(UPDATE: MAY 2018)
1. PERSONAL DATA
You have the option to browse the Site without disclosing any personal information about yourself. However, if you choose to do so, you may not be able to benefit from certain information or services.
Some personal data will be requested if you complete a form on the Site (name, surname, email address, telephone number, etc., hereinafter your “Personal Data”). By providing this information, you expressly agree that it will be processed by VADE SECURE for the purposes indicated in section 1.2. below and, if applicable, only for the purposes set out at the end of each form.
We do not collect any personal data without your knowledge or prior consent. Only personal data provided voluntarily will be collected. This is data that we are committed to protecting in an optimal security environment.
In addition, we do not collect or process sensitive personal data that directly or indirectly reveals your racial or ethnic origin, your political, philosophical or religious opinions, your trade union membership, your health, or your sexual life.
In accordance with Regulation (EU) 2016/679 of April 27, 2016, in force as of May 25, 2018 in all countries of the European Union, known as the General Data Protection Regulation (hereinafter referred to under the initials “GDPR”), and the Data Protection Act of January 6, 1978 amended, VADE SECURE informs you of the following:
1.1. Identity of the data controller
The data controller is the company VADE SECURE, with its registered office at 2 Avenue Antoine Pinay 59510 HEM, France.
Tel.: +33 (0)359 616 650.
1.2. Purposes of processing
VADE SECURE may process your Personal Data for the following purpose(s):
- Provision of information or services that you have requested (in particular via the various forms of the Site);
- Improvement of the Site, our products, and our services (including cookies);
- Contact to offer you services and offers adapted to your interests;
- Sharing information on social networks.
VADE SECURE is the sole recipient of your Personal Data. This data, whether in individual or aggregated form, is never transmitted to a third party, notwithstanding the subcontractors whom VADE SECURE uses. Neither VADE SECURE, nor any of its subcontractors, sell the personal data of visitors and users of the Site.
1.4. Length of data retention
VADE SECURE only retains your Personal Data for the time necessary to fulfill the purpose of collection. In no event may it exceed 3 years.
1.5. Information rights and Freedom
You have the following rights concerning your Personal Data, which you can exercise by writing us a letter to the address VADE SECURE – Service Juridique – 2 bis avenue Antoine Pinay – 59510 HEM, France, or by email at firstname.lastname@example.org. A copy of your ID with mention of your dates and place of birth must be attached to your requests to prove your identity.
1.5.1. Right of access and communication of data
You have the right to access the Personal Data that concerns you. To do this, simply ask us for a copy of all the Personal Data we have about you.
VADE SECURE informs you that it shall be entitled, if necessary, to refuse manifestly abusive requests (by their number, their repetitive or systematic nature).
To help you in exercising your right, you will find a sample letter drafted by the French National Commission of the Computing and Freedoms (CNIL, also known as the French Data Protection Authority) by clicking on the link below (in French): https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces
1.5.2. Right to rectify your data
You have the right to request the rectification, updating, blocking, or the deletion of the data concerning you, which you can show to be inaccurate, erroneous, incomplete or obsolete, as the case may be.
Also, you can set general and specific guidelines in place regarding the fate of Personal Data after your death.
To help you in exercising your right, you will find a sample letter drafted by the French National Commission of the Computing and Freedoms (CNIL, also known as the French Data Protection Authority) by clicking on the link below (in French): https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees
1.5.3. Right to object
You have the right to object to the use of your Personal Data and request its removal.
To help you in exercising your right, you will find a sample letter drafted by the French National Commission of the Computing and Freedoms (CNIL, also known as the French Data Protection Authority) by clicking on the link below (in French): https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet
1.6. Response times
VADE SECURE undertakes to respond to your requests for access, rectification or opposition or any other request for additional information within a reasonable period of time, which may not exceed one month from the receipt of your request.
1.7. Authorized service providers and transfer to a non-member country of the European Union
VADE SECURE informs you that it uses its authorized service providers to facilitate the collection and processing of the data that you have communicated to us. These providers may be located outside the European Union and may be able to share the data collected through the forms on the Site.
Similarly, some VADE SECURE subsidiaries are located outside the European Union.
VADE SECURE has received advance assurance of the implementation by its subsidiaries and service providers of adequate guarantees and compliance with strict conditions regarding confidentiality, use and data protection. In particular, vigilance was centered on the existence of a legal basis for any data transfer to a non-member country of the EU (such as Binding Corporate Rules or Privacy Shield).
1.8. Complaint to the competent authority
If necessary, you can send a complaint or a request to the CNIL electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.
When you first log on to the VADE SECURE Site, a banner alerts you that information about your browsing may be stored in cookie files. You will find below information about the cookies on our Site, their purpose, and methods for cookie settings.
2.1. General information about the cookies on the Site
The information collected through cookies does not in any way identify you by name. It is issued for our own purposes only and is never passed on to third parties unless you have previously consented to it or when the disclosure of such information is required by law, by order of a court or any administrative or judicial authority empowered to do know it.
The information collected allows us to compile statistics on Site visitation or more generally the use of our Site, and to send you content adapted to your interests.
The retention period of the information collected through cookies shall not exceed one year.
2.2. Setting your cookie preferences
2.2.1. Accept or refuse the placing of cookies at any time
When you first log in to the Site, a banner briefly outlining information about the placement of cookies and similar technologies will appear at the bottom of your screen. This banner warns you that by continuing your navigation on the Site (by loading a new page or by clicking on various elements of the Site for example), you accept the placement of cookies on your device. Only by accepting cookies will remove the banner from your display.
Ø Cookies exempt from consent
In accordance with the recommendations of the CNIL, certain cookies are exempt from the prior collection of your consent to the extent that they are strictly necessary for the operation of the Site or have the sole purpose of enabling or facilitating communication by electronic means. These mainly include session ID, authentication, load balancing session cookies, as well as cookies for personalizing your interface. These cookies are fully subject to this policy to the extent that they are issued and managed by VADE SECURE.
Ø Cookies requiring the prior collection of your consent
This requirement applies to third-party cookies that are termed “persistent” as long as they remain in your device until they are deleted or expired. Since such cookies are issued by third parties, their use and deposit are subject to their own privacy policies. These kinds of cookies include audience measurement cookies, advertising cookies (which VADE SECURE does not use), as well as social network sharing cookies.
Audience measurement cookies provide statistics about visitation and use of various elements of the Site (such as the content/pages you visited). This data helps to improve the ergonomics of the Site. Two audience measurement tools are used on the Site:
- Google Analytics (opt-out module: https://tools.google.com/dlpage/gaoptout? hl=en).
Social network sharing cookies are issued and managed by the publisher of the social network concerned. Four types of social network sharing cookies are present on the Site:
2.2.2. Tools for cookie settings
Most Internet browsers are configured by default so that cookies are allowed to be placed. You can change these standard settings so that all cookies are systematically rejected or that some cookies are accepted or rejected according to their issuer.
WARNING: Your refusal to allow cookies to be placed on your device may alter your user experience and your access to certain services or features of the Site. In this case, VADE SECURE waives all responsibility concerning the consequences related to the degradation of your navigation conditions. These consequences cannot constitute damage and you cannot claim any compensation for this fact.
Your browser also allows you to delete existing cookies on your device or to notify you when new cookies may be placed on your device. These settings do not affect your navigation, but you lose all the benefit of the cookie.
To find out how to change your cookie preferences, you can consult the CNIL website (in French): https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.