Confidentiality policy

published on 11/10/2018

The present confidentiality policy defines and informs you how Spincontrol uses and protects information that you have shared with us, or in case you use the present website accessible from the following address: www.spincontrol.fr (identified thereafter as the « Site »).

Please note that this confidentiality policy is likely to be modified or completed at any time by Spincontrol, notably in order to comply with any legal, regulatory, case-law or technological evolution. Should such case arise, the date of last update would be clearly identified at the top of the present policy. Those modifications engage the User as soon as they get online. It is therefore recommended that the User regularly consults the present confidentiality policy and policy related to cookies usage so as to be aware of its eventual modifications.

I. PERSONAL DATA

In general, you can access the website, www.spincontrol.fr edited by Spincontrol, without providing any of your personal information. You are not in any way obliged to send this information to Spincontrol.

However, in certain cases Spincontrol might ask you to provide personal information (see « Types and purpose of the collected data »). By providing this information, you expressly agree that it is treated by Spincontrol for the purposes indicated in point 3 below, as well as for the purposes reminded at the end of each form.

Should you refuse to provide such information, you might not be able to receive certain information or services that you requested.

In accordance with the General Data Protection Regulation adopted by the European Parliament on the 14th of April 2016, and the modified Law on Computer Technology and Freedoms from the 6th of January 1978, Spincontrol informs you about the following points:

1. Identity and contact details of the responsible for data treatment

The entity responsible for the data treatment is the company Spincontrol, whose headquarter is located in 238, rue Giraudeau 37000 Tours,
Tel.: +33(0)2.47.37.62.79 . Fax+33 (0)2.47.37.58.28,
E-mail: spincontrol@spincontrol.fr

2. Collect and origin of data

All data concerning the Users are directly collected from them.

Spincontrol commits to collect the consent of its Users and/ or allow them to refuse the use of their data for certain purposes, as soon as it is necessary.

 

In all cases, Users are informed about the purpose of collection of their data through the various forms of data collection present online.

3. Types and purposes of collected data

Spincontrol might need to analyze your Personal Data in order to provide to you the requested service(s). This collection is done using a series of forms which would have been completed directly by you.

  • [NEWSLETTERS] Diffusion lists

Our platform manages the following diffusion list(s):

- (Example: title + purpose) « General newsletter »: electronic information letter whose purpose is to inform you about our news, products and services.

By ticking the corresponding boxes in our various forms, you provide your consent to be able to receive the corresponding service.

Each time you receive such newsletter, there is a link available allowing you to unsubscribe at any time.

Our diffusion lists are managed by the platform [sendingblue and oxymailing).

Spincontrol only collects adequate, relevant and limited data for which it is necessary, based on the objectives for which they are analyzed.

4. Type of treated data

Spincontrol is likely to analyze the following data concerning you:

  • Name, surname, date of birth
  • Phone number, email address, postal address

5. Addressees

Spincontrol is the only addressee of your Personal Data. Whether it is individual or grouped data, they are never transmitted to any third party, except the subcontractor whom Spincontrol collaborates with (you can find more information about them in the point 7 below). Neither Spincontrol nor any of its subcontractors proceed to the commercialization of personal data from visitors and Users of its Site.

6. Duration of storage

Your Personal Data is stored by Spincontrol as long as it is necessary in order to perform the concerned activities, except if you request to close your account and in case you exercise your right to be forgotten – and in accordance with and within the limitation of legal obligations about the storage of documents related to those activities.

 [if client account only]

For example a client account without any activity for more than 3 years could be closed and the data would be made anonymous.

7. Exploitation of collected data outside of our platform

Data collection on our platform is not in any way provided or sold to any third party. It can however be exploited and transferred to another application in the following cases:

  • For the treatment of bank transaction, when purchasing online
    • When purchasing online with a credit card, data considered indispensable for the treatment of your order (name, surname, e-mail) is sent to the banking platform in charge of the transaction [PAYBOX SYSTEMS or other]  in a secure way. No banking data is collected or stored on our platform during this process.
  • As part of the routing of transactional e-mails
    • In order to optimize the delivery of our transactional e-mails (e.g. when sending tickets and subscriptions, confirmation of account creation…) and when using the platform of e-mails routing.
  • As part of the management of diffusion lists
    • In order to analyze and manage (un-subscription) diffusion lists, and to route the concerned information.
  • As part of analyses or study of our sales and customers
    • As part of our marketing policy and the management of our activity, we may perform automated analyses (profiling) or semi-automated (querying) on the collected data for statistical purposes, sales follow-up, for sending information or commercial offers on our activities.
    • In this context, you can exercise your right to opposition for free and at any time by contacting us at the address mentioned at the beginning of our CONFIDENTIALITY POLICY.
  • As part of the analysis of our audience on our platform
    • See chapter II. POLICY RELATED TO COOKIES

8. Computer Technology and Freedom rights

You have the following rights regarding your Personal Data that you can exercise by writing to our postal address mentioned in point 1 or by filling the contact form.

  • Access rights and communication of data

You can access to your Personal Data.

However, due to the safety and confidentiality obligations related to personal data which are required from Spincontrol, you are informed that your request will be taken into account given that you provide a proof of your identity, notably by providing a scan of your valid ID (in case of requesting it through our dedicated online form) or a signed photocopy of your valid ID (in case of request sent by writing).

Spincontrol informs you that they would have the right, where applicable, to refuse any obviously abusive request (as per the number of requests sent, their repetitive or systematic nature).

In order to help you with your request, and notably should you wish to exercise your access right using a written request sent to our postal address mentioned in point 1 above, you can find a model of letter prepared by the National Commission on Computer Systems and Freedoms (the « CNIL ») by clicking on the following link.

https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

  • Right to modify data

As part of this right, the law allows you to request the modification, update, locking or even deletion of data concerning you which is considered inaccurate, incorrect, incomplete or obsolete.

Moreover, you can define general and particular rules related to the future of your personal data after your death. Otherwise, heirs of a deceased person can demand to take into consideration the death of their close relative and/ or proceed to necessary updates.

In order to help you with your request, and notably should you wish to exercise, for yourself or on behalf of one of your deceased close relatives, your modification right using a written request sent to our postal address mentioned in point 1 above, you can find a model of letter prepared by the CNIL by clicking on the following link.

https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

  • Opposition right

It is possible for you to claim this right only in one of the following two cases:

  1. When the exercise of this right is based on legitimate motives; or
  2. When the exercise of this right aims at preventing that collected data be used for commercial prospection purposes.

In order to help you with your request, and notably should you wish to exercise your opposition right using a written request sent to our postal address mentioned in point 1 above, you can find a model of letter prepared by the CNIL by clicking on the following link.

https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

  • 8. Deadlines for replying

Spincontrol is committed to answer any of your requests, whether it relates to modification, opposition or any request to receive complementary information, in a reasonable timeline which would not exceed one month after reception of your request.

  • 9. Query to competent authorities

If you consider that Spincontrol does not respect its obligations regarding your Personal Data, you can send a complaint or query to the competent authorities. In France, the competent authority for such matter is the CNIL to which you can send a request electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

II. POLICY RELATED TO COOKIES

During your first connection to Spincontrol website you are informed via a banner at the bottom of the page that information about your browsing on the website may be saved in files called « cookies ». Our policy regarding the use of cookies allows you to better understand all that we put in place on our website in terms of browsing. It informs you notably about all the cookies present on our website, their purpose (part I.) and provides the steps for their setup (part II.).

1. General information regarding cookies present on our website

Spincontrol, as editor of the website, can proceed to the setup of a cookie on the hard drive of your device (computer, tablet, mobile phone etc.) in order to ensure smooth browsing on our website.

« Cookies » are small text files of limited size which help us recognize your computer, tablet or mobile phone in order to customize services that we propose to you.

Information collected using cookies does not allow in any way to identify you personally. It is exclusively used for our own needs in order to improve the interactivity and performance of our website as well as to send you contents suitable to you centers of interests. None of this information is communicated to any third party except when Spincontrol previously obtained your consent or when the disclosure of such information is required by law, by order of a court or any competent administrative or judicial authority authorized to have access to it.

In order to provide details and information about what cookies identify, please find below a table listing different types of cookies that may be used on the Spincontrol website, their name, purpose and storage duration. 

2. Setting your preferences regarding cookies

You can accept or refuse the storage of cookies at any time.

During your first connection to Spincontrol website you are briefly informed via a banner at the bottom of the page about information related to cookies storage and other similar technologies. This banner informs you that by continuing with this browsing on the Spincontrol website (by loading a new page or by clicking on various elements of the website for example), you accept the use of cookies on your device. Clicking on the “X” located at the right corner of the banner of information at the bottom of your screen will be considered as agreement with the use of cookies.

Depending on the type of cookie considered, your agreement to the reading or storage of the cookies might be required.

a. Cookies which do not require any prior agreement

In accordance with recommendations from the CNIL, certain cookies do not require prior agreement from you since they are strictly necessary for the functioning of the website or because their only purpose is to allow or facilitate communication online. It is notably the case of session cookies, cookies used for identification, load balancing as well as customization cookies. Those cookies entirely fall under the present policy since they are emitted and managed by Spincontrol.

b. Cookies which require prior agreement

This requirement concerns cookies emitted by third parties and which are qualified as « persistent » in the sense that they remain on your device until they are deleted or until they reach their expiry date.

Such cookies being emitted by third parties, their use and storage are defined under their own confidentiality policies whose link you can find below. This group of cookies gathers cookies to measure the audience (notably PIWIK), advertisement cookies (which Spincontrol does not use) as well as sharing cookies from social medias (notably from Facebook, YouTube, Twitter and LinkedIn).

Cookies used to measure the audience establish statistics concerning the frequency of use and usage of various elements of the website (such as contents/ pages that you have visited). This data participates to the improvement of the ergonomics from Spincontrol website. A tool to measure the audience is used on the present website:

Sharing cookies from social medias are emitted and managed by the editor of the concerned social media. Provided your prior agreement, those cookies allow to easily share part of the content published on the Spincontrol website, notably via a « key » leading to data sharing, depending on the concerned social media. Four types of sharing cookies from social medias are present on the Spincontrol website:

c. Several tools of cookies setup are available to you

Most Internet browsers are setup by default so as to allow the storage of cookies. Your browser gives you the possibility to modify those standard parameters so that all the cookies are systematically rejected or else that only some cookies be accepted or refused based on the issuer.

WARNING: We would like to draw your attention on the fact that the refusal of cookies storage on your device might alter your experience as a user as well as the access to certain services or functionalities of the present website. Should such case arise, Spincontrol declines any responsibility regarding the consequences linked with the worsening of your conditions of browsing which occur as a result of your choice to refuse, remove or block cookies considered as necessary for the functioning of the website. Those consequences cannot constitute any damage and therefore you would not be able to claim any financial compensation.

Your Internet browser can also help you delete cookies present on your device or inform you each time a new cookie may be stored on your device. This setup does not have any effect on your browsing experience but it makes you lose the benefit brought by the cookie.

Please review below the various tools available to you for the setup of cookies stored on your device.

d. Setup of your Internet browser

Each internet browser has its own parameters to manage cookies. In order to know which way to modify your preferences in terms of cookies, you can find thereafter the link to the necessary help to access to the relevant menu on your particular Internet browser:

Chromehttps://support.google.com/chrome/answer/95647?hl=fr

Firefoxhttps://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences   

Internet Explorerhttps://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Operahttp://help.opera.com/Windows/10.20/fr/cookies.html

Safarihttps://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR

Should you need more information regarding the tools to manage cookies, you can consult the website from the CNIL: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.