CONFIDENTIALITY POLICY - PERSONAL DATA - COOKIES CHARTER

 

Last updated on : 2019.11.05

 

This charter (hereinafter the "Charter") is intended for users of the web and mobile site http://www.telmondis.fr (hereinafter the "Website").

 

When we use the terms "you" or "your", we are referring to you as user of the Website.

This Charter is designed to inform you of the reasons for and conditions of processing: 

•   Firstly, of your personal data on the Website, hereinafter called "Personal Data". Personal Data are information that directly or indirectly identifies you.

 

•   Secondly, of information concerning your browsing on the Website that may be saved in files called “cookies” or similar tools (for the sake of simplicity, we will refer to these cookies and similar tools by the single term “Cookies”). Some information from Cookies does not identify you directly or indirectly and is not Personal Data. Other information may identify you indirectly and legally constitute Personal Data. We will refer to them together hereinafter as "Information from Cookies”. To learn more about Cookies and similar technologies and the processing of Information from Cookies, you can directly read the “Cookies” section by clicking on the following link, 

II. COOKIES

For the sake of simplicity, Information from Cookies and Personal Data will be hereinafter referred to by the single term "Data".

 

This Website is published by SAS AUBES PRODUCTIONS, a French “société par actions simplifiée”, with capital of 48.000 Euros, whose registered office is at 46 avenue de Breteuil, 75007 Paris, registered on Paris Trade and Companies Register under number 429 138 019 (hereinafter the "Publisher" or "We/Us").

 

We may modify this Charter at any time, particularly to comply with any regulatory, case law, editorial or technical development. Prior to browsing the Website, we advise you to read the latest version of the Charter. You can find out whether any changes have been made since you last read it by consulting the date at the top of the page. 

Your Data are processed in accordance with applicable regulations, particularly the European Regulation known as "GDPR" (no. 2016-679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data) and the French data protection act (act no. 78-17 of 6 January 1978 on data processing, data files and freedoms, as amended, and any regulations which may complete or replace them (hereinafter "Data Protection Regulations").

 

The Publisher is the controller of most Data processing operations carried out on the Website as specified below.  

Processing is an operation on Data (such as consultation, collection, etc.).

However, the Publisher is not the controller for all the processing of your Data. Suppliers and customers of the Publisher or third parties may be the sole controllers for certain processing operations as specified below. 

 

 

1. I. DATA PROTECTION 

 

1. A. Processing for which the Publisher is controller

 

When the User uses the Website, Data may be collected and processed in order to allow access to the Website services (hereinafter the "Services") for administrative and commercial management purposes. 

 

1. 1) What Personal Data do you declare directly?

These are Personal Data that you communicate directly to us for the purposes indicated in our forms on the Website (e.g. Data provided to register for an account) 

 

Personal Data collected via forms 

The types of Personal Data collected by these forms are specified in each one and differ depending on the Service and the purpose of the processing. They may be:

•   Identification Personal Data (last name, first name, age, etc.)
•   Professional data concerning your company, functions, etc.
•   Contact Personal Data (email, postal address, phone number, etc.)
•   Personal Data concerning your habits or preferences 

 

When such Data are collected, you are particularly informed of:

•   the reasons why these Data are collected (purpose)
•   whether certain Data are mandatory or optional and where applicable, the consequences of not providing mandatory data. In general, if you do not provide mandatory Data, access to and use of the Services may be restricted. 
•   the controller(s) (the Publisher in principle but it may be partners in which case you are informed at the time the Data are collected)
•   your rights and how you can exercise them with the controller
•   the legal basis justifying the lawfulness of the processing (for example, if the processing is based on your consent, or on the need to comply with a legal obligation, or on the performance of the contract between us, or on the Publisher’s or a third party’s legitimate interest, etc.) 
•   the categories of persons authorised to access your Data (i.e. the recipients of your Data) 
•   if we intend to transfer your Data outside the European Union, we implement safeguards and we inform you of these safeguards which ensure that transfers comply with Data Protection Regulations,
•   the storage periods or, where this is not possible, the criteria used to determine this period,
•   and more generally all the information required by Data Protection Regulations.

This Charter again provides you with this information as well as other information.

 

1. 2) Which Data are indirectly collected on the Website?

In general, they are Information from Cookies or similar technologies. To find out more about Cookies and how to change your settings, click directly on section 

II. COOKIES

They may be data concerning browsing: i.e. data collected on behalf of the Publisher when you browse the Website. These browsing data are Connection Data such as the date and time of connection and/or browsing, the type of browser, the browser language and the IP address. 

 

1. 3) Why do we collect some of your Data and how long do we keep them? 

The reason or reasons why Data are collected in the collection forms are specified at the time of collection. 

The purposes of Data and Information from Cookies the deposit of which is subject to your consent, are indicated in the information banner that displays when you first connect and explained in greater detail in this Charter in the Cookies section which can be consulted by clicking here 

II. COOKIES

In general, the purposes and storage periods differ with the Services. The purposes and storage periods may be as follows, on the understanding that only the Data necessary for each of these purposes are collected. The purposes for which the Publisher collects Data and the corresponding storage periods are:

Purpose: Prospect new professional customers

•   Storage period: 3 years after the prospect’s last contact
•   Legal basis: Consent (newsletter) / legitimate interest  

 

Purpose: Manage the user base (B2C)

•   Storage period: 3 years after the data collection or the customer’s last contact
•   Legal basis: Contract performance 

 

Purpose: Manage the user base (B2B)

•   Storage period: 3 years after the data collection or the customer’s last contact
•   Legal basis: Contract performance 

Purpose: Secure the loyalty of the customers base (Newsletter, emailing ...)

•   Storage period: 3 years after the data collection or the customer’s last contact
•   Legal basis: Consent / legitimate interest  / Contract performance

 

Purpose: Analytical management of website activity and website improvement 

•   Storage period: 13 months after the customer’s last contact
•   Legal basis: legitimate interest  

 

Purpose: Manage exercise of the rights of the data subject (1)

•   Storage period: 3 years after the exercise of the rights 
•   Legal basis: legal obligation  

1.  (1) Rights of erasure, rectification: Retention of data name, e-mail address, and purpose and justification of requests. 

The durations are mentioned subject to additional legal obligations

Your Data will not be kept by the Publisher for longer than is strictly necessary for the purposes indicated in this Charter, in accordance with Data Protection Regulations and applicable laws. 

 

For example, if you register for an account and you then remain inactive, we will delete the Data you entered when you registered or we will anonymise them after three years of inactivity. 

 

Upon the expiry of the storage periods indicated for the main purpose of the processing, Data may be archived and kept for the statutory limitation period in order to defend our rights or for the storage period required by law.

Archiving means that these Data will no longer be consultable online but will be extracted and stored on an autonomous, secured medium. The Publisher may also keep Data (particularly User contributions on forums) in a permanently anonymised form, for the purpose of producing statistical analyses. These analyses do not identify Users under any circumstances; they only concern trends resulting from their aggregated Data.

Data may be collected for other purposes for certain specific or temporary services. Where applicable, the information concerning such processing will be indicated in a specific document when these Data are collected.

 

4) Who are the recipients of collected Data?

The database created when you register for Services is strictly confidential. We undertake to take all necessary precautions and appropriate organisational and technical measures to protect the security, integrity and confidentiality of the Data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorised third parties. 

 

•   Recipients of Personal Data collected for the Publisher’s purposes 

 

For the Publisher's own processing purposes, it needs authorised persons to be able to process these Data. Therefore, the Publisher’s authorised departments and its processing service providers are recipients who are subject to confidentiality and authorised to access the Data collected within the framework of your use of the Website.

 

•   Personal Data transferred to third parties 

 

In addition, Personal Data may be transferred to third-party recipients, such as commercial partners, for purposes determined by these third parties of which you will be informed when your consent is obtained. In general, any such transfer is only made with your prior consent, unless another legal basis is more appropriate. In this case, the third-party recipient will generally be the controller of this additional purpose.

 

•   Data transferred to public authorities and/or organisations: 

 

Finally, in accordance with applicable regulations, Data may be sent to competent authorities on request and particularly to public organisations exclusively to meet legal obligations, to court officers, ministerial officers and organisations responsible for recovering debts, and within the framework of investigating perpetrators of offences committed online.

 

1. 5) Protected transfers outside the European Union 

Some recipients are based outside the European Union. In accordance with Data Protection Regulations, safeguards have been or will be provided to ensure an appropriate level of protection of your Personal Data.

 

Among these recipients and in order to guarantee secure Data transfer, the Publisher may particularly use (i) a file sharing and storage service and (ii) a rights management service provider whose servers or systems may be based outside the European Economic Area (EEA), entailing the transfer of Data outside the EEA territory. Where applicable, the transfer is carried out with all appropriate safeguards to ensure the continued confidentiality, integrity and security of the Data, including, depending on the service providers: (i) the local legislation of the importing service provider where it is recognised as adequate by the competent Supervisory authority, (ii) the US Privacy Shield programme recognised by the European Commission as providing adequate protection of personal data transferred to the USA, (iii) "binding corporate rules" approved by the European Commission and guaranteeing an adequate level of personal data protection or (iv) Standard Contractual Clauses defined by the European Commission, requiring the service provider to implement and maintain an adequate level of personal data protection by contract. In all cases, the Controller verifies the effectiveness of these safeguards and keeps all additional information available to data subjects in the manner described below.

 

Information from Cookies and similar technologies may be transferred outside the European Union with a view to being hosted and processed for advertising or audience measurement purposes. You will find more information on this point for each partner concerned in section II. COOKIES

 

You may obtain a copy of the safeguards by contacting the controller at the following addresses:

 

By post : AUBES PRODUCTIONS – Direction de la communication - 46 avenue de Breteuil, Paris (75007)

By email: telmondis@telmondis.fr

Or our data protection officer at: RGPD@mediawan.com

 

1. 6) What are your rights and how do you exercise them?

In accordance with and within the limits of Data Protection Regulations, you have a right of access to, rectification and erasure - particularly the right to request erasure of Data where they were collected when you were a minor -, objection, restriction and portability of your Personal Data. 

 

When the processing of these Data is based on your consent, you may withdraw your consent at any time. 

When the processing is based on the legitimate interest of the Publisher or a third party, you may object to it at any time, for reasons relating to your specific situation. However, where the processing is done for direct marketing purposes, you may object to it without stipulating any reason, including profiling insofar as it is linked to such direct marketing.

You may also define directives concerning the post-mortem processing of your Personal Data. 

You may contact the Publisher at any time to exercise your rights, when the latter is the controller: 

By post: AUBES PRODUCTIONS – Direction de la communication - 46 avenue de Breteuil, 75007 Paris

By email: telmondis@telmondis.fr

Or our data protection officer at: Donnees.Personnelles@lagardere-studios.com

The Personal Data provided when you exercise your right of access and portability are provided on a personal and confidential basis. In this regard, in order to process any request for access and portability, we require you to provide the information necessary to identify you, i.e. a written statement on your honour certifying that you are the holder of said Personal Data along with a photocopy of your identity document bearing your signature. 

In the event of a dispute, you may refer the matter to the French data protection authority, the Commission Nationale de l’Informatique et des Libertés.

 

1. 7) Security

We take adequate technical and organisational measures to prohibit unauthorised access to your Data and their disclosure to unauthorised persons.

 

However, we cannot guarantee that we eliminate all risks of wrongful use of Data. You must keep your identifiers confidential to prevent any unlawful use of your account. 

 

For a request for erasure, the Publisher shall take action within the legal time limits in order to delete the Data (or to anonymise them in the case of public contributions) but shall not be liable for any residual traces that may be found online. 

 

B. Processing for which the Publisher is not controller

Some of your Personal Data collected on the Website may be used for the benefit of third-party partners. Furthermore, third-party partners may process Information from Cookies for their own account. They are then the controllers of the processing carried out and you must contact them to exercise your rights. 

In general, any such transfer to third parties is only done with your prior consent, unless another legal basis is more appropriate. 

 

When these third parties are the controllers of your Data, you are informed in the specific information or contractual documents (collection forms, competition rules, privacy policy of the third-party partner or customer, etc., Cookie section of this Charter).

 

 

II. COOKIES

1. 1) What is a Cookie?

A cookie or any similar tracker (hereinafter "Cookie(s)") is a tracker that may be saved on your device (computer, tablet or smartphone) when you consult a Service with a browser, via the Website. 

A cookie enables its issuer, during its validity period, to recognise the device concerned whenever it accesses digital content including cookies from the same issuer and, depending on the type of Cookie, to collect additional but not directly identifiable information about your behaviour as regards the Services. 

 

In the case of a computer used by several people, for instance several family members using the same browser, the cookie is allocated to the browsing information of all the people who have used the same device without distinction.

1. 2) Who uses Cookies?

Cookies may be placed on your device by the Publisher, by its technical suppliers or by its partners or third parties.

 

Only the user of the Cookie, i.e. the entity for which it is issued, whether or not it is the issuer thereof, is liable for its use and for the Data collected via it. 

1. 3) Why are Cookies used on the Publisher's Website?

Cookies allow the Website to function efficiently and your preferences to be saved, to provide the Publisher and its partners with information for statistical or advertising purposes. Below you will find the main purposes of the Cookies issued on the Publisher's behalf and in the privacy policies of the partners below you will find further information about the processing of Cookies they use.

 

•   COOKIES AND OTHER SIMILAR TECHNOLOGIES USED FOR BROWSING PURPOSES: 

These Cookies are necessary for you to correctly browse the Website. They are particularly used to:

- Adapt the Website presentation to the display settings of your device (language used, display resolution, operating system used, etc.);

- Store information about your identifiers;

- Give you access to your account or any other reserved space using your identifiers;

- Implement security measures, for example when you are asked to log in again to Content or a Service after a certain time has elapsed.

 

•   AUDIENCE MEASUREMENT AND STATISTICS COOKIES: 

Audience measurement Cookies help to prepare statistics and establish volumes of visits to and use of the various component parts of the Website (sections and content visited, browsing path), to enable the Publisher to improve the relevance and ergonomics of the Services.

 

•   ADOBE FLASH PLAYER™ "FLASH"© COOKIES:

 

"Adobe Flash Player"™ is an IT application allowing rapid development of dynamic content using the "Flash" computer language. Flash (and similar applications) remember the settings, preferences and uses of these contents via a technology that is similar to Cookies. However, "Adobe Flash Player"™ manages this information and the User's choices via a different interface to the one provided by their browsing software. 

 

1. 4) How do you control them?

By continuing to browse the Website, you agree to the Publisher's and third party cookies being placed on your device, for the purposes indicated in the information banner and in this Charter. 

However, you may express your choice to the Publisher's partners and configure your browsing software at any time so that Cookies are saved on your device or, on the contrary, are rejected, either systematically or for specific issuers. You may also configure your browser so that you are asked to accept or refuse Cookies whenever a Cookie is likely to be saved on your device. 

Please note: your choices concerning advertising Cookies are based on a Cookie. If you delete all the Cookies saved in your device, we will no longer know which consent you have given and it will therefore be reset. As a result, you will be asked to give your consent again when you next visit or when you next load a page of the Website. 

 

•   AGREEMENT TO COOKIES

 

You are deemed to have given your agreement:

•   by clicking the "OK" icon on the information banner you see when you connect to the Website for the first time,
•   by continuing to browse, that is to say when you have clicked on an element of the Site (image, link, "search" button, etc.) or have visited another page of the Site.

 

If, via your browser, you agree to Cookies being saved on your device, the Cookies integrated into the pages and contents you have viewed may be temporarily stored in a dedicated space on your device. They will only be readable by their issuer. 

 

The agreement you give is, in principle, only valid for thirteen (13) months after the first deposit on your device, after you have expressed your consent.

 

•   MAKING YOUR CHOICES 

Some Cookies are deposited on our Website by the Publisher or its technical service providers and used by the Publisher for its own needs in which case the Publisher is responsible for them.

Other cookies are issued and used by third-party partners of the Publisher for purposes determined by such third parties, in which case they are the controllers. 

Only the user of the Cookie, whether or not it is the issuer, is responsible for its use and the Data it collects via it. 

You will find more information about the purposes of third-party Cookies by reading these partners' privacy policies to which you will find links in the section below on "Making your choices about third-party Cookies".

 

•  NAVIGATION COOKIES STRICTLY NECESSARY FOR THE SERVICE :

PHPSESSID: session cookie

NSC : player

VIMEO : video player

•  SOCIAL NETWORK SHARING COOKIES

The Publisher offers you the ability to share editorial content and any type of content published on the Site through social networking sites. Social network cookies are managed by the publisher of the social network site. You are invited to read the policy for managing social network cookies on the concerned sites (Twitter – Reddit).

•  MAKING YOUR CHOICES ABOUT THIRD-PARTY COOKIES:

• ON NAVIGATION COOKIES

If your device is likely to view content developed using the Flash language, you can access the Flash cookie management tools directly from the website https://www.adobe.com/privacy/cookies.html. 

 

•  ON STATISTIC COOKIES AND AUDIENCE MEASUREMENT

 

Partner	Privacy policy	Unsubscribe link
Google Analytics (1P-JAR, ANID, CONSENT, NID)	https://www.google.com/policies/technologies/cookies/	https://tools.google.com/dlpage/gaoptout?hl=fr

 

• Means of making your choices: 

VIA YOUR ONLINE CHOICES:

• You can log in to the Youronlinechoices site, offered by the digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France. You will thus be able to find out which companies are registered on this platform and which offer you the possibility to refuse or accept the Cookies used by these companies to adapt the advertisements that may be displayed on their terminal to the Navigation User's information: http://www.youronlinechoices.com/fr/controler-ses-cookies/

 

VIA ABOUTADS:

• This site published in English also allows you to express your choice online via the following link: http://www.aboutads.info/choices/

 

VIA YOUR BROWSER SETTINGS: 

For Cookie settings, the configuration of each browser is different and is described in the browser's help menu which explains how you can change your cookie preferences: 

For Internet Explorer™:
http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies 

For Safari™:
https://support.apple.com/kb/H19214?locale=fr_FR&viewlocale=fr_FR

For Chrome™:
http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 

For Firefox™:
https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites

For Opera™:
http://help.opera.com/Windows/10.20/fr/cookies.html