Privacy Policy


Security and protection of personal data


Last updated on June 17, 2020

Définitions

The terms “Personal data”, “data subject”, “processor” and “sensitive data” have the meaning defined by the General Data Protection Regulation (GDPR: n° 2016-679).


Description of services provided

The purpose of the Website is to provide information about all of the Publisher's activities. The Publisher strives to provide information on the Website that is as accurate as possible. However, the Publisher cannot be held responsible for any omissions, inaccuracies, or shortcomings in the update, whether caused by the Publisher or by third-party partners who provide information to the Publisher.

All information provided on the Website is for informational purposes only and is subject to change. Furthermore, the information on the Website is not exhaustive. It is provided subject to modifications that have been made since it was put online.


Personal data management

The User is informed of the regulations concerning marketing communication, the Law of June 21, 2014 for Confidence in the Digital Economy, the Data Protection Act of August 6, 2004, and the General Data Protection Regulation (GDPR: n° 2016-679).


Data controller for Personal data collection

For the Personal data collected as part of the User's browsing on the Website, the data controller is:

Caroline Dero - Data Protection Officer (DPO) - dpo@keepyourdream.com 

As the data controller for the data it collects, the Publisher undertakes to comply with the legal framework in force. In particular, it is responsible for determining the purposes of its data processing, providing its users, prospects, and customers, with complete information on the processing of their Personal data from the collection of their consent, and maintaining a register of processing operations that complies with reality.

Whenever the Publisher processes Personal data, it takes all reasonable steps to ensure the accuracy and relevance of the Personal data with regard to the purposes for which it processes it.


Types of data collected

In the context of the use of the Websites, the Publisher may collect the following categories of data concerning its Users:


Disclosure of Personal data to third parties

Disclosure to authorities based on legal obligations

Based on legal obligations, your personal data may be disclosed in application of a law, regulation, or by decision of a competent regulatory or judicial authority. In general, we undertake to comply with all legal rules that could prevent, limit or regulate the dissemination of information or data and in particular to comply with the Law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms.

Disclosure to third parties for commercial solicitation for equivalent products and services

We may, with our business partners and occasionally, inform you of our new products, news and special offers, by email, by mail and by phone about products or services similar to the products or services that have been the subject of quotes or orders.

Disclosure to third party partners

We may make certain personal data available to strategic partners working with us, for the provision of products and services or helping us market our products to customers.

Disclosure to third parties with restrictions on recipients

The personal data that you communicate to us when you place an order may be transmitted to our suppliers and subsidiaries for the processing of your order. This information is considered by our suppliers and subsidiaries to be strictly confidential.

Disclosure to third parties for direct marketing

We may share information with advertising partners to send you promotional communications, or to show you more tailored content, including advertising relevant to products and services that may interest you, and to understand how users interact with advertisements.


Virality of Personal data reuse conditions

No commitment on the virality of conditions and submission to specific contractual obligations

In the event that your personal data is communicated to a third party, the Publisher reserves the right to contractually establish with you the terms and conditions of data reuse.


Advance information for the disclosure of Personal data to third parties in the event of a merger/acquisition

Prior information and opt-out possibility before and after the merger/acquisition

In the event that we take part in a merger, acquisition, or any other form of asset transfer, we undertake to guarantee the confidentiality of your personal data and to inform you before it is transferred or subjected to new confidentiality rules.


Purpose of reusing collected Personal data

Carrying out operations related to customer management concerning

Carrying out operations related to prospecting

Developing commercial statistics

Updating its prospecting files by the organization in charge of managing the opposition list to telephone canvassing, in application of the provisions of the Consumer Code

Organizing contests, lotteries or any promotional operation excluding online gambling and games of chance subject to the approval of the Online Gaming Regulatory Authority

Managing requests for access, rectification and opposition

Managing unpaid debts and litigation, provided that it does not relate to offences and/or does not result in the exclusion of the person from the benefit of a right, a benefit or a contract

Managing people's opinions on products, services or content


Data aggregation

Aggregation with Non-Personal data

We may publish, disclose and use aggregated information (information about all of our Users or specific groups or categories of Users that we combine in such a way that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other business purposes.


Identity data collection

Free consultation

Consulting the Website does not require prior registration or identification. You can do so without providing any personal data about yourself (name, first name, address, etc.). We do not record any personal data for the simple consultation of the Website.


Geolocation

Geolocation with partner sharing for referencing and aggregation (with opt-in)

We may collect and process your geolocation data with our partners. We undertake to anonymize the data used. In accordance with your right to object provided for by the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to geolocation.


Collection of terminal data

Collection of profiling and technical data for service provision purposes

Some of the technical data of your device are automatically collected by the Website. This information includes your IP address, Internet access provider, hardware configuration, software configuration, browser type and language, etc. The collection of this data is necessary for the provision of the services.

Collection of technical data for advertising, commercial and statistical purposes

The technical data of your device are automatically collected and recorded by the Website for advertising, commercial and statistical purposes. This information helps us to personalize and continuously improve your experience on our Website. We do not collect or store any personal data (name, first name, address, etc.) that may be attached to a technical data. The collected data may be resold to third parties.


Right of access, rectification and opposition

In accordance with the current European regulations, Users of the Site have the following rights:

As soon as the Publisher becomes aware of the death of a User and in the absence of instructions from the User, the Publisher undertakes to destroy their data, unless its retention is necessary for evidential purposes or to comply with a legal obligation.

If the User wishes to know how the Publisher uses their Personal Data, to request its rectification or to object to its processing, the User may contact the Publisher in writing at the following address:

KEEP YOUR DREAM SAS, Caroline Dero - DPO, 30, rue Montrosier - 92200 Neuilly-sur-Seine, FRANCE

In this case, the User must indicate the Personal data that they would like the Publisher to correct, update or delete, by identifying themselves precisely with a copy of an identity document (identity card or passport).

Requests for deletion of Personal data will be subject to the obligations imposed on the Publisher by law, in particular with regard to the retention or archiving of documents.

Finally, Users of the Site may file a complaint with the supervisory authorities, and in particular with the CNIL (https://www.cnil.fr/en).


Hypertext links, cookies and Internet tags

A "cookie" is a small information file sent to the User's browser and stored on the User's device (e.g. computer, smartphone). This file includes information such as the User's domain name, the User's Internet access provider, the User's operating system, and the date and time of access. Cookies cannot damage the User's device under any circumstances.

The Publisher may process the User's information concerning their visit to the Site, such as the pages viewed and the searches performed. This information allows the Publisher to improve the content of the Site and the User's navigation.

The Publisher may also use Internet tags (also known as "tags", or action tags, single-pixel GIFs, transparent GIFs, invisible GIFs and one-to-one GIFs) on the Site and deploy them through a partner specializing in web analytics and which may be located (and therefore store the corresponding information, including the User's IP address) in a foreign country.

These tags are placed both in online advertisements that allow Internet users to access the Site, and on the various pages of the Site.

This technology allows the Publisher to evaluate the visitors' responses to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the User's use of the Site.

The external service provider may collect information about visitors to the Site and other websites using these tags, compile reports on the Site's activity for the Publisher, and provide other services related to the use of the Site and the Internet.

Cookie retention period

In accordance with the recommendations of the CNIL, the maximum retention period for cookies is 13 months after they are first placed on the User's device, as is the validity period of the User's consent to the use of these cookies. The lifespan of cookies is not extended with each visit. The User's consent must therefore be renewed after this period.

Purpose of cookies

Cookies may be used for statistical purposes, in particular to optimize the services provided to the User, based on the processing of information concerning the frequency of access, the personalization of pages, the operations performed and the information consulted.

You are informed that the Publisher may place cookies on your device. The cookie records information relating to your browsing on the service (the pages you have consulted, the date and time of consultation, etc.) which we may read during your subsequent visits.

User's right to refuse cookies, deactivation resulting in a degraded operation of the service

You acknowledge that you have been informed that the Publisher may use cookies, and you authorize the Publisher to do so. If you do not want cookies to be used on your device, most browsers allow you to disable cookies through the settings options. However, you are informed that some services may no longer function properly.

Possible association of cookies with personal data to allow the service to function

The Publisher may collect browsing information through the use of cookies.


Technical data storage

Technical data retention period

Technical data is stored for the period strictly necessary to achieve the aforementioned purposes.


Personal data retention and anonymization period

Data necessary for issuing quotes

One year if the quote is not followed up; if the quote leads to an order, the data is transferred to our company's customer file.

Data necessary for carrying out commercial prospecting operations with our prospects

Three years from the date of data collection or the last contact from the prospect.

Data concerning opt-out lists for receiving colicitation

Three years

Data retention during the contractual relationship

In accordance with Article 6-5° of the French Data Protection Act of January 6, 1978, personal data that is processed is not kept beyond the time necessary for the execution of the obligations defined at the conclusion of the contract or the predefined duration of the contractual relationship.

Retention of anonymized data beyond the contractual relationship/after account deletion

We keep personal data for the period strictly necessary to achieve the purposes described in these Terms and Conditions. Beyond this period, it will be anonymized and kept for exclusively statistical purposes and will not be used for any purpose whatsoever.

Data deletions

Data purging procedures are implemented to ensure the effective deletion of data as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached. In accordance with the French Data Protection Act of January 6, 1978, you also have the right to delete your data, which you can exercise at any time by contacting the Publisher.

Data deletion after 3 years of inactivity

For security reasons, if you have not authenticated on the Site for a period of three years, you will receive an email inviting you to connect as soon as possible, otherwise your data will be deleted from our databases.


Indications in case of a security breach detected by the Publisher

Informing the User in case of a security breach

We undertake to implement all appropriate technical and organizational measures to guarantee a level of security adapted to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data. In the event that we become aware of illegal access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the realization of the risks identified above, we undertake to:

Limitation of liability

Under no circumstances can the commitments defined above regarding notification in the event of a security breach be construed as any form of recognition of fault or responsibility for the occurrence of the incident in question.


Transfer of Personal data abroad

Transfer of data to countries with an equivalent level of protection

The Publisher undertakes to comply with the applicable regulations relating to the transfer of data to foreign countries, in particular in accordance with the following procedures:

To find out the list of these countries: CNIL - Data protection in the world (in French)


Modification of the T&Cs and Privacy Policy

In the event of a modification of these T&Cs, we undertake not to lower the level of confidentiality substantially without the prior information of the persons concerned.

We undertake to inform you in the event of a substantial modification of these T&Cs, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.


Applicable law and dispute resolution

Application of french law (CNIL legislation) and jurisdiction of the courts

These Terms and Conditions (T&Cs) and your use of the Site are governed by and interpreted in accordance with the laws of France, including Law No. 78-17 of January 6, 1978, relating to Information Technology, Data Files and Civil Liberties. The choice of applicable law does not affect your rights as a consumer under the applicable law of your place of residence.

If you are a consumer, you and we agree to submit to the non-exclusive jurisdiction of the French courts, which means that you can bring an action relating to these T&Cs in France or in the EU country in which you live. If you are a professional, all actions against us must be brought before a court in France.

In the event of a dispute, the parties will seek an amicable solution before any legal action is taken. In the event of failure of these attempts, any disputes concerning the validity, interpretation and/or execution of these T&Cs shall be brought before the French courts, even in the event of multiple defendants or a call for warranty.


Data portability

Data portability

The Publisher undertakes to offer you the possibility of having all your data returned to you upon simple request. The User is thus guaranteed better control over his data and keeps the possibility of reusing it. This data must be provided in an open and easily reusable format.


Requests

For any request concerning the data protection policy of the Site users, and to exercise your rights, you can contact the Publisher at the following address:  contact@keepyourdream.com.

Politique de confidentialité - Version française