DATA PROTECTION POLICY
The Groupe Atelier du Sourcil (hereinafter "ADS Formation et products"), including the company ADS Formation et products, as well as all of its subsidiaries as defined by the provisions of Article L 233-1 of the French Commercial Code, existing and future, is the publisher of content, products and services available on various magazines and digital media, including applications, newsletters, websites, social platforms, and any other existing media (hereinafter "the Services").
ADS Formation et produits places great emphasis on the protection of the Personal Data of its customers, users of its websites and mobile applications, partners and employees.
This policy (hereinafter referred to as "the Policy") outlines the commitments of ADS Formation et produits regarding the protection of the Personal Data of Internet users visiting this site or this application (hereinafter referred to as "the Website") and of users of the Services. It also informs you of the procedures for collecting and using your Personal Data and the options you have in this regard.
It may be modified at any time by ADS Formation et produits, according to the modifications made, in order to comply with any regulatory, jurisprudential, editorial and/or technical developments.
You are advised to refer to the latest version of the Policy available on our Services before browsing.
ADS Formation et produits complies with the General Data Protection Regulation, no. 2016/679 of 27 April 2016, the "Informatique & Libertés" law no. 78-17 dated 6 January 1978, as amended, as well as the law "pour la confiance dans l'économie numérique" no. 2004-575 dated 21 June 2004 (article L. 34-5 of the French Post and Electronic Communications Code).
ADS Formation et produits has appointed a data protection officer in charge of the right to information, access, rectification, opposition, deletion, limitation and portability that you have in accordance with the aforementioned law (e-mail: contact[@]atelierdusourcil.com).
The Policy applies in addition to the provisions of the General Terms and Conditions of Use of Services and the General Terms and Conditions of Sale of Services, where they exist.
ARTICLE 1: WHO IS THE DATA CONTROLLER?
Data controller is the company ADS Formation et Produits, SAS with a capital of €4,000, registered in the PARIS Trade and Business Register under the number 753 285 808, whose headquarters are located at 87, Rue Réaumur, F-75002 PARIS.
ARTICLE 2 - WHY IS YOUR PERSONAL DATA COLLECTED BY ADS FORMATION ET PRODUITS?
ADS Formation et Produits may collect and process declarative data, behavioural data of its customers, prospects and users of the website and interaction data with them (hereinafter taken as a whole "Personal Data").
This Personal Data in the context of the use of the Site and the Services is processed for the following purposes:
When you create a user account on the Site or one Sites of ADS Formation et produits in order to access the various Services;
When you subscribe to our newsletters or marketing communications or those of our partners;
When you participate in the games and competitions we run;
When you respond to surveys we organize or agree to test products we send you;
When we have to deal with unpaid bills and disputes with customers;
Where we collect Personal Data necessary to improve user experience;
When we collect data to send you targeted advertising;
When we carry out statistical studies and audience measurement of our websites.
ADS Formation et produits only collects data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed.
These purposes are specific and legitimate. Under no circumstances will your data be further processed in a way that is incompatible with these purposes, except with your prior consent.
ARTICLE 3 - WHAT PERSONAL DATA IS COLLECTED BY ADS FORMATION ET PRODUITS?
3.1. Declarative data: ADS Formation et produits may create one or more files containing information that you voluntarily provide to benefit from a Service. This Personal Data is collected when you register for the Services or when you place an order, or during any other marketing activity (e.g. game, study, survey, etc.) and regardless of the Service used.
This data is:
- Data needed to contact you:
- Your identity (title, name, first names, date of birth, username);
- Your contact details (postal and/or e-mail address, telephone number);
- Those necessary for the execution of the services we provide:
- Browsing and connection data: IP address, connection data and browsing data;
- Transaction data such as transaction number, details of the purchase, subscription, good or service purchased;
- Data related to the organisation and processing of competitions, lotteries and any other promotional operation, such as the date of participation, the answers given to the competitions and the nature of the prizes offered;
- Data relating to the input of individuals who submit reviews of products, services or content, including their username;
- Those useful for getting to know you better:
- Your data relating to the household members: marital life, number of people in the household, number and age of children in the household, profession, field of activity, socio-professional category, existence of pets,
- Your data relating to the monitoring of the commercial relationship: requests for documentation, requests for tests, products purchased, services or subscriptions subscribed to, quantity, amount, frequency, delivery address, history of purchases and services, product returns, origin of the sale (vendor, representative, partner, affiliate) or order, correspondence with the customer and after-sales service, exchanges and comments from customers and prospects, person(s) in charge of customer relations;
When your data is used for direct marketing by e-mail or SMS, your prior consent is required.
You may be asked to accept commercial offers:
- From the ADS Formation et produits group
- From its partners.
As an exception, and in accordance with the applicable regulations, in the case where these details have been collected in the context of the sale of a product or a service and they are used to send prospecting intended to promote similar products or services provided by ADS Formation et produits. Your details may be used without your consent. Likewise, your consent will not be required for telephone or postal marketing. In these two cases, ADS Formation et produits processes your data for the purposes of interests considered legitimate by the law, without this having any consequences for your rights.
When collecting Personal Data, the account creation, online order or information forms specify the data that must be communicated in order to benefit from the Service concerned, the optional data and the consequences of not communicating a specific data.
3.2. Behavioural data : ADS Formation et produits is also likely to collect your browsing data using data collection tools: cookies, tags, beacons, and any other appropriate technical means installed on the Services (hereinafter taken as a whole referred to as the "Tools").
The Tools are needed to enable you to benefit from some of the features of our Services. If you have chosen to disable the Tools via your web browser, access to the Services may be impaired or impossible. We therefore recommend you leave them activated to take full advantage of our services and your browsing on our sites.
The Tools allow, during each of your visits, and according to the purposes defined in article 2:
- To carry out statistical studies,
- To identify you,
- To adapt the content of a service or advertising to your behavioural data and,
- To adapt the content of a service or an advertising offer to your behavioural data and, more generally, to study your behaviour during browsing on the Site in order to offer you a better surfing experience and use of our Services.
3.3. Interaction data: in addition, ADS Formation et produits may process interaction data between you and our company - opening or links to newsletters we send, clicking on links in newsletters we send. This information allows us to tailor our interaction with you.
ARTICLE 4 - WHO ARE THE RECIPIENTS OF PERSONAL DATA?
The Personal Data is intended for use by ADS Formation et produits and its subsidiaries.
As an exception, they may be communicated to third parties in the following cases:
If you have ticked the "Yes" box for the "Partners" option, you may also receive correspondence and commercial offers relating to products and/or services provided by our partners, specifically advertisers, advertising agencies and advertising sales firms. Our partners will then have access to your declarative data.
When it transmits your Personal Data to third parties, ADS Formation et produits contractually frames this transfer so that the partner complies with the regulations concerning personal data. However, ADS Formation et produits is not responsible for the processing by its partners of your declarative data once it has been transmitted to them. If you no longer wish to receive commercial offers from our current partners, we suggest you refer to their terms and conditions for more information. If you do not wish to receive commercial offers from our future partners, you may at any time click on the administration interface provided for this purpose on our Services. You may also exercise your rights of access, rectification, opposition, deletion, data portability and limitation of processing with our various partners according to the terms and conditions they have defined.
(2) Your declarative data may also be passed on to the service providers appointed by ADS Formation et produits to ensure the effectiveness of the Services you have ordered, for example to guarantee deliveries. These service providers may be located outside the European Union. In this case, these service providers are signatories to the standard contractual clauses validated by the European Commission.
(3) In accordance with the regulations in force, declarative data may be transmitted to the competent authorities upon request.
ARTICLE 5 - HOW LONG IS PERSONAL DATA RETAINED?
Depending on the purpose of the processing, the period of retention of Personal Data may vary.
Except for imperative legal provisions, ADS Formation et produits keeps the Personal Data for the time necessary to achieve the intended purpose.
Personal Data will be retained for the period during which you use our services, and deleted no later than three years from the date of our last contact, unless anonymisation or a legal obligation to retain certain data for a longer period is imposed.
Connection data to the Site will only be kept for a period of thirteen months.
ARTICLE 6 - WHAT IS ADS FORMATION ET PRODUITS' POLICY ON COOKIES AND SIMILAR IDENTIFICATION TECHNOLOGIES?
A cookie is a small data file copied to your computer's hard drive by a website. It records information relating to the browsing of your computer on a site (such as the pages visited or the dates and times of consultation), which can then be read during your subsequent visits to the Site. ADS Formation et produits may send cookies when you visit the Site or when you register to access an online Service.
The cookies used on the Site come in several types and serve different purposes:
– Browsing cookies, which make it easier to browse the Site or which are necessary for the provision of the Services you order: "shopping basket" cookies, session cookies, or even flash cookies allowing a media player to operate when necessary for the functioning of the Services you order, for example;
– Audience measurement cookies, which enable us to collect anonymous visitor statistics. ADS Formation et produits uses these cookies to detect browsing problems that may occur on the Site, to improve its performance and functionality, and to improve the Services;
– Behavioural analysis cookies, which allow the collection of behavioural data. This data allows us, for example, to know whether you have visited the Site before, helps us to identify what information on the Site might be of most interest to you, and helps to improve your browsing experience and make it more interesting. This is why we keep track of your preferences when you visit a particular site. They may also allow ADS Formation et produits and its partners to display advertising relevant to your interests.
Cookies allow us to tailor your media content and advertising, provide social media features and analyse our traffic. We also share information about the use of our site, such as browsing and/or geolocation data, with our social media, advertising and analytics partners who may combine this with other information you have provided to them or that they have collected through your use of their services.
You can selectively refuse or accept the installation of behavioural analysis cookies, geolocation cookies and/or audience measurement cookies and/or the installation of cookies by the partners of ADS Formation et produits by configurating your Internet browser used from your Terminal. Access to some of the offers and topics offered by the Services may then be altered or even impossible. You are invited to consult the CNIL website at the following address: http://www.cnil.fr or consult the Help and Documentation of your Internet browser.
In Internet Explorer :
Click on Tools at the top of the browser window and select Internet Options.
In the options window, click on the Privacy tab.
To enable cookies, set the slider to Medium or lower.
To disable cookies, move the slider to the top to block all cookies.
Click on Tools in the browser menu and select Options.
Select the Privacy tab.
To enable cookies, check the Accept cookies box.
To deactivate cookies, uncheck the Accept cookies box.
Click on the wrench icon in the browser toolbar.
Select the Settings option.
Click View advanced settings
In the Privacy section, click on the Content Settings button.
To enable cookies, select Enable local data storage in the Cookies section. Both proprietary and third-party cookies are then enabled. Both proprietary and third-party cookies are then enabled.
To disable cookies, select Restrict all sites from storing data in the Cookies section.
If needed, open Safari.
Choose Safari > Settings, then click Privacy.
In the section Block Cookies, indicate whether Safari should accept cookies from the Site and under what circumstances.
For an explanation of each option, click on Details.
To find out which websites store cookies on your computer, click on Details.
For other browsers and mobile devices:
ADS Formation et produits may use other identification technologies other than cookies that serve the same purpose in mobile environments where cookies do not work. These solutions can be SDKs (Software Development Kits) or Local Storage or any other suitable solution.
ARTICLE 7 - WHAT SECURITY PRECAUTIONS?
Each user opening an account is asked to create a username and a password. This password must be kept secret and you must restrict access to your computer or mobile devices and log out once you have finished using our services.
Furthermore, ADS Formation et produits has implemented technical and organizational measures to protect Personal Data against accidental loss, destruction, deterioration, abuse, damage and unauthorized or illegal access.
The Personal Data being confidential, ADS Formation et produits restricts their access to the only employees of the company or service providers who need it for the processing.
All persons with access to Personal Data are subject to a duty of confidentiality and may be subject to disciplinary action and/or other sanctions if they fail to comply with these obligations.
When we resort to subcontractors, service providers, or transmit Personal Data to partners, this transmission is subject to a contract to ensure the protection of this information.
ARTICLE 8 - WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?
You have a number of rights with respect to the processing of your Personal Data, within the limits of the regulations in force:
- The right to be informed about the use of your Personal Data,
- The right to access the personal information we hold about you,
- The right to request the correction of inaccurate, incomplete, ambiguous or outdated Personal Data (which you can also do directly in "My Account" if you have created one),
- The right to request that ADS Formation et produits deletes your Personal Data or that it stops processing them in certain circumstances,
- The right to withdraw your consent to receive information from us and to object to the processing of your data (in particular for the purpose of sending you commercial prospecting messages),
- The right to request that we return your data to you or transfer it to another service provider (right to portability),
- The right to define directives concerning the handling of your Personal Data after your death,
- The right to complain to the national authority responsible for the protection of personal data (in France, this is the Commission Nationale de l'Informatique et des Libertés - CNIL - whose contact details are available at https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil).
To stop receiving messages from ADS Formation et produits, you can also click on the unsubscribe link in each of our messages.
If you have any questions or wish to exercise your rights, simply send an e-mail or a written request to the following address:
ADS Formation et produits
Le délégué à la protection des données
87, rue Réaumur, F-75002 PARIS.
If you wish to make use of a right, your requests must be made in writing and must be signed and accompanied by a photocopy of an ID document bearing your signature. The request should specify the address to which the reply should be sent. ADS Formation et produits will have 1 (one) month to reply upon receipt of your request. This period may be extended by two months, taking into account the complexity and number of requests sent to ADS Formation et produits. In this case, we will inform you of the extension and the reasons for it.
ARTICLE 9 - WHAT ABOUT THE USE OF MY DATA VIA SOCIAL NETWORKS?
You can join our Instagram and Pinterest accounts, our Facebook pages, from our website and through them, follow our news. The only data that ADS Formation et produits is likely to collect is anonymous and processed for purely statistical purposes (in particular to monitor the number of subscribers who follow these accounts).