This Privacy Policy is an integral part of the General Terms and Conditions of Sale ("GTC") of TROISIEME CULTURE, headquartered at 27 allée du 6 juin 1944, 91410 Roinville, France, registered with the Registre du Commerce et des Sociétés d'Evry, France, under number 853498012 (hereinafter referred to as "TROISIEME CULTURE"), which can be accessed at https://www.cestquoilafrance.fr/cgv : as such, capitalized terms have the same definition as that which is given to them within the GTC.
1. DEFINITIONS
● Application: means the computer hardware or software with which the User's Personal Data is collected.
● Cookies: includes HTTP cookies, "flash" cookies, the result of the calculation of a unique terminal fingerprint in the case of "fingerprinting" (calculation of a unique terminal identifier based on elements of its configuration for tracking purposes), invisible pixels or "web bugs", and, in general, any other identifier generated by a software or an operating system (serial number, MAC address, unique terminal identifier (UTI), or any set of data that is used to calculate a unique fingerprint of the terminal (for example via a "fingerprinting" method).
● Usage Data:means information collected automatically from this Application (or third party services employed by this Application), which may include: the IP addresses or domain names of computers used by Users who use this Application, URI (Uniform Resource Identifier) addresses, time of request, method used to submit the request to the server, size of the file received in response, numeric code indicating the status of the server's response (successful, error, etc. ), the country of origin, the characteristics of the browser and operating system used by the User, various details of the time per visit (e.g. time spent on each page in the Application) and details of the path followed in the Application with special reference to the sequence of the pages visited, and other parameters relating to the User's operating system and/or computer environment.
● Personal Data (or Data): means any information concerning a natural or legal person, institution or association that is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
● Concerned Person means the natural or legal person to whom the Personal Data refers.
● Data Controller (or Owner): means the natural or legal person, public administration or any other entity, association or organization being entitled, even jointly with the Data Controller, to make decisions regarding the purposes and methods of processing Personal Data and the means used, including security measures regarding the operation and use of this Application. Unless otherwise stated, the Data Controller is the Owner of this Application. In this case, the Data Controller (or Owner) is TROISIEME CULTURE.
● User means the person using this Application, who must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
● Processing (or Process) means any operation or set of operations performed or not performed using automated processes and applied to data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction.
2. NATURE OF PERSONAL DATA PROCESSED
The use of the Website and/or the placing of an Order may result in the collection and Processing of Personal Data, carried out in compliance with the regulations in force and in particular with the amended Law n°78-17 of January 6, 1978 relating to information technology, files and freedoms and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (hereinafter the "RGPD ").
The Personal Data Processed by TROISIEME CULTURE in the context of the use of the Website www.cestquoilafrance.fr are strictly confidential.
These Data are those provided directly by the Customer, namely:
● last name(s) and first name(s) of parent
● city and country of parent
● language of the parent
● email address
● child(ren)'s first name(s)
● child(ren)'s date of birth
● child(ren)'s native language(s)
● child(ren)'s email address
● password
● bank card
3. CHARACTERISTICS OF PERSONAL DATA PROCESSING
When collected, this Data will be Processed by TROISIEME CULTURE for the purposes of:
● create a Customer Account on the Website;
● allow TROISIEME CULTURE to manage the processing of the Customer's Order (placing an Order, making the Products available, after-sales service);
● process the payment of the Customer's Orders and Subscriptions (monthly debit on the Customer's Account);
● send information and/or commercial offers from TROISIEME CULTURE subject to the Customer's express prior consent;
● allow the display of targeted advertisements on the Internet browser and social network pages of the Person Concerned (advertising retargeting, point 9);
● produce statistics that will be used by TROISIEME CULTURE, in particular to improve its Website, and/or transmitted to third parties after anonymization;
● allow TROISIEME CULTURE to create accounting documents and supporting documents in order to comply with certain legal obligations;
● allow TROISIEME CULTURE to build up evidence in the event of a possible dispute; and
● improve and customize the Products.
4. DURATION OF RETENTION OF PERSONAL DATA
In accordance with the provisions of the regulations in force, the Data processed are kept for limited periods of time, and, in general, for all the time necessary to:
● managing the processing of the Customer's Order (placing an Order, delivery, after-sales service);
● the operation of the Customer Account on the Website;
● the communication of information and/or commercial offers from TROISIEME CULTURE, if the Customer has given his/her express and prior consent;
● the purging of the legal conservation obligations incumbent on TROISIEME CULTURE;
● the production of statistics that will be used by TROISIEME CULTURE, in particular for the improvement of its Website, and/or transmitted to third parties after anonymization.
After one (1) year of suspension of the Customer Account, the Customer Account is deleted and the Personal Data is automatically purged to keep only pseudonymized and/or anonymized data, in compliance with legal, accounting and tax obligations incumbent upon TROISIEME CULTURE.
Prospective customers' data are kept for a maximum of six (6) months and are automatically purged to keep only pseudonymized and/or anonymized data.
In addition, data provided by the Customer to TROISIEME CULTURE may be communicated to third parties for commercial prospecting purposes, subject to the Customer's express prior consent.
5. PLACE OF PROCESSING OF PERSONAL DATA
The Data is processed at the Data Processor's registered office and at any other location where the parties responsible for processing are located. It is possible to contact the Data Manager for further information.
6. METHODS AND SECURITY OF PROCESSING PERSONAL DATA
The Data Manager processes Users' Data in an appropriate manner and takes all necessary security measures to prevent unauthorized access, disclosure, modification or destruction of the Data.
The User is informed that the Data relating to his/her bank details are processed in a secure manner on behalf of TROISIEME CULTURE by its service provider DALENYS, certified according to the PCI-DSS standard, a recognized international security standard.
As such, the User is informed that THREE CULTURE does not store any credit card information.
7. CUSTOMER RIGHTS
In accordance with the regulations in force, Law No. 78-17 of January 6, 1978, as amended, relating to data processing, files and freedoms and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, the Customer has, at any time:
● the right to access, rectify and/or delete data processed by TROISIEME CULTURE;
● of the right to object to the processing of data, to request TROISIEME CULTURE to limit the processing of data and/or the portability of data;
● of the right to withdraw or modify consent to the collection and processing of data.
These rights can be exercised by the persons concerned by the Data by writing to TROISIEME CULTURE and proving their identity:
● by email to the following address: contact@cestquoilafrance.com ;
● by postal mail at the following address: TROISIEME CULTURE - 27 allée du 6 juin 1944, 91410 Roinville ;
● through the website www.cestquoilafrance.fr by going to the "Contact me" section,
8. SPONSORSHIP AND PROMOTIONS
As part of sponsorship and promotion offers implemented by TROISIEME CULTURE, Personal Data concerning the beneficiaries of sponsorship and promotions could be processed. Where applicable, the User must therefore ensure that he/she obtains the consent of the sponsored third party prior to providing the Data.
9. ADVERTISING RETARGETTING
TROISIEME CULTURE uses advertising retargeting services ("remarketing") in order to offer its Clients and Users targeted advertising on social networks or third-party websites.
TROISIEME CULTURE is committed to respecting the rules applicable to each channel of distribution of advertising content. In any case, the Data is only used to improve the offer and will not be used for any other purpose.
The display of these targeted advertisements can be adjusted at any time via the privacy preferences of the web browser and/or social network pages used.
TROISIEME CULTURE uses the following retargeting tools:
● FACEBOOK BUSINESS MANAGER
TROISIEME CULTURE uses FACEBOOK BUSINESS MANAGER technology, a marketing service of Facebook, which allows personalized and targeted advertising to be displayed on Facebook based on the Customer's browsing behavior and purchasing preferences. For this purpose, TROISIEME CULTURE uses cookies and the email address previously provided by the Customer and/or User.
The rules regarding the processing of data by Facebook's marketing department as well as the possibilities to object to the collection and processing can be consulted here : https://www.facebook.com/about/privacy.
● GOOGLE ADS
TROISIEME CULTURE uses the Google Ads remarketing service provided by Google Inc. This allows TROISIEME CULTURE to send targeted advertisements to its Customers and/or Users based on their browsing behavior and purchasing preferences. TROISIEME CULTURE uses cookies as well as the email address previously provided by the Customer and/or User.
Google Ads can be deactivated and/or customized by visiting the following page http://www.google.com/settings/ad. The rules relating to the processing of data by the Google Ads service can be consulted here : https://policies.google.com/privacy?hl=fr.
10. GENERAL INFORMATION
10.1 Legal Action
The User's Personal Data may be used for legal purposes by the Data Manager, in the Courts or at any stage leading to a possible legal action resulting from improper use of this Application or related services.
The User is aware that public authorities may require the Data Processor to disclose Personal Data.
10.2 Additional Information Regarding User Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with contextual information regarding particular services or the collection and processing of Personal Data.
10.3 System Log and Maintenance
For operational and maintenance purposes, this Application and any third party services may collect files that record interactions with this Application (System Log) or use any Personal Data (such as IP address) for this purpose.
10.4 Changes to the Privacy Policy
The Data Manager reserves the right to modify this Privacy Policy at any time by notice to Users on this page. It is recommended that this page be reviewed frequently, with reference to the date of the last modification indicated at the bottom of this page. If a User objects to any changes made to this Privacy Policy, the User must cease using this Application and may request the Data Manager to delete the Personal Data. Unless otherwise stated, the then current Privacy Policy applies to all Personal Data that the Data Manager holds about Users.
10.4 Changes to the Privacy Policy
The Data Manager reserves the right to modify this Privacy Policy at any time by notice to Users on this page. It is recommended that this page be reviewed frequently, with reference to the date of the last modification indicated at the bottom of this page. If a User objects to any changes made to this Privacy Policy, the User must cease using this Application and may request the Data Manager to delete the Personal Data. Unless otherwise stated, the then current Privacy Policy applies to all Personal Data that the Data Manager holds about Users.
● oppose the use of Cookies;
● accept the use of Cookies and delete them after acceptance by using the settings of his web browser.
In case of opposition to the deposit of Cookies or subsequent deletion of Cookies, the User's experience may be degraded. Indeed, if the User refuses the use or deactivates the Cookies, he/she may not be able to access certain functionalities of the Site.
For information purposes, the User will find the information he/she needs to authorize or refuse the recording of cookies by visiting the following links:
Cookies used by TROISIEME CULTURE record information related to the navigation of the Website (pages consulted, date and time of consultation, etc.), which the User may read during subsequent visits and/or connections to the Website and/or to his Customer Account. These Cookies are used to facilitate the use of the Website in that they allow the display of information entered in the context of the use of a Customer Account at the time of the last connection by the User and to carry out statistical studies on the use of the Website (number of sessions, duration of connection, etc.) as well as to measure its audience.
Done on 1/01/2022
