DATA CONFIDENTIALITY

CIMONE, registered in the Trade and Companies Register of Nîmes under number 898 372 339.

below " Les Francophones »»

Our society LES FRANCOPHONES is led to process some of your personal data to provide you with the services you expect from our website lesfrancophones.fr (hereinafter the "Site") or any other substituted URL.

In this context, our company LES FRANCOPHONES acts as Data Controller within the meaning of EU Regulation No. 2016/679 (GDPR) and the Data Protection Act No 78-17 of January 6, 1978 amended.

The data processing carried out by our company requires us to comply with specific legal obligations resulting from the Regulations on the protection of personal data. Our society LES FRANCOPHONES attaches fundamental importance to compliance with these obligations.

This privacy policy is therefore intended to present to you our obligations and commitments in complete transparency, in order to inform you as well as possible about the processing of your personal data in the context of your use of our Site.

1    DEFINITIONS

-        Personal data : means any information which relates to you as an identified or identifiable natural person, according to the Personal Data Regulations ;

-      Personal data regulations: refers to EU Regulation No. 2016/679, known as the "RGPD", and the Data Protection Act No 78-17 of January 6, 1978 amended ;

-        Treatment : any operation or set of operations whether or not carried out using automated processes and applied to your Personal Data within the meaning of the Personal Data Regulations ;

-        Data controller: this is our company LES FRANCOPHONES, which determines the means and purposes of the Processing of your Personal Data described in Article 3 of this privacy policy ;

-        Subcontractor : designates the persons who act under the authority of our company LES FRANCOPHONES and under our instructions for certain Processing of your Personal Data ;

-        Breach : means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of your Personal Data, or unauthorized access to such data ;

-        Terms of Sales : means the general conditions of sale governing any purchase made on our Site, which accompany this Privacy Policy.

2    LES FRANCOPHONES IS RESPONSIBLE FOR PROCESSING

The Processing of Personal Data identified in this Privacy Policy is carried out by our company LES FRANCOPHONES as Data Controller.

The legal information about us at the top of this Policy.

3    THE PROCESSING OF PERSONAL DATA WE PERFORM

We process the Personal Data that you enter on the Site or through Cookies for the following purposes:

3.1.  Creation and management of our customer relationship:

3.1.1. Creation of your User Account

For the creation of your User Account, you must ask:

- your e-mail address (hereinafter referred to as “e-mail”) ;

 - your name ;

- Your first name;

- create a user name of your choice (Identifier);

- create a password passOf your choice .

With regard to the change of your surname, first name and the e-mail address entered during your registration, this personal data may be modified by sending a request to the following address: rgpd@lesfrancophones.fr If applicable, the referent  to the protection of personal data may ask you for any proof of identity in order to ensure that the request for modification comes from you.

As part of the General Terms and Conditions of Sale, you must maintain the accuracy of your identification data (Last Name, First Name) throughout the duration of your User Account for the purposes of the Services.

You can modify and/or delete the other information at any time, directly on the Site in your profile in the “My Account 

Regarding the password, it is up to you to create a strong password, not guessable with regard to your private life (first names, last names, dates, personal tastes, etc.), different from other passwords used on other applications (1 account – 1 password), never write it down anywhere (paper/digital), etc. The longer and more complex your password, the lower the risk of your account being hacked.

Given the state of the art in terms of passing passwords, it is recommended that your word of password is composed of at least 12 characters including uppercase, lowercase, numbers and special characters. For example, you can write a sentence with spaces respecting the above criteria.

In any case, you are responsible for the security and preservation of the confidentiality of your password.

We emphasize that the communication of this information is mandatory so that we can create your member account.

Your Personal Data processed for the creation and management of your account is kept for the duration of your User Account and up to a maximum of 36 months from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

We specify that in the event of inactivity of your member account for two uninterrupted years, your account and its content will be deleted. You will be notified in advance of this deletion and can prevent it by logging back into your account before the time limit.

3.1.2. Order processing, shipping and tracking

Payment

When you place an order on the Site, you must log in to your User Account.

For the purposes of payment of the order by Credit Card, we do not become aware of this data and do not ensure it conservation.

You are actually redirected to the site of a Service Provider Payment (PSP) duly authorized by the Prudentiel and Resolution Authority (ACPR).

Your Personal Banking Data is therefore collected and processed by the Payment Service Provider in accordance with applicable banking regulations.

We only receive confirmation that the transaction was validated by the issuing establishment of your bank card.

xexpedition of order

For the purposes of delivery, you must ask:

-                  Your first and last name

-                  A delivery address (home, place of work, or any other desired address)

-                  A relay point address

-                  Your number phone

The Relai Point corresponds to a company that is duly authorized to receive orders for your account until it is withdrawn by your care.

The processing of your data for the dispatch of orders is part of the execution of the General Conditions of Sale (the Contract).

For the purposes of processing the delivery, this data is shared with the Logistics Service Providers (carriers, logistics warehouses), the Relay Point of destination of the Order if applicable, the Customer Management Service in the event of outsourcing.

Failing this, we will not be able to carry out the delivery of the Order to the desired place of delivery.

Data related to delivery is kept for a maximum of 36 months from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

Ø  trade management, after-sales services and recovery

For the purposes of our commercial, accountant and legal follow-up, we collect and maintain during each order:

-                  Details of each order and its amount

-                  The reference number for each order

-                  The invoice for each order

-                  History of your purchases

The data related to your orders is kept on your user account up to 36 months from a maximum of your last order.

Accounting documents, including contracts, invoices, delivery notes and other supporting documents are kept on our system for 10 years, to enable us to meet our legal obligations.

In the event of a dispute, this data may be kept until the final resolution of the dispute.

For the purposes of order processing, this data is shared with our administrative and financial management and control services, the customer management service and the collection service. These Services may be part of our internal organization or be outsourced to our providers .

3.1.3. Contacts, notifications and customer relations concerning the service

Some of your Personal Data is used so that:

-        you can contact us via the contact form, 

-Rreceive notifications required To the provision of the Service, And

-       more generally, that we can contact you for the needs of any customer relationship in connection with any Order (Order management, after-sales service, etc.)

These processing purposes are part of the execution of the General Terms and Conditions of Sale.

Your Personal Data concerned by these Processing purposes are:

-        Your Surname, first name,

-        Your email,

-

-       We emphasize that the communication of this information is mandatory in order to respond to your contact requests and contact you in the context of our customer relationship. Otherwise, we will not be able to respond to you.

Your Personal Data processed to take into account your requests for ccontacts, sending notifications and customer relationship management are kept for the duration of your member account until it is deleted and up to 36 months from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

3.1.4. Newsletter subscription

Our company publishes a Newsletter periodically, in particular to keep subscribed Users informed of new products and/or Services, news related to events of all kinds, and more generally any information that we consider useful to enable you to take full advantage of the Products and/or Services in connection with our activity. The Newsletter also allows you to be the recipient of promotional and/or commercial operations that we would like to send you concerning our Products and/or Services.

Subscribing to our Newsletter is optional, and you can unsubscribe at any time via the unsubscribe link that is included in our newsletters.

 

If your account remains inactive for two years after your last login, the subscription to the Newsletter will be revoked. You will be notified in advance of this deletion and can prevent it by logging back into your account before the time limit.

3.1.5. Prospecting commercial and advertising

If you are already a customer of the Site, we may send you commercial and/or promotional offers on products and/or services similar to those that you have already ordered on our Site.

The legal basis for this processing is our legitimate interest.

In order to inform you of any other product available and/or any promotional operation on such products, you have the possibility of expressing the wish to receive offers from our company and our partners.

These communications can be made by e-mail, SMS, telephone or mail.

For any communication relating to Products and/or Services different from the products/services that you have already ordered and/or those marketed by our partners, the legal basis is your Consent.

Subscribing to these promotional and commercial offers is optional, and you can unsubscribe at any time via the unsubscribe link which is included in any communication made in this context.

These offers would be disseminated through us, so that your data would not be communicated to third parties. 

If your account remains inactive for two years after your last login, the subscription to our partners' offers will be revoked. You will be notified in advance of this deletion and can prevent it by logging back into your account before the time limit.

3.1.6.      Customization of the member account

As part of the personalization of your User Account, you can personalize your profile by adding a photography . Your photograph can be imported from your library to your terminal. If it is a photograph of you, it will appear when you use your Account, in particular when you communicate with us or if you wish to communicate with other Users of the Site.

If you choose another photograph, make sure you have received permission from anyone else who may appear in the photograph. If it is a photograph taken by a third party, make sure that you have the rights to use it, in application of the rules provided for by the Intellectual Property Code.

You can modify and/or delete it at any time in your profile.

Any content and/or information to customize your account will be retained until it is deleted and, if not, up to 36 months from your last order. In case of litigation, such data could be retained until the final resolution of the dispute.

Summary of the Processing carried out for the creation and management of our customer relationship:

 

                                           Purposes

                                      Personal data concerned

Compulsory nature or not of the collection

                                                                Data retention period

                                                                                           Legal basis

 

                                     Account creation / management

 

                                    Last name, first name (s), email address, identifier, password

 

 

 

   

YES

 

 

 

For the duration of your account and 36 months maximum from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

 

Execution of the contract (GTC)

 

Notifications necessary for the provision of service and customer relations

 

 

 

Last name, first name(s), e-mail address

 

 

YES

 

For the duration of your account and 36 months maximum from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

 

 

Execution of the contract (GTC)

 

 

 

 

Shipping of orders

 

 

Family name, first names)

Delivery address

Relay point address

Number of phone[EJR15] 

 

YES

Up to a maximum of 36 months from your order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

 

Execution of the contract (GTC)


 

 

 

Commercial management, after-sales services and collection

 

Details of each order and its amount

 

Reference number specific to each order

 

Invoice for each order

 

History of your purchases

 

 

 

YES

 

Throughout the duration of your User Account and up to a maximum of 36 months from your last order. In the event of a dispute, this data may be kept until the final resolution of the dispute.

10 years for accounting documents

 

 

 

Execution of the contract (GTC)

 

Newsletter subscription

 

 

 

Last name First Name,

e-mail address

                                  

 

NO

 

 

Until you unsubscribe or 2 years after your last connection in the event of an inactive account

 

 

Your consent

Receipt of promotional and commercial offers on similar products that you have already ordered

 

Last name First Name,

e-mail address

 

NO

 

Until your opposition or 2 years after your last connection in the event of an inactive account

 

Our legitimate interest

Receipt of promotional and commercial offers of other products and/or services from our company and our partners

Last name First Name,

e-mail address

 

 

 

NO

 

 

Until you unsubscribe or 2 years after your last connection in the event of an inactive account

 

Your consent

 

Profile customization

 

Photography

 

NO

Deletion possible at any time. Deletion at the latest 36 months from your last order

 

Your consent

 

Contact request excluding orders

 

 

Last name, first name, email address

 

 

YES

 

36 months maximum from the entry of the contact data

 

Your consent

 

3.2 Creation of personalized content and improvement of your user experience:

We also collect some of your Personal Data in order to create personalized content on our Site. We also collect data about your use of the Site so that we can improve it and your user experience.

3.2.1 Site usage data - Cookies

As part of the use of the Site on your multimedia equipment (computer, tablet, mobile phone, etc.) (hereinafter referred to as the "Terminal"), we deposit files on your Terminal allowing us to collect technical information and of your use of the Site (hereinafter referred to as “the Cookies”).

Some Cookies installed by Les Francophones on your Terminal are necessary for the performance of the services available on the Site or for the establishment of communication.

Cookies allow us to know:

-     The type of your Terminal, your browser and screen size,

-De maintain the customization of the interface of your User Account (conservation of the basket, choice of language, presentation of the Services, etc.)

-        Page load time statistics, time spent on each page,

-        Statistics on your actions as a user (click, selection) per page,

-        Audience measurements per page.

The purpose of statistics / audience measurement is to enable our company to measure the performance of its Site, to detect browsing problems, to optimize its technical performance. This data is not "entered" by you on the Site or your Terminal, but is collected via files linked to our System.

With regard to the statistical data of use of our Site, these are processed on the basis of our legitimate interests, so that we can improve our Services and your user experience. We specify that these files have a purpose strictly limited to statistics and in particular to the measurement of the audience of our Site and only produce anonymous statistics.

We point out that any other Cookies are not mandatory. You are free to accept them under the banner dedicated to Cookies on our Site. .

With regard to the data collected in our legitimate interest, they are kept for a maximum period of twenty-five months from their collection by our trackers.

With regard to Cookies requiring your consent, your consent is valid of 6 months maximum. The shelf life of these cookies will be of a maximum duration of6 month. At the end of this period, we will seek your consent again.

You are informed that you can withdraw your consent at any time for the processing of data linked to these cookies for which you have given your consent consent.

The Site may allow you, according to the rights granted by our company, to share content and/or information appearing on the Site, on third-party sites, in particular social networks. These sharing links therefore allow you to exploit the functionalities of these networks.

When you enable this sharing, the Site may send information to the social network solicited, which can then associate your actions with your profile with the third-party publisher (social networks, etc.).

Cookies from these third parties / social networks, not controlled by Les Francophones, can then be placed in your browser and/or Terminal. If you use these content sharing features on third-party publisher applications (e.g. Facebook, Instagram, gmail etc.), we invite you, before any sharing of your data with these publishers, to consult their privacy policy, in order to to know the methods of processing of your data collected by these third parties, in particular the purposes and sharing with third parties. If you decide to share your data on applications / sites of these publishers through the Site, Les Francophones no longer has control of your shared data, the authorizations you give or not, and cannot be responsible for the use made of your personal data by these other publishers.

Summary of the Processing carried out for the creation of personalized content and the improvement of your experience user :

-                 

 

                                           Purposes

                                      Personal data concerned

Compulsory nature or not of the collection

                                                                Data retention period

                                                                                           Legal basis

Cookies necessary for the realization of the services available on the Site within the framework of the GCS or for the establishment of the communication

-  Technical information on the characteristics of your Terminal;

-  Customizing your interface

 

 

 

YES

 

Twenty-five months from their collection by our tracers.

 

Legitimate interest

 

 

Cookies necessary for the production of statistics anonymous

 

- page loading time,

- time spent on each page

- actions (click, selection) per page,

- audience measurements per page

 

 

YES

 

 

Twenty-five months from their collection by our tracers.

 

 

 

Legitimate interest

Purpose of others Cookies

 

 

6 months maximum with the possibility of renewing your consent for periods of 6 months.

Your consent

 

4. NO AUTOMATED DECISION MAKING OR PROFILING

The Personal Data Regulations require us to inform you about the existence of automated decision-making, including profiling based on your Personal Data.

You are informed that under no circumstances our society LES FRANCOPHONES does not use your Personal Data to make such automated decisions about you, or to carry out profilingWithin the meaning of the Personal Data Regulations.

5. DATA TRANSFERS TO THE STRANGER 

Due to the identity of some of our Subcontractors, your Personal Data may be transferred outside the European Union, and more particularly to the United StatesUnited .

Our society LES FRANCOPHONES has ensured that the transfer of such data to its Subcontractors located outside the European Union is accompanied by appropriate or adapted guarantees according to the Regulations on the protection of personal data. These guarantees are:

-        The choice of storage of your Personal Data on servers located within the European Union ;

-        The conclusion of Contractual Clauses Kinds within the meaning of article 46 of the GDPR n°2016/679.

You can obtain a copy of the list of these guarantees by making your request to our contact person for personal data, whose contact details are indicated in Article 9.

6. SECURITY AND BREACH OF PERSONAL DATA

Our society LES FRANCOPHONES makes every effort to ensure the security of your Data Personal.

We thus implement several security measures adapted to the categories of Personal Data that we process:

-        In particular, we ensure that only the staff of our company LES FRANCOPHONES necessary for our Processing has access to the Personal Data concerned, and we ensure that this staff is subject to an obligation to confidentiality[EJR29] ;

-        We limit access to Personal Data through physical and paperless authentications ;

-        We use encryption and pseudonymization of data[EJR30] ;

-        We take care to implement means to guarantee the confidentiality, integrity and availability of your Data Personal[EJR31] ;

-        We are also setting up testing[EJR32]  intended to regularly evaluate the effectiveness of our technical and organizational measures.

These security measures are not exhaustive.

However, despite the protective measures it implements, our company cannot guarantee their infallibility, in particular against the illegal actions of third parties.

Thus, in the event of a Personal Data Breach, we will ensure that we comply with the obligations provided for by the Personal Data Regulations.

We will therefore notify the Violation suffered to the Commission Nationale Informatique et Libertés (CNIL) taken as the competent authority as soon as possible, within 72 hours of becoming aware of it, unless the Violation in question is not likely to create a risk for the rights and freedoms of the natural persons concerned.

When the Violation suffered is likely to create a high risk for your rights and freedoms as a natural person, our company LES FRANCOPHONES then notifies you as soon as possible, except:

-        Whether the Personal Data affected by the said Breach has been protected by appropriate safeguards in order to render the data incomprehensible to any person not authorized to have access to it;

-        If we have taken subsequent action which ensures that the high risk to your rights and freedoms is no longer likely to materialise;

-        Whether such notification would require disproportionate effort. In this case, we will instead proceed with a public communication or similar measure.

Our society LES FRANCOPHONES maintains an inventory of violations[EJR33]  of personal data that it has undergone, specifying in particular their methods, their effect and the measures taken to remedy them. We keep this inventory available to the CNIL.

7. EXERCISE OF YOUR RIGHTS OVER YOUR PERSONAL DATA

In accordance with the Regulations on the protection of personal data, you are informed that you have on your Personal Data that we process:

-        Of a right of access,

-        A right of rectification,

-        A right of limitation,

-        A right of opposition for legitimate reasons,

-        A right of portability

-        A right to erasure, ,

-        As well as the right to define directives relating to the fate of your personal data after your death.

You can exercise these rights by sending your written request to our referent in terms of personal data, whose contact details are indicated in article 9 below.

We emphasize that the aforementioned rights are strictly exercised within the limits made by the regulations on the protection of personal data.

8. YOUR PERSONAL DATA CORRESPONDENT WITHIN LES FRANCOPHONES  

Our referent in charge of issues relating to the protection of personal data within our company LES FRANCOPHONES east :

-        gDPR@Thergpd@lesfrancophones.frsfrancophones.frm[EJR34] 

You can address any questions regarding the processing of your Personal Data that you wish.

For your requests, in order to allow us to verify your identity and make the link with your User Account, we thank you for indicating to us in your message your surname, first name, e-mail address attached to your User Account, your address and specify the postal or electronic address to which you wish to receive the response.

If you have forgotten the e-mail address attached to your User Account on the Site or in case of doubt about a possible usurpation of your identity, we may ask you for proof of identity to verify that you are indeed at the origin of the request. Any credentials will be deleted after verification has been completed.

Our referent will respond to you within one month of receiving your request.

However, this period may be extended by two months, depending on the complexity and the number of requests received. In addition, you may be asked for proof of identity in order to respond to your request.

9. Reclamation to the CNIL

You are informed that you always keep the right to take a complaint with a control authority if you consider that our company contravened the regulations on the protection of personal data when processing your personal data.

This authority presents itself in France as the National Commission for Computing and Liberties (CNIL), located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22, https://www.cnil.fr/fr/vous-souhaitezcontacter-la-cnil. .

The CNIL benefits from an online complaint filing service, available here: https://www.cnil.fr/fr/plaintes

10. CHANGES TO THIS PRIVACY POLICY

Our company may be required to modify this privacy policy, in particular due to an evolution of the Site, the methods of processing Personal Data and/or a change in the Regulations on personal data.

In this case, these modifications apply to the Processing of Personal Data carried out after the publication of our modified privacy policy.

You will also be informed of these news on the email address associated with your member account in accordance with the provisions of Article 3 of this Privacy Policy.