PRIVACY POLICY

PERSONAL DATA AND COOKIES

 

1-    INTRODUCTION

In the context of its business, the Company SILEANE processes data about you. For example, by browsing our website or by completing a newsletter subscription form, you are providing us with information some of which may identify you (“personal data”).

This Privacy Policy informs you of how we collect and process your personal data. We ask you to read it carefully.

Important

We only use your personal data in the instances set out by the regulations in force:

–     Carrying out a contract that we have already concluded with you, and/or
–      Complying with legal obligations and/or
–      Your consent to the use of your data and/or
–      The existence of a legitimate interest in using your data. A legitimate interest is a set of commercial or business reasons that justify the use of your data by SILEANE.

For any questions about this document, you can contact the company SILEANE (contact@sileane.com).

2-    WHO IS RESPONSIBLE FOR THE PROCESSING MENTIONED IN THIS DOCUMENT?

The entity responsible for the processing cited in this document is the company SILEANE, a simplified joint stock company with a capital of €50,000, registered with the Saint-Etienne trade and companies register under number 442 004 461 00 46, and whose head office is at 17, rue Descartes, 42000 Saint-Etienne, France and for whom Hervé Henry, chairman, is the legal representative.

3-    WHAT DATA CAN WE COLLECT ABOUT YOU AND WHICH CIRCUMSTANCES CAN WE COLLECT IT?

3.1       Data you send us directly

During the various times we have contact with you, you may be required to provide us with information about you. Data is more particularly collected during registration for a newsletter or when submitting a form.

This includes your e-mail address and any other information which you wish to bring to our notice.

3.2       Data we collect during our business relationship with you

 

The data we collect during our business relationship with you includes the following:

  • Your participation in events;
  • The requests you have sent to our company or the incidents that you have reported to us, for example about the performance of our services;

3.3       The data we automatically collect

 We collect connection and browsing data during each of your visits to our sites and applications. Various different types of technology may be implemented to collect this data. The main way is through cookies.

  • Data collected through cookies

Data collected through cookies A cookie is a text file that is stored in a specific area on your computer or mobile device’s hard disk when you visit an online site, application or advertisement. Cookies are managed by your internet browser and only the issuer of a cookie can decide to read or edit the information contained in it.

A cookie has a limited period of existence. It is deposited and stored on your device in compliance with the applicable legislation and subject to the choices you have expressed and that you can change at any time, under the conditions specified in Article 9 below.

Cookies cannot identify you personally. Issuers use them to recognise your device and to collect a certain amount of information about your browsing habits on this device.

Cookies have several functions, such as enabling you to navigate efficiently on a site or an application, to remember your choices, any goods and services you want to buy, offer you relevant advertising content based on the interests you have expressed during your navigation. You will find more information about cookies on the following websites:

www.cnil.fr

www.allaboutcookies.org
www.aboutcookies.org
www.youronlinechoices.eu

Cookies deposited by SILEANE subject to your choices give us access to the following information:

–      Identifiers of the equipment you use (IP address of your computer, Android ID, Apple ID, etc.),

–      Type of operating system used by your device (Microsoft Windows, Apple OS, Linux, Unix, BeOS, etc.),

–      Type and version of the navigation software used by your device (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),

–      Dates and times of logging in to our services,

–      Address of the internet page of origin (“referrer”),

–      Navigation data about our services, content viewed.

  • Data collected by standard internet technology

We are also likely to use standard internet technology, such as scripts, pixels and redirects. Scripts (sometimes called tags) written in javascript language are programs that run in your browser and perform various actions, for example sending information to our servers. Scripts are also able to create pixels. Pixels (sometimes called transparent GIFs, clear GIFs or web bugs) are lines of code that enable you to display a graphic image (which is usually invisible) on a web page or in an email. Redirections make web pages available under several page addresses (URLs). When a browser opens a redirected URL, a page with a different URL is opened.

The purpose of this technology is to improve your experience on our sites and apps, as well as providing you with personalised content based on your interests. For example, when a user clicks on an article-sharing button, a script creates a pixel that counts the share. This means we are able to find out the total number of shares for an article and we can establish a ranking for the most shared articles.

This technology mainly gives us access to the following information:

–      Information about your use of our sites and applications;

–      Information about cookies on your device, about the hour and date a page was viewed, and a description of the page where the online tag was deposited;

–      Information about whether you have or have not read the emails we have sent you and about whether you click the links contained in these emails.

3.4       Exclusion of any sensitive data

SILEANE does not collect any sensitive data about you. Sensitive data includes: data about racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health data or sexual orientation. If any such information is communicated to us in any manner whatsoever, it will be deleted.


4-    WHAT DO WE USE YOUR DATA FOR?

This article tells you the main purposes for which we use the data mentioned in article 3.

4.1       Operations that are needed for supplying products or services 

  • Management of subscriptions to our newsletters and/or e-mail alerts;
  • Customer relations: provision of a communitymanager who can be contacted via email about any questions or claims;
  • Customer satisfaction surveys;
  • Sending of information about changes or developments to our business activities;
  • Management of the exercise of your rights over your personal data, under the conditions set out in article 9;
  • Verification that the applicable legislation, our contracts and general terms and conditions are being complied with.

4.2       Marketing and commercial prospection operations relating to SILEANE‘s publications, products and services 

  • Postal standards compliance, updates, enrichment and duplication of your persona data in a specific SILEANE database;
  • Sending of information about our company and its business activities;
  • Personalised loyalty or commercial prospecting operations;
  • Setting up of competitions or other promotional activities;
  • Collection of customer feedback;
  • Development of commercial statistics.

4.3          Purposes of depositing cookies on your browser

  • Operation and optimisation of navigation on our sites and applications  

o       Adaptation of how our sites and applications appear to your device’s display preferences (language used, display resolution, operating system, etc.) during your visits, based on the viewing devices, reading devices and software that your device has on it;

o       Provision of sharing tools on social networks;

o       Management of our platforms and performance of internal technical operations to resolve issues, analyse data, and for tests, research, analysis, studies and surveys;

o       Implementation of security measures;

o       Quality measures to ensure us that the display of our content is adapted to your device.

 

  • Measurement of audience and habits 

o       Establishment of visit and volume statistics and statistics about the use of our various site elements (sections and content visited, user routes) to improve interest in our services and their ergonomics;

o       Improvement in customer/user knowledge for personalisation purposes.

 

5-    HOW LONG DO WE KEEP YOUR DATA?

 Your personal data is kept for a period of time in accordance with the legal provisions or in proportion to the purposes for which it was recorded. Certain retention periods meet SILEANE‘s legitimate interests as specified in the introduction.

The retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), or whether we have had a contractual relationship in the past (you are an inactive customer) or whether we have never had such a relationship with you (you are a prospect). The data from your browsing of our online services as collected by the cookies you have authorised has a specific retention period.

The table below gives the main retention periods for your data.

In any case, we regularly review the information we hold on you. We will delete your data securely when its retention is no longer justified by legal, commercial or customer account management requirements, or if you have applied your right to modify your data.

Data categories Purposes Retention periods
Data generated by cookies
Data about your navigation of our online services Operation and optimisation of our services Use measurement.Personalisation of content and advertisements  13 months maximum
Supposed data
Data about your supposed habits and interests Sending of information and offers to match your supposed interests and habits Daily update

6-    WHO HAS ACCESS TO THE DATA WE COLLECT? 

Access to data within SILEANE

 The following may have access to your data:

  • Employees from the administrative, accounting and management auditing, communitymanagement and marketing & sales services.

Access to your data is based on individual and limited access permissions. Those who can access personal data are subject to a Non Disclosure Agreement (by a nominal and personal confidentiality commitment).

 

7-    IS DATA SENT OUTSIDE THE EUROPEAN UNION?

We keep your data in France. In all cases, we make sure that the processing is carried out in accordance with this privacy policy and that it is governed by the standard contractual clauses of the European Commission which guarantees a sufficient level of protection of people’s privacy and fundamental rights.

 

9-    WHAT ARE YOUR RIGHTS?

9.1       Your rights regarding access to your personal data

You have the right to access your personal data and request that it be rectified, completed or updated. You can also request that your data be deleted or you can object to it being processed as long as you give a valid reason.

You can ask to exercise your right to the portability of your data, e.g. the right to receive the personal data that you have provided to us in a structured, commonly used format and the right to send this data to another data controller.

You can also create guidelines about the retention, deletion and communication of your personal data after your death.

You can exercise these rights by contacting SILEANE at the following address: 17, rue Descartes, 42000 Saint-Etienne, France or via email at: contact@sileane.com.

Before responding to your request, we may verify your identity and/or ask you to provide us with more information so we can reply to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the timeframes set by law.

If you are not happy with the response, you can file a complaint with the French National Commission for Data Protection and Civil Liberties (CNIL).

9.2       Your rights for accepting and managing cookies

The registration of a cookie on your browser is subject to your choice. You can at any time change your preferences regarding the acceptance or rejection of cookies stored on your device, either on your browser or online with different operators.

In order to manage cookies in a way that matches your choices as closely as possible, we advise you to configure your browser settings, while taking into account what these cookies are used for.

How do you set your preferences?

  1. Setting your preferences on your browser

You can set your browser to either systematically accept or reject cookies before a cookie can be saved or to systematically accept or reject the saving of cookies to your device.

We would like to alert you to the fact that any setting on your browser that rejects technical cookies and features will likely alter your browsing comfort on our websites or even prevent use of some of our services requiring the use of these same cookies.

If you choose to ignore this, we decline responsibility for any consequences arising from our sites or services functioning poorly as a result of our inability to save or check cookies that are required for proper operation but that you have rejected or deleted.

Each browser differs in terms of the management of your cookies and preferences. A description is given in your browser’s help menu, which should show you how to change your cookie preferences.

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

  • Cookies Flash de Adobe Flash Player

Adobe Flash Player is an application for the fast development of dynamic content that uses the Flash software language. Flash (and similar apps) remembers the settings, preferences, and usage of this content through technology similar to cookies. However, Adobe Flash Player manages this information and your choices by an interface different from that provided by your browser.

If your device is able to view content developed using Flash, we encourage you to access your Flash cookie management tools directly via the site http://www.adobe.com/fr.

  • “Do not track“

You can also set your browser so that it sends a code to other websites to inform them that you do not wish to be tracked (option “Do not track“).

Microsoft Internet Explorer

http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11

Microsoft Edge

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

Apple Safari

http://support.apple.com/kb/PH11952

Google Chrome

https://support.google.com/chrome/answer/114836?

Mozilla Firefox

https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister

Opera

http://help.opera.com/Windows/12.10/fr/notrack.html

  1. Online preferences

For audience measurement and analytics cookies

Analytics cookies enable us to obtain anonymous statistics about the use of our site in order to optimise it and to detect any potential bugs. They are deposited on our sites and applications by the Google Analytics, ATInternet (XiTi), Parse.ly, Weborama and ACPM site.

If you do not wish our sites and services to save cookies in your browser for audience measurement purposes, you can click on the following links where you will find more information about this:

–      Cookies Google Analytics

https://tools.google.com/dlpage/gaoptout

For “social networks” cookies

We use the LinkedIn sharing button.

To manage your data on Linkedin
https://www.linkedin.com/legal/cookie-policy

Disabling these cookies then prevents any interaction with social networks.