Site, information relating to the traceability of actions and interactions with the Site, identifiers linked to your device, hardware, or operating system, scoring information, information about your browsing and usage preferences on the Site and even third-party websites, location data, information relating to the network and your language, as well as non-personal data.
Legal basis for processing: When the sole purpose of processing your data is to enable or facilitate electronic communication, or when it is strictly necessary for the provision of an online communication service at your express request (for example, to enable you to browse our Site and benefit from the features offered), it is based on our legitimate interest in facilitating your browsing of our Site. In other cases, Processing is subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes. You have the option of not consenting or, if you do consent, of withdrawing your consent at any time, without having to provide any reason or explanation. For more information about the cookies, trackers, and other similar technologies used by us and our partners on our Site, as well as how to configure them, please refer to our cookie management policy.
Maximum lifespan of cookies and retention of personal data collected by this means: six months from the date the cookies are placed on your browser or device.

4.1.8 Use of cookies or similar technologies with social networks and marketing tools:

Purpose of Processing: In order to offer interactive features between our Site and social networks, as well as to monitor, understand, and study the use of our pages on social networks and the interactions between our Site and social networks, we provide links to our pages on social networks on our Site, configure these pages as administrators, or suggest that you use tools created or offered by these social networks. In this context, we process your Personal Data, in particular to provide you with the aforementioned interactive features. We also use this data to improve your user experience, measure the audience and performance of our social media pages and interactions between our Site and said networks, and to compile statistics, particularly browsing statistics. Personal Data concerning you may also be collected and processed in order to display advertisements on social networks, which may be targeted, based on your profile, your browsing, your location, and your interactions with our pages on social networks, but also with our Site, or with other websites you visit. This Personal Data is collected using cookies or other technologies. Personal Data concerning you may also be collected and processed in order to display advertisements on social media, which may be targeted, based on your profile, your browsing history, your location, and your interactions with our social media pages, as well as with our Website or other websites you visit. This personal data is collected using cookies or other similar technologies, and their use is subject to your consent and is therefore optional.
Processed data: The processed data includes session, connection, and Internet browsing data, including information about your browser or device and its configuration, traffic and browsing history on our social media pages, information relating to the traceability of actions on and interactions with our social media pages or between our Site and social media, information such as “identifiers” related to your device, hardware, social networks, or operating system, location data, network information, your language, and non-personally identifiable information.
Legal basis for processing: This processing is subject to your prior consent to the use of cookies and other similar technologies for the purposes mentioned above. You therefore have the option of not consenting to this, or, if you do consent, of withdrawing your consent at any time, without having to provide any reason or explanation. For more information about the cookies, trackers, and other similar technologies we use, please refer to our cookie management policy.
Joint Controllers: When the settings we configure for a social media tool affect the nature of the Personal Data processed or the characteristics of this Processing, and more specifically when it can be considered that the Company jointly contributes to determining the purposes and/or means of processing Personal Data, we may be jointly responsible for the Processing with the social media network concerned. In this case, the social network, which primarily determines the purpose and means of processing, as well as the nature and methods of depositing cookies, has primary responsibility for the Processing. We recommend that you consult the privacy policies and cookie policies of these third parties for detailed information on their practices for collecting and processing your personal data. The social networks concerned are Instagram, Telegram, Pinterest, YouTube, Twitter, LinkedIn, and Discord. For more information on how these social networks process your personal data, please consult their respective privacy policies and cookie policies.
Maximum lifespan of cookies and storage of Personal Data collected by this means: six months from the date the cookies are placed on your browser or device.

4.1.9 Applications and the recruitment process:

Purpose of Processing: The Company may process your Personal Data in connection with the management and follow-up of applications in response to job or internship offers, or those sent to us unsolicited. This includes operations related to the recruitment process, such as monitoring and actively searching for professional profiles that match the positions available within the Company, receiving and reviewing applications, evaluating and selecting applications and professional profiles, creating a database of candidates, using recruitment support methods and techniques, inviting candidates and conducting recruitment interviews, as well as making the resulting decisions.
Data processed: The data processed includes your identity, contact details, information about your professional life, details about your education, experience, and career history, your skills/professional references, information related to your current job, economic and financial information, and all the information contained in your resume.
Legal basis for processing: Such processing is necessary for the pursuit of our legitimate interests in seeking and recruiting new employees.
Data retention period: Your personal data is retained for the period necessary to process your application. Unless you object, it may be retained for up to two years from the date of receipt of your application. This period allows us to contact you during this time if a position related to your profile becomes available.

4.2.1 Management of requests to exercise the rights of data subjects with regard to the protection of personal data:

Purpose of Processing: As part of our legal and regulatory obligations relating to the protection of Personal Data, particularly in response to requests to exercise the rights of data subjects, we may process Personal Data concerning you in connection with this purpose.
Data processed: The data processed includes identity, contact details, the subject matter and content of the request, exchanges and response, as well as additional information or a copy of an identity document, but only when justified by the situation.
Legal basis for processing: This processing is necessary to comply with our legal and regulatory obligations mentioned above.
Data retention period: Data is retained for the period necessary to process the request. Subsequently, the data necessary for the exercise of these rights may be retained for a period of three years from the date of the request made by the data subject to the Company. It should be noted that, in the event of a request to opt out of marketing, your data will be retained for this purpose in an opt-out list for three years. When a copy of an identity document is collected as part of a request to exercise your rights, it is immediately deleted if it has been provided by you when the request does not require the transmission of such an identity document. It is deleted as soon as the identity of the person making the request has been verified when the situation requires such verification.

4.2.2 Pre-litigation and litigation

Purpose of Processing: The purpose of processing your personal data is to manage and monitor pre-litigation and litigation matters, in particular commercial disputes with customers, partners, service providers, suppliers, and other contacts. This includes the preparation, exercise, and monitoring of litigation, as well as the enforcement of judgments and the management of actions aimed at establishing, exercising, or defending a legal right.
Data processed: The data processed includes identity, civil status, economic and financial information, data relating to defendants, victims, witnesses, and court officers involved in the dispute, history of exchanges with the Company, information on financial situation, specific data, and any other information necessary for the purpose of the dispute. This may also include data relating to offenses, convictions, or security measures, if strictly necessary for the purposes of establishing, exercising, or defending a legal right.
Legal basis for processing: This processing is based on the legitimate interests of the Company in preserving and enforcing its legal rights, particularly in the context of its relationships with customers, partners, contacts, candidates, etc. Personal data may be processed if strictly necessary for these purposes. Similarly, data relating to offenses, convictions, or security measures may be processed in order to prepare, exercise, or follow up on legal action and enforce the decision rendered.
Data retention period: Data is retained beyond the legal time limits, in the form of archives, for the duration of the limitation periods, in particular for evidentiary purposes. In the event of pre-litigation, the data is retained until the dispute is settled amicably or, failing that, deleted as soon as the limitation period for legal action expires. In the event of litigation, the data is retained for the duration of the proceedings and until the expiry of the remedies against the decision rendered. The decisions rendered may be retained until the decision has been fully enforced, or even as definitive archives.

4.2.3 Personal data that may be retained beyond the periods mentioned:

either after obtaining your consent;
either in the form of archives, to comply with any legal and regulatory obligations imposed on the Company (e.g., ten years for the retention of accounting documents, electronic contracts, five years for anti-money laundering and counter-terrorist financing obligations, etc.), or during the legal limitation periods, in particular for evidentiary purposes (e.g., five years for the limitation period under ordinary civil law, six years for the limitation period under ordinary criminal law, two to five years under labor law).

5. Recipients and sharing of Personal Data

5.1 We ensure that only authorized persons within the Company can access your Personal Data when such access is necessary for the performance of their duties and/or tasks. This includes Company personnel, including employees, interns, temporary workers, etc., with responsibilities in the areas of marketing, communications, sales, recruitment, human resources, customer and prospect relations, administration, finance, legal, development, IT, projects, etc.

5.2 External Recipients may also receive communication of your Personal Data, in particular:

the staff of the departments responsible for auditing our Company (auditors, departments responsible for internal or external control procedures, bodies authorized to carry out audits, etc.);
our advisors (legal, financial, etc.);
the staff of our partners, including our service providers and suppliers, who are subject to contracts specifying their obligations
the staff of our contractual or commercial partners, as well as third-party companies, such as social media publishers, third-party website publishers, or publishers of cookies used on our Site, for example in the context of prospecting, communication, etc., or in the management of our digital marketing and the proper functioning of our Site. It is important to note that if you publish content disclosing your Personal Data on the internet, in particular on our Site or on the Company’s social media pages, this content may be accessible to any internet user.
whose access to Personal Data is strictly necessary and/or justified in the context of their activities or missions. This category of recipients may include publishers of applications, computer programs, or tools, as well as providers of payment or verification services used in connection with our activities or to provide you with the services accessible through the Site, as well as any IT or maintenance providers for the applications, computer programs, and/or tools that we use and in which your Personal Data may be processed;;
the Company’s customers for certain Personal Data;
staff of social security and tax authorities authorized to receive Personal Data in certain circumstances;
staff of agencies, court officers, and bailiffs acting in particular in the context of their debt collection duties;
where applicable, the staff of the organization responsible for managing the do-not-call list;
court officers, bailiffs and, where applicable, the staff of the courts or authorities competent to allow the sale or transfer of all or part of our activities or assets, or in the context of the management and monitoring of pre-litigation and/or litigation;
our insurers and/or insurance brokers, including their staff.

5.3 Certain partners or third parties, including their staff, are also recipients of your Personal Data when you use the services accessible through the Site.

It is important to note that the Company is not responsible for the Processing of Personal Data carried out by these partners and third parties. These entities carry out their own respective Processing of Personal Data, for which they are solely responsible. The Company has no power of determination or control over such Processing. For information purposes, users are invited to consult the personal data protection policies of these entities and any other documentation made available by these entities concerning the processing of personal data that they carry out.

5.4 Furthermore, in response to legitimate requests from public or authorized authorities, we may be required to disclose your Personal Data. These requests may arise from the obligation to comply with personal data law, concerns related to national security, the fight against fraud, money laundering, terrorist financing, or more generally, the application of legal or regulatory provisions. Your Personal Data may therefore be disclosed to any competent authority, in particular in the event of a request from judicial, police, or administrative authorities. In such situations, we carefully examine the applicable provisions, the nature of the request, and the legitimacy and proportionality of the information requested. In addition, we reserve the right to report to public authorities any activities that we believe in good faith to be illegal and any suspected abuse.

5.5 It is important to note that the Recipients mentioned above are not necessarily the beneficiaries of all your Personal Data. They only receive the information strictly necessary for the purpose for which the communication takes place.

6. Your rights

6.1 In accordance with the terms and conditions defined by the legal and regulatory provisions relating to the protection of personal data, you have the following rights regarding your data:

Right of access: You have the right to obtain confirmation of whether the Company is processing Personal Data concerning you. Where such processing is carried out, you have the right to access this data, as well as certain information relating to the processing and associated characteristics.
Right to rectification: You have the right to request the correction of your Personal Data that you believe to be incomplete or inaccurate.
Right to erasure: In certain circumstances, you may request the deletion of your Personal Data, unless its processing is necessary for the performance of contractual relationships with the Company, for compliance with legal or regulatory obligations, or for the establishment, exercise, or defense of legal claims.
Right to restriction of processing: You have the right to request the restriction of the processing of your Personal Data in certain circumstances, allowing your data to be flagged so that its future processing is restricted.
Right to Data Portability: Under certain conditions, you have the right to request to receive your Personal Data provided to the Company or, where technically feasible, to transfer it to a third party in a machine-readable format. This right applies only to processing based on your consent or on the performance of contractual relationships, provided that the processing is carried out using automated processes.
Right to withdraw your consent: If the processing is based on your consent, you have the right to withdraw that consent without affecting the lawfulness of the processing carried out prior to the withdrawal.
Right to define guidelines after your death: You have the right to establish guidelines regarding the storage, deletion, or communication of your Personal Data after your death. In the event of death, your Personal Data will normally be deleted, unless it needs to be retained for legal and regulatory reasons, or in accordance with the mandatory legal limitation and retention periods mentioned in paragraph 4 of the processing characteristics. This data may also be disclosed to a third party that you may have designated.

6.2 You may exercise your rights relating to the processing of your personal data by the Company either by email at the following address: [email protected], or by post at the following address: 8 chemin des Floralies 13090 Aix-en-Provence, France.

In case of reasonable doubt as to the identity of the person requesting to exercise their rights, the Company reserves the right to request additional information to confirm the identity of the Data Subject. In this case, the response times will be suspended until the necessary information is received.

The Company undertakes to respond to any request as soon as possible and, in any event, within a maximum period of one month from receipt of the request. If necessary, this period may be extended by two months due to the complexity and number of requests, and the applicant will be informed if this is the case.

The request may be made by the Data Subject or by a person specifically authorized for this purpose, provided that this authorized person can prove their identity and the identity of the principal, their mandate, its duration, and its specific purpose. The mandate must also specify whether the authorized representative may receive the response.

6.3 Furthermore, please note that in certain situations, we may be considered jointly responsible for the Processing of your Personal Data with the social networks on which we have dedicated pages or with which we offer interactions.

6.4 You also have the right to lodge a complaint with the competent supervisory authority (in France, the Commission Nationale de l’Informatique et des Libertés, known as “CNIL”: 3 place de Fontenoy – TSA 80715, 75334 Paris cedex 07; tel.: 01 53 73 22 22) if you believe that the Processing of your Personal Data does not comply with the legal and regulatory provisions on the protection of Personal Data. To better understand your rights, you can consult the explanations provided by the CNIL here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles.

6.5 Pursuant to Articles L.223-1 et seq. of the French Consumer Code, if you are a consumer, you have the right to object at any time to being contacted by telephone by registering free of charge on the website: https://www.bloctel.gouv.fr.

7. Security of Personal Data

7.1 The Company implements appropriate organizational and technical security measures, taking into account, in particular, the categories of Personal Data processed, technological advances, implementation costs, and the nature, scope, context, and purposes of the Processing. These measures are also adjusted according to the risks, including the degree of probability and severity, in order to protect your Personal Data against any malicious intrusion, loss, alteration, or unauthorized disclosure to third parties. The overall objective is to preserve security and confidentiality and to guarantee a level of security appropriate to the risk, while preserving the rights and freedoms of individuals.

However, due to the challenges inherent in online activity and the risks associated with electronic data transmission, the Company cannot guarantee absolute results. In the event of difficulties, the Company undertakes to make every effort to contain the risks and to take all appropriate measures in accordance with its legal and regulatory obligations, such as corrective actions, informing the CNIL (French Data Protection Authority) and, where applicable, the persons concerned.

7.2 When designing, creating, selecting, and using our services offered on the Site, which are based on the Processing of Personal Data, the Company incorporates the principle of the right to the protection of Personal Data by default and from the outset, in accordance with the principles of Privacy by Design and by Default.

7.3 Access to your Personal Data is restricted to our employees, partners, and the Recipients mentioned above, who are authorized and need this data in order to perform their duties and/or activities.

7.4 In the event that part or all of the Processing of Personal Data is subcontracted, the Company shall contractually impose security guarantees on its Subcontractors, in particular confidentiality guarantees, concerning the Personal Data to which they may have access. These guarantees shall include the implementation of appropriate technical and organizational measures to protect such data.

8. Is personal data transferred outside the European Union?

8.1 Your Personal Data receives special treatment within the European Union.

8.2 Within the scope of the aforementioned purposes, some of your Personal Data may nevertheless be transferred to third parties located outside the European Union (e.g., subcontractors of the Company involved in the aforementioned Processing, etc.).

Some of these entities receiving your Personal Data are considered to offer an adequate level of protection for such data, as they are established in a country whose regulations on the protection of Personal Data have been recognized as satisfactory by adequacy decisions of the European Commission (available here:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).

However, if the country of the entity receiving your Personal Data does not guarantee an adequate level of protection, we will ensure that appropriate security and confidentiality measures are in place to ensure that your Data remains protected.

In such cases, you are informed that transfers of your Personal Data to other entities outside the European Union are governed by the conclusion, with the recipients of such Data, of contractual clauses in accordance with the recommendations of the European Commission. These clauses ensure that appropriate safeguards are in place to protect your Data.

We would like to point out that transfers of Personal Data outside the European Union are legitimate if the transfer is necessary for the performance of a contract between the Data Subject and the Data Controller, to the implementation of pre-contractual measures taken at the request of the Data Subject, to the conclusion or performance of a contract concluded in the interest of the Data Subject between the Data Controller and another natural or legal person, or if the Data Subject has given their explicit consent to the proposed transfer, after having been informed of the risks that such transfer may entail due to the absence of an adequacy decision and appropriate safeguards.

A copy of the reference documents mentioned in this paragraph can be obtained (with the exception of any commercial information considered sensitive or confidential or covered by business secrecy) by contacting us.

9. Links to third parties

9.1 We would like to inform you that our digital media, such as our website and social media pages, may contain links to third-party websites, including social media platforms. We have no control over the activity of these websites or the policies they apply with regard to the protection of your Personal Data and your rights. We strongly recommend that you review the safeguards provided by these sites before interacting with them. Please note that the personal data protection policies of these sites may differ from those of our company, and it is your responsibility to familiarize yourself with them.

9.2 If you publish content disclosing your Personal Data on the Internet, particularly on social networks, including on our company’s social network pages, this content may be accessible to any Internet user and collected or used by third parties for purposes beyond our control. In any event, our company cannot be held liable if the processing of Personal Data carried out via one of these third-party sites contravenes the applicable legal and regulatory provisions.

10. Changes to the Privacy Policy

10.1 This Data Protection Policy may be subject to change at any time, taking effect on the date of publication of the corresponding update. We therefore encourage you to consult it regularly.