Privacy and Data Protection Policy

PRIVACY AND DATA PROTECTION POLICY

 

 

 

 

PREAMBLE

 

When you browse our Website and in order to manage your Product Orders and/or your requests for information, INFOCLIPPER will collect and process personal data about you.

INFOCLIPPER aims to provide you with accurate information on all its processing.

For this reason, this privacy policy is addressed to Users of the Website http://www.info-clipper.com/ (hereinafter the "Website") under the French Data Protection Act of 6 January 1978, as amended, and the General Data Protection Regulation (EU) of 27 April 2016 (hereinafter "GDPR").

What is personal data?

"Personal data" is any information about you that makes it possible for you to be identified directly or indirectly. For example, your first name and surname or a photo may make it possible to be identified directly. Your email address may identify you indirectly.

Data relating to legal persons and in particular Businesses with legal personality, including the name, legal form and contact details of the legal person, are not affected by the duties under the GDPR.

What is processing?

The term "processing" refers to any operation or set of operations that involves personal data, irrespective of the process used (collection, recording, organisation, storage, adaptation, change, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, deletion or destruction).

 

 

1     WHO COLLECTS AND MANAGES YOUR DATA?

INFOCLIPPER, a joint-stock company with share capital of €165,020, registered in the Compiègne company and commercial register under no 497 833 137, with registered office at 17, rue des Marronniers, 60620 Cuvergnon, France (hereinafter "INFOCLIPPER") will act as data controller for processing operations relating to:

-     Management and tracking of accounts and contracts

-     Management of Orders, the delivery of the Products and the tracking of the commercial relation;

-     Management of requests for information;

-     Sending news and commercial offers;

-     Management of requests for the exercise of rights;

-     The proper functioning and continuous improvement of the Website.

 

Legal reminder:

The data controller, within the meaning of the Data Protection Act and the GDPR, is the person who determines the means and purposes of processing.

Where two or more controllers jointly determine the purposes and means of the processing, they constitute the joint controllers (or co-leaders).

The data processor is a person who processes personal data on behalf of the data controller and acts under the authority and instructions of the data controller.

 

1     DEFINITIONS

 

·     "Customer": means the contractual partner of INFOCLIPPER who gives a guarantee of being a professional as defined by French law and case law. In this respect, it is expressly stipulated that the Customer is acting in the context of his/her usual or commercial activity.

·     "Data" or "Personal Data" means Personal Data subject to Processing under this Privacy Policy, as defined in Article 4 (1) of the GDPR.

·     "General Data Protection Regulation" or "GDPR": means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

·     "Data Processor": means the natural or legal person, public authority, department or any other body that processes Personal Data on behalf of and under the instructions of INFOCLIPPER in accordance with Article 4 (8) of the GDPR.

 

·     "Processing/Process": means any of the operations referred to in Article 4 (2) of the GDPR, performed on Personal Data in the context of the performance of this Privacy Policy.

 

·     "User": refers to any natural or legal person who accesses and navigates the Website, whether a Customer or a simple Internet User.

 

2     WHAT ARE THE PURPOSES AND LEGAL BASES OF THE PROCESSING CARRIED OUT?

 

INFOCLIPPER collects only the Data necessary for the purposes explicitly stated below:

 

§     Management and tracking of accounts and contracts

 

Processing details

 

The management and monitoring of accounts and contracts covers the following processes:

 

-     Customer and User registration;

-     Management of the Customer accounts.

 

Legal basis

 

Performance of a contract or performance of pre-contractual measures

 

 

§     Management of Orders, delivery of Products and tracking of the commercial relationship

 

Processing details:

 

This processing has the following purposes:

 

-     Provision of services related to the ordering of Products on the Website;

-     Digital delivery of Products;

-     Commercial tracking.

 

Legal basis:

 

Performance of a contract or performance of pre-contractual measures

 

The User's consent when required.

 

 

§     Invoicing

 

Processing details:

 

This processing has the following purposes:

 

-     Invoicing tracking;

-     Maintenance of accounting records and legal receipts.

 

 

 

Legal basis:

 

The processing of the Customer's personal data is necessary for the performance of the contract (payment of the Products).

 

Legal duty: Article L.102 B and following of the Tax Procedures Book.

 

 

§     Management of information requests

 

 

Processing details:

 

This processing has the following purposes:

 

-     Response to contact requests by form or any other means;

-     Request tracking;

-     Informative tracking.

 

Legal basis:

 

Performance of a contract or performance of pre-contractual measures

 

 

 

§     Sending news and commercial offers

 

 

 

Processing details:

 

This processing has the following purposes:

 

Sending newsletters and other relevant marketing communications

 

Legal basis:

 

The User's consent when required.

 

 

§     Managing requests for rights arising from the GDPR and the amended Data Protection Act.

 

 

Processing details:

 

This processing covers all the operations necessary for the tracking of requests for rights sent to INFOCLIPPER (qualification of the request, surveys, carrying out specific technical operations, etc.). It only concerns cases where INFOCLIPPER is acting as a data controller.

 

Legal basis:

 

Our legal duty under the GDPR and the Data Protection Act.

 

 

§     The proper functioning and continuous improvement of the Website and its features

 

 

Processing details:

 

To ensure the proper functioning and continuous improvement of the Website and its features.

 

Legal basis:

 

Our legitimate interest in guaranteeing the best level of operation and quality of the Website, thanks in particular to the visit statistics.

 

The User's consent when required.

 

 

3     WHAT DATA IS COLLECTED?

The compulsory or optional nature of the personal data collected and the possible consequences of a failure to reply are indicated during the various contacts with the persons concerned.

You can see below the details of the personal data we may hold about you.

Details of data processed:

 

NB: the information provided below is not intended to be exhaustive and is primarily intended to inform Users of the categories of data that INFOCLIPPER may process.

§     For the management and monitoring of accounts and contracts:

-     Surname, first name;

-     Email address.

§     For the management of Orders, delivery of Products and tracking of the commercial relationship

 

-     Data relating to the identity of the Customer contacts: surname, first name

-     Email address

-     Postal address.

-     If applicable, company name

§     For invoicing

 

-     Data required for invoicing.

 

§     For the management of information requests

 

-     Surname, first name;

-     Telephone;

-     Email address

-     If applicable, company name

 

§     For sending news and commercial offers

 

-     Surname, first name;

-     Email address.

 

§     For the management of requests for rights resulting from the GDPR and the changed Data Protection Act

 

-     Surname, first name;

-     Email address;

-     If necessary, a copy of an identity card.

 

§     For the proper functioning and continuous improvement of the Website and its features

 

-     Data collected through cookies and other trackers on our Website; for more details, see our cookie policy.

 

 

 

4     WHAT PERSONAL DATA IS AUTOMATICALLY COLLECTED?

 

When you browse the Website, INFOCLIPPER automatically records information about your browsing.

When you use our services, connection data may be automatically recorded in our server logs, such as your anonymized IP address, your unique identifier, your operating system and its location, the type of browser you are using and the pages you have visited.

 

5     WHO DO WE SEND YOUR DATA TO?

 

Only the authorised and specified persons mentioned below will be able to access the Users' data:

·     Authorised INFOCLIPPER personnel;

·     The service providers responsible for managing and hosting the Website and INFOCLIPPER's computer system;

·     The service providers in charge of managing the payment;

·     If applicable, authorised personnel of our subcontractors;

·     If necessary, the courts concerned, mediators, chartered accountants, auditors, lawyers, bailiffs, debt collection Businesses, police or gendarmerie authorities in the event of theft or judicial requisition;

·     Third parties who may place cookies on your terminals when you consent to them.

Your data will not be shared, traded, sold or rented to anyone other than those mentioned above.

 

6     HOW LONG DO WE KEEP YOUR DATA?

INFOCLIPPER undertakes to ensure that the Data collected is kept in a form that allows your identification for a period that does not exceed the time necessary for the purposes for which it is collected and processed.

 

 

For the management and monitoring of accounts and contracts

The data is kept for the duration of the contractual relationship plus three (3) years.

They are then kept in an intermediate archive for five (5) years for evidentiary purposes.

 

For the management of Orders, delivery of Products and tracking of the commercial relationship

The data is kept for the duration of the contractual relationship plus three (3) years.

They are then kept in an intermediate archive for five (5) years for evidentiary purposes.

Accounting records are also kept for 10 years.

 

 

For the management of information requests

The data is kept for the time necessary to process the request, and then for three (3) years from the last contact with INFOCLIPPER.

 

For sending news and commercial offers

The data is kept until the User unsubscribes through the link provided for this purpose.

 

For the management of requests to exercise rights

Data relating management of requests for rights are kept for the time necessary to process the request. It is then archived for the duration of the criminal statute of limitations applicable in intermediate storage.

If a copy of an identity document is provided, it may be retained for one (1) year after receipt of the request.

 

For the proper functioning and continuous improvement of the Website

Cookies and other commercial tracers may be deposited on the User's terminal for a maximum period of thirteen (13) months. After this period, the raw traffic data associated with an identifier is either deleted or anonymised.

The information collected through cookies and tracers is kept for a period of twenty-five (25) months. After this period, this data is deleted or anonymised.

 

 

7     WHAT ARE YOUR RIGHTS?

In accordance with the Data Protection Act and the GDPR, you have the following rights (learn more):

-     Right of access (Article 15 GDPR), of rectification (Article 16 GDPR), of update and of data supplementation;

-     Right to deletion (or "right to be forgotten") of your personal data (Article 17 GDPR), when they are inaccurate, incomplete, ambiguous, outdated or whose collection, use, communication or conservation is prohibited;

-     Right to withdraw your consent at any time (Article 7 GDPR);

-     Right to limit the processing of your data (Article 18 GDPR);

-     Right to object to the processing of your data (Article 21 GDPR);

-     Right to portability of the data you have provided to us, where your data is subject to automated processing based on your consent or on a contract (Article 20 GDPR);

-     Right not to be subjected to a decision based exclusively on automated processing (Article 22 du GDPR);

-     Right to file a complaint with the CNIL (Article 77 GDPR);

-     Right to determine what happens to your data after your death and to choose whether or not we share your data with a third party that you have designated (Article 85 LIL). In the event of your death and in the absence of instructions from you, we undertake to destroy your data, unless their retention is necessary for evidential purposes or to meet a legal duty.

You can exercise your rights:

·     By sending a message on the Contact page ;

·     By mailpost to INFOCLIPPER - 17, rue des Marronniers, 60620 Cuvergnon, France

To learn more about your rights, you can also consult the Website of the Commission nationale de l'informatique et des libertés (National Commission on Informatics and Liberty), accessible at the following address https://cnil.fr.

 

8     SECURITY

INFOCLIPPER and any subcontractors undertake to implement all technical and organisational measures to ensure the security of the processing of personal data and the confidentiality of your data, according to the current technical means and in application of the amended Data Protection Act and the GDPR.

INFOCLIPPER will take the necessary precautions, with regard to the nature of your data and the risks presented by our processing, to preserve the security of the data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorised third parties (physical protection of the premises, authentication process for our customers with personal and secure access through confidential Credentials and passwords, logging of connections, etc.).

 

 

9     DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

 

INFOCLIPPER essentially processes your data within the European Union.

Given the nature of its business, INFOCLIPPER may need to transfer your data outside the European Union. In this case, these transfers are accompanied by appropriate guarantees in accordance with the regulations. These guarantees are available on request by post to INFOCLIPPER - 17, rue des Marronniers, 60620 Cuvergnon, France.

11. LOGIN DATA AND COOKIES

For the proper functioning of the Website, INFOCLIPPER uses connection data (date, time, Internet address, computer protocol of the visitor, page consulted) and cookies (small files saved on your computer) to identify you, to remember your visits and to benefit from audience measurements and statistics, particularly relating to the pages consulted.

 

You can consent, decline or choose the type of cookies you agree to be placed on your computers, tablets and smartphones.

 

A cookie is a text file that is deposited and read, in particular, when you browse a Website, irrespective of the type of terminal hardware used.

 

 

The cookie allows us to record certain information about your browsing and online behaviour, which enables us to facilitate and improve your experience as a web user.

 

The submission of these files on your terminal requires the prior collection of your consent when they are not strictly necessary for the proper functioning of the Website.

 

 

12. UPDATE OF OUR PRIVACY POLICY

 

This Privacy Policy may be changed, particularly in accordance with the various legislative and regulatory changes. For this purpose, the User may consult the update directly on the Website.

 

 

15/03/2022