Privacy policy
– PERSONAL DATA AND COOKIES –
1- INTRODUCTION
As part of its activity, EFFECTOR is required to process information about you. For example, by browsing our website or our mobile and digital applications, by filling out a newsletter subscription form, by clicking on an advertising link that we present to you, you transmit information to us, some of which is likely to identify you (« personal data »).
This Privacy Policy tells you how we collect and process your personal data. We invite you to read it carefully.
Important
We only use your personal data in the cases provided for by the regulations in force:
– To perform a contract we have entered into with you, and/or
– to comply with a legal obligation, and/or
– Your consent to the use of your data, and/or
– The existence of a legitimate interest in using your data. A legitimate interest is a set of commercial or business reasons which justify Effector’s use of your data.
For any questions relating to this document, you can contact the EFFECTOR Data Protection Officer (click : email garcia.cecile@univ-pau.fr ).
2- WHO IS RESPONSIBLE FOR THE PROCESSING MENTIONED IN THIS DOCUMENT?
The party responsible for the processing mentioned in this document is EFFECTOR , whose registered office is at IPREM Technopôle Helioparc 2 avenue P. Angot 64053 Pau Cedex 9.
The data protection officer Effector
3- WHAT DATA DO WE COLLECT ABOUT YOU AND UNDER WHAT CIRCUMSTANCES DO WE COLLECT IT?
3.1 Data you send us directly
During the various contacts we have with you, you may be asked to provide us with information about yourself. This information is collected in particular when you register for a newsletter, create an account on our website and application or access any other offer or service.
This data includes your e-mail address and any other information you wish to share with us.
3.2 The data we collect in the course of our commercial relationship
The data we collect in the course of our commercial relationship with you includes the following:
– Your participation in promotional offers, competitions or events;
– Requests you have made to our community manager or incidents you have reported to us, for example concerning the performance of our services;
3.3 The data we collect automatically
Each time you visit our sites and applications, we collect information relating to your connection and browsing. Various technologies may be used to collect this data. The main one is the cookie.
- Data collected via cookies
A cookie is a text file deposited when you visit a website, an application or an online advertisement and stored in a specific space on the hard disk of your computer or mobile device. Cookies are managed by your Internet browser and only the sender of a cookie can decide whether to read or modify the information contained in it.
A cookie has a limited validity period. It is deposited and stored on your terminal in compliance with applicable legislation and subject to the choices you have made and which you may modify at any time, under the conditions specified in article 9 below.
A cookie does not identify you personally. It enables its sender to recognise your terminal and to collect a certain amount of information relating to the browsing carried out from this terminal.
Cookies have a number of functions, such as enabling you to browse a site or application efficiently, remembering your choices and the goods and services you wish to purchase, and offering you relevant advertising content based on your areas of interest as expressed during your browsing. Further information on cookies can be found on the following websites:
www.allaboutcookies.org
www.aboutcookies.org
www.youronlinechoices.eu
Cookies placed by EFFECTOR subject to your choices give us access to the following information:
– Identifiers of the equipment you are using (IP address of your computer, Android identifier, Apple identifier, etc.),
– Type of operating system used by your terminal (Microsoft Windows, Apple Os, Linux, Unix, BeOS, etc.),
– Type and version of browser software used by your device (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),
– Dates and times of connection to our services,
– Address of the Internet page from which you came (« referrer »),
– Browsing data on our services, content viewed.
- Data collected using standard Internet technologies
We may also use standard Internet technologies such as scripts, pixels and redirects. Scripts (sometimes called tags), written in javascript, are programmes that run in your browser and perform various actions, such as sending information to our servers. Scripts can also create pixels. Pixels (sometimes called transparent GIFs, clear GIFs or web bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an e-mail. Redirects make a web page available under several page addresses (URLs). When a browser opens a redirection URL, a page with a different URL is opened.
The aim of these technologies is to improve your experience on our sites and applications, including providing you with personalised content according to your centres of interest. For example, when a user clicks on a share button on an article, a script creates a pixel that enables the sharing to be counted. This enables us to see the total number of times an article has been shared, and we can rank the most shared articles.
These technologies give us access to the following information in particular:
– Information relating to your use of our sites and applications;
– Information relating to the presence of cookies on your terminal, the time and date of consultation of a page, and a description of the page on which the Web beacon is placed;
– Information on whether or not you read the e-mails we send you and on the clicks you make on the links contained in these e-mails.
Our sites and applications may also include scripts, pixels and third-party redirections. These technologies allow third party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites. These third party service providers process the information they collect for audit and research purposes, and to report information about our sites and applications and advertisements viewed on them. We do not share your identification data with these third parties in connection with their use of these technologies.
- Data provided by mobile devices
Certain mobile devices, depending on the functions you have activated (for example: « Push » or « Geolocation ») when downloading one of our applications, send information, in particular: model of your phone, version of its operating system, type of connectivity, name and version of the application used.
This data, which is necessary for the proper functioning of the mobile applications we publish, is automatically processed by our servers and those of some of our partners (in particular AT Internet, SmartAdServer) so that we can provide you with a service and advertising tailored to the technical characteristics of your device and measure the audience for our application.
In addition, if you have accepted this functionality when downloading our applications, we are able to identify the physical location of your device (geolocation), in particular to inform you of content or offers that we believe are in line with your expectations or centres of interest or to improve your experience on our mobile applications. In accordance with applicable law, geolocation functions can be deactivated at any time in the system settings of your device.
3.4 The data we assume
By combining the data we have about you with general, anonymous statistical information, we may be able to make assumptions about the content and services that are likely to meet your tastes or uses.
Example: If, according to statistical data, a majority of people aged between 30 and 50, living in Pau and interested in creating a website, are also passionate about social networks, and you are a company director, or a 42-year-old shopkeeper who regularly consults articles on our site relating to our activity, we will assume that you are also interested in e-marketing and we will be able to show you an advertisement for an affiliation service when you browse our site.
3.5 Data relating to minors
In principle, our products and services are intended for adults who are capable of entering into contractual obligations.
Users who are minors must obtain the consent of their legal guardian prior to the communication of personal data concerning them.
The age of 16 is accepted for registration on our sites and for some of our online services (e.g. newsletter).
Internet users under the age of 18 at the time of publication or creation of an online account have a specific right to have their personal data deleted. For any information, please contact the EFFECTOR data protection officer (Clic: email address garcia.cecile@univ-pau.fr ).
3.6 Data relating to a third party
Before offering a service or any other product that we market to a third party, you must ensure that the person concerned agrees to their personal data, in particular their postal address, being communicated to us.
3.7 Exclusion of all sensitive data
EFFECTOR does not collect any sensitive data about you. The following are considered sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data relating to health or sexual orientation. If such information is communicated to us in any way, it will be deleted.
4- WHAT DO WE USE YOUR DATA FOR?
This article tells you the main purposes for which we use the data mentioned in article 3.
4.1 Operations necessary for the supply of products or services
– Management of subscriptions to our newsletters and/or e-mail alerts;
– Customer relations: a community manager is available by e-mail for any questions or complaints;
– Customer satisfaction surveys;
– Sending information about changes or developments to our services;
– Management of the exercise of your rights to your personal data, under the conditions set out in article 9;
– Checking compliance with applicable legislation, our contracts and general terms and conditions of use.
4.2 Marketing and business development operations relating to EFFECTOR’s publications, products and services.
– Bringing your personal information up to postal standards, updating, enriching and de-duplicating it in a dedicated database;
– Sending information about our company, its publications and its activities;
– Sending marketing, advertising and promotional offers relating to our products and services by post, mail, e-mail, mobile notifications, on social networks or any other medium;
– Personalised loyalty or commercial prospecting campaigns;
– Setting up competitions or other promotional operations;
– Collecting customer opinions;
– Compilation of sales statistics.
4.3 Operations linked to commercial partnerships
– Sharing, exchanging or renting files with commercial partners in compliance with current regulations and security requirements;
– Sending marketing, advertising and promotional messages relating to partners’ products and services by post, mail, e-mail, mobile notifications, on social networks or any other medium;
– Setting up competitions or other promotional operations or events with commercial partners.
4.4 Purposes associated with depositing cookies on your browser
- Operation and optimisation of navigation on our sites and applications
o Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, according to the hardware and software for viewing or reading that your terminal has;
o Storage of information relating to a form that you have completed on our site (registration or access to your account) or to products, services or information that you have chosen on our site (service subscribed to, content consulted, purchase made, etc.);
o Automatic connection to reserved or personal areas of our site, such as your account, using identifiers or data that you have previously entrusted to us;
o Provision of sharing tools on social networks;
o Management of our platforms and performance of internal technical operations as part of problem-solving, data analysis, tests, research, analyses, studies and surveys;
o Implementation of security measures;
o Quality measures to ensure that our content is displayed correctly on your device.
- Traffic and audience measurement
o Establishment of statistics and volumes of visits to and use of the various elements making up our site (sections and content visited, path taken) in order to improve the interest and ergonomics of our services;
o Counting of the total number of advertisements displayed by us on our advertising spaces, classification and statistics;
o Analysis of audiences based on the results of advertising campaigns;
o Determination of centres of interest and behaviour;
o Improving customer/user knowledge for personalisation purposes.
- Personalised advertising on our sites and applications
o To adapt the advertising spaces to the display preferences of your terminal (identification of advertisements, establishment of statistics and volumes of frequentation and use of the various elements making up our site: sections and content visited, path taken) in order to improve the interest and ergonomics of our services;
o To adapt the advertisements displayed on your terminal when you browse our sites and applications to the technical characteristics of your terminal (1), to your previous browsing choices (2), to your centres of interest and uses (3), to the data you have previously communicated to us (4) and, where applicable, to the geographical location data of your terminal (5);
o To recognise you in order to display personalised advertising on social networks;
o To measure the effectiveness of our advertising campaigns and service offers.
5- HOW LONG DO WE KEEP YOUR DATA?
Your personal data is kept for a period in accordance with legal provisions or proportionate to the purposes for which they were recorded. Certain retention periods meet EFFECTOR’s legitimate interests as specified in the introduction.
The retention periods vary depending on whether we have an ongoing contractual relationship (you are an active client), whether we have had a contractual relationship with you in the past (you are an inactive client) or whether we have never had a relationship of this type with you (you are a prospect). The data relating to your browsing of our online services collected by the cookies that you have authorised has a specific retention period.
The table below lists the main retention periods for your data.
In any event, we regularly review the information we hold. When its retention is no longer justified by legal or commercial requirements or in connection with the management of your customer account, or if you have exercised a right of modification or deletion, we will delete it securely.
| Categories of data | Purposes | Retention periods |
| Data relating to a prospect | ||
| All data | Constitution and management of a file of prospective customers | 3 years from the date of collection of the data or the last contact from the prospective customer |
| Data relating to an active customer | ||
| All data | Customer account management | For the duration of the contractual relationship |
| Data relating to an inactive customer | ||
| Identification and contact data – Newsletter subscribers | Information on the development of our publications and offers | 3 years maximum from the date of unsubscription or the last contact from the customer |
| Data generated by cookies | ||
| Data linked to your browsing on our online services | Operation and optimisation of services Measurement of visitor numbers. Personalised content and advertising | Minimum 13 months |
Assumed data | |||
Data relating to your presumed uses and interests | Sending information and offers that are supposed to correspond to your interests and uses | Annual update | |
6- WHO IS LIKELY TO HAVE ACCESS TO THE DATA
THAT WE COLLECT?
6-1 Access to data within Effector
The following may have access to some of your data:
– Employees of the administrative, accounting, IT, community management and marketing & sales departments.
Access to your data is based on individual and limited access authorisations. Staff with access to personal data are subject to an obligation of confidentiality (through a nominal and personal confidentiality undertaking).
- Data transmission
They may also have access to some of your data:
- Subcontractors
They provide services on our behalf, including
– Handling telephone calls, sending postal or digital mail
– Personalising the content of websites and mobile applications
– Carrying out maintenance operations and technical developments
– Collecting customer reviews
– Providing analytical solutions or audience measurement statistics
Our subcontractors are given access to your data on the basis of signed contracts that specify their obligations in terms of data security and confidentiality.
- Social networking platforms
The use of social networks to interact with our sites and applications (including the « share » buttons on Facebook, Twitter, Google +) is likely to result in exchanges of data between EFFECTOR and these social networks. For example, if you are connected to the Facebook social network and you visit a page on the Nathalie Goujon website, Facebook is likely to collect this information. Similarly, if you view an article on the site EFFECTOR and you click on the « tweet » button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social networks to find out how they collect and process your data.
- Our commercial partners
They promote products or services on their own behalf or on behalf of advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our commercial partners and you allow them to access some of your information, in particular by connecting to their sites or applications, their confidentiality policies and their cookie deposits are binding on you. We have no control over the collection or processing of your data by our commercial partners on their own platforms.
- Police, judicial or administrative authorities
When we are legally obliged to do so or in order to protect the rights, property and safety of Le Monde Group.
7- IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?
We store your personal data in France. In all cases, we ensure that processing is carried out in accordance with this privacy policy and is governed by the European Commission’s standard contractual clauses, which guarantee an adequate level of protection for the privacy and fundamental rights of individuals.
8- HOW IS YOUR DATA PROTECTED?
As data controller, we implement appropriate technical and organisational measures in accordance with applicable legal provisions, to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorised access, including:
– The appointment of a data protection officer;
– The creation of an information systems security unit;
– Raising awareness of confidentiality requirements among our employees who have access to your personal data
to your personal data;
– Securing access to our premises and IT platforms;
– Implementing the company’s general IT security policy;
– Securing data access, sharing and transfer;
– High standards of data protection when selecting our subcontractors and partners.
9- WHAT ARE YOUR RIGHTS?
9.1 Your rights of access to your personal data
You have the right to access your personal data and request that it be corrected, supplemented or updated. You may also request the deletion of your data or object to its processing, provided you can justify this on legitimate grounds.
You may ask to exercise your right to data portability, i.e. the right to receive the personal data you have provided us with in a structured, commonly used format and the right to transfer this data to another data controller.
Lastly, you may formulate instructions concerning the retention, deletion and communication of your personal data after your death.
You can exercise your rights by contacting the Data Protection Officer at Effector IPREM Technopôle Helioparc 2 avenue P. Angot 64053 Pau Cedex 9 or by e-mail: garcia.cecile@univ-pau.fr
Before responding to your request, we may verify your identity and/or ask you to provide further information in order to respond to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the time limits set by law.
In the event of an unsatisfactory response, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).
9.2 Your rights to object to commercial solicitations
We may use your details for commercial solicitations, in accordance with applicable law and the clauses of this privacy policy. You may object to these solicitations at any time, depending on the communication channel we use to send them to you.
- Commercial solicitations by electronic means (e-mail) :
We comply with the rules of Article L.34-5 of the Code of Posts and Electronic Communications, which provides for the prior and express collection of your consent for the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS).
However, your express prior consent is not required when you are already a customer of EFFECTOR and the purpose of our solicitation is to offer you products or services similar to those we already provide.
In all cases, you always have the option to opt out of receiving such solicitations by clicking on the unsubscribe link provided in each email.
- Commercial solicitations on mobile applications
When you first open EFFECTOR’s mobile applications on your smartphone or tablet, you can give permission to receive mobile notifications or « push ». These notifications enable us to send you editorial content (news alerts, content highlighted by the editorial team), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in your smartphone settings.
9.3 Your rights to accept and manage cookies
The storage of a cookie on your browser terminal is subject to your wishes. You may at any time modify your choices regarding the acceptance or refusal of cookies placed on your terminal, either on your browser or online with various operators.
In order to manage cookies as closely as possible to your wishes, we invite you to configure your browser taking into account the purpose of the cookies.
How can you exercise your choices?
- Make your browser settings
You can configure your browser software either so that you are offered the option of accepting or refusing cookies from time to time, before a cookie is likely to be saved, or so that you systematically accept or refuse the saving of cookies on your terminal.
We warn you that any setting on your browser software concerning the refusal of technical and functional cookies may alter your browsing comfort on our websites, or even prevent the use of some of our services requiring the use of these cookies.
Where applicable, we decline all responsibility for the consequences of the degraded operation of our websites and services resulting from the impossibility for us to record or consult the cookies necessary for their operation and which you have refused or deleted.
To manage cookies and your choices, the configuration of each browser is different. This is described in your browser’s help menu, which will tell you how to modify your cookie preferences.
- Microsoft Internet Explorer
http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies - Microsoft Edge
https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
- Apple Safari
http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html - Google Chrome
http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 - Mozilla Firefox
http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies - Opera
http://help.opera.com/Windows/10.20/fr/cookies.html
- Cookies Flash from Adobe Flash Player
Adobe Flash Player is a computer application that enables the rapid development of dynamic content using the Flash computer language. Flash (and similar applications) memorises the settings, preferences and use of this content using a technology similar to cookies. However, Adobe Flash Player manages this information and your choices via an interface different from that provided by your browser software.
If your terminal is likely to view content developed using Flash language, we invite you to access your Flash cookie management tools directly from the site http://www.adobe.com/fr.
- « Do not track »
You can also set your browser to send a code to websites indicating that you do not wish to be tracked (« Do not track » option).
Microsoft Internet Explorer
http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
Microsoft Edge
https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
Apple Safari
http://support.apple.com/kb/PH11952
Google Chrome
https://support.google.com/chrome/answer/114836?
Mozilla Firefox
https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
Opera
http://help.opera.com/Windows/12.10/fr/notrack.html
- Make your choices online
For audience measurement cookies and analytical cookies
Analytical cookies enable us to obtain anonymous statistics on visits to our site in order to optimise it and detect any malfunctions. They are placed on our sites and applications by the companies Google Analytics and Facebook.
If you do not want our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links for further information:
– Cookies Google Analytics
https://tools.google.com/dlpage/gaoptout
For « Social Network » cookies
We use the Facebook, Twitter, Pinterest, Google+ and LinkedIn sharing buttons.
To manage your data on Facebook https://www.facebook.com/help/cookies/
To manage your data on Twitter https://support.twitter.com/articles/20170518-utilisation-des-cookies-et-des-technologies-similaires-par-twitter
To manage your data on Pinterest https://policy.pinterest.com/fr/cookies
To manage your data on Google+ https://policies.google.com/privacy?hl=fr#infochoices
To manage your data on Linkedin https://www.linkedin.com/legal/cookie-policy
Deactivating these cookies therefore prevents any interaction with social networks.
For advertising cookies
We use the Doubleclick and SmartAdserver platforms to manage advertising displays on our websites.
To manage Doubleclick cookies https://www.google.com/settings/u/0/ads/authenticated
To manage SmartAdserver cookies http://www.smartadserver.fr/privacy-policy
We also use the Ligatus platform to offer articles based on popularity and your interests, as well as sponsored articles.
To find out more about interest-based targeting http://www.youronlinechoices.com/fr/a-propos-de-la-publicite-comportementale/
To deactivate this targeting technology https://www.ligatus.com/fr/privacy-policy
You can also connect to the http://youronlinechoices.com website, which is run by digital advertising professionals belonging to the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France.
This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralised interface enabling you to express your refusal or acceptance of the cookies used by these companies to adapt the advertising likely to be displayed on your terminal to your browsing information:
http://www.youronlinechoices.com/fr/controler-ses-cookies/ .
Lastly, some cookies are placed by third-party service providers for the purposes of personalised advertising. You can also click on the following links to find out more about their practices and exercise your choices:
– Cookies Rubicon
http://www.rubiconproject.com/privacy/consumer-online-profile-and-opt-out/
– Cookies DoubleClick for Publisher
https://www.google.com/settings/u/0/ads/authenticated
– Cookies AppNexus
http://appnexus.com/en/company/platform-privacy-policy-fr
– Cookie weborama
https://weborama.com/fr/respect-de-la-vie-privee/
– Cookie Index Exchange
http://www.indexexchange.com/privacy/
