PRIVACY AND PERSONAL DATA USE POLICY
Subsequently, we will refer to:
- “Personal Data”: is defined as being “any information relating to a natural person identified or identifiable, whether directly or indirectly, by reference to an identification number or to one or more factors specific to them”, in accordance with the information technology and civil liberties law of 6 January 1978.
- “Service”: service https://www.afalula.com and all its content.
- “Publisher” or “We”: AFALULA, legal person or natural person responsible for the publishing and content of the Service.
- “User” or “You”: the web user visiting the site and using the Service.
The purpose of this charter is to inform you about the undertakings of the Service in respect of your privacy and the protection of your Personal Data as collected and processed when you use the Service.
By signing up for this Service, you undertake to provide true information about yourself. Providing false information is against the general terms of the Service.
You will also find a description of your privacy protection rights and how the law protects you.
ARTICLE 2 - DATA COLLECTED ON THE SITE
The Data collected and later processed by the Service are those you freely sent us by completing the various files present within the Service. For some operations on content, you may have to share your Data with third parties through their own services, more specifically when you make payments. We do not have such data as their collection and processing are regulated by those service providers’ own terms. We invite you to read their terms before sharing your Data.
Your IP address (the identification number assigned on the Internet to your computer) is collected automatically. You are informed that the Service can use an automatic tracing tool (cookie), which you may reject by changing the relevant settings of your Internet browser as explained in the general terms of this Service.
Generally speaking, you can use the Service https://www.afalula.com without sharing any Personal Data. In any case, you are under no obligation to share such information. However, if you refuse, you may not be able to access certain information or services.
We collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data, but are not covered by law because the data do not directly disclose your identity. For instance, we can aggregate your usage data to calculate the percentage of Users that access a specific Service feature.
For the purposes of providing better content and services, the Service https://www.afalula.com uses the analysis service Google Analytics. Google Analytics does not track your surfing habits on third-party servers. Information concerning you to which Google Analytics has access does not contain your Personal Data.
We do not collect so-called ”sensitive” data.
The contact details of Users who sign up for the Service will be stored in accordance with the provisions of the 6 January 1978 law on information technology and civic liberties. In accordance with this law, users have the right to access, remove, change or rectify Data provided by them. To do so, all they have to do is submit their request by email to firstname.lastname@example.org, or by ordinary mail to AFALULA, Données personnelles, 82 rue de Courcelles 75008 Paris, France.
The collection of Users’ Personal Data by the Publisher does not require any report to the French personal data protection authority (Commission Nationale de l’Informatique et des Libertés – CNIL).
ARTICLE 3 - IDENTITY OF THE CONTROLLER
The controller is AFALULA.
ARTICLE 4 - PURPOSE OF THE DATA COLLECTED
Data identified as mandatory on the Service forms are necessary to access the corresponding features of the Service, particularly operations of the content provided within the Service.
The Service may collect and process its Users’ Data:
ARTICLE 5 - RECIPIENTS AND USE OF THE DATA COLLECTED
The Data we collect are processed for the purpose of performing operations on the Service’s content.
You may receive emails from our Service, including for purposes of sending you newsletters to which you consented. You can ask to no longer receive said emails by contacting us at email@example.com or using the relevant link in each of the emails that will be sent to you.
AFALULA is the only recipient of your Personal Data. Said Personal Data are never transmitted to a third party, notwithstanding processors whose services AFALULA uses. Neither AFALULA nor its processors market the Personal Data of visitors and Users of its Service.
We require that all third parties guarantee the security of your Personal Data and process them in accordance with the law. We do not allow our third-party service providers to use your data.
Article 6 - LEGAL BASES FOR THE PROCESSING OF DATA
In accordance with the General Data Protection Regulation (GDPR), AFALULA only processes Personal Data in the following situations:
- with your consent;
- where there is a contractual obligation (a contract between AFALULA and you);
- for purposes of meeting a legal obligation (under EU or national law).
Article 7 - DATA SECURITY
You are hereby informed that your Data may be disclosed in accordance with a law, regulation or following a decision made by a competent regulatory or judicial authority or, where necessary, for the purpose of enabling the Publisher to safeguard his rights and interests.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, changed, disclosed or accessed without authorisation. Moreover, access to your Personal Data are subject to a defined and documented security procedure.
ARTICLE 8 - DATA RETENTION PERIOD
Data are stored by the host of the Service, the contact details of which are contained in the legal notices relating to the Service and are retained for the period strictly necessary for the achievement of the purposes stated above and may not exceed 24 months. Beyond this period, they will be stored for exclusively statistical purposes and will not be used in any manner whatsoever.
ARTICLE 9 - AUTHORISED PROVIDERS AND TRANSFER TO A NON-EUROPEAN UNION COUNTRY
AFALULA hereby informs you that it uses the service of authorised providers to facilitate the collection and processing of the data that you have provided to us. The providers are based exclusively in the European Union.
AFALULA previously ensured that its providers implemented suitable guarantees and complied with strict requirements in respect of data privacy, use and protection. Said providers are also bound by the General Data Protection Regulation (GDPR).
ARTICLE 10 - DATA PROCESSING RIGHTS AND FREEDOMS
- Right of access: you have the right to submit a request for access to your Personal Data in order to receive a copy of the Personal Data in our possession; however, because of AFALULA’s obligation in respect of Personal Data security and privacy, you are informed that your request will be processed subject to proof of your identity, in particular by presenting a scan or photocopy of your valid identity document.
- Right to rectification: the right to ask us to rectify any of your incomplete or inaccurate Personal Data. Under this right, the law allows you to ask any Personal Data that is be inaccurate, false, incomplete or outdated be rectified, updated, blocked or erased.
- Right to erasure, also known as “the right to be forgotten”: in some cases, you can request that your Personal Data in our possession be deleted (unless where there is a compelling legal reason for us to store them).
- Right to restrict processing: you have the right, in certain circumstances, to request that we suspend the processing of Personal Data.
- Right to data portability: you have the right to ask us for a copy of your Personal Data in a commonly used format (for example a .csv file).
- Right to object: you have the right to object to processing of your Personal Data (for example, prohibiting us from processing your data for direct marketing purposes).
However, exercising of this right is only possible under either of the following two circumstances: where exercising of the right is based on legitimate grounds or where exercising of the right is designed to prevent the data collected from being used for purposes of commercial prospecting.
Contact us if you wish to exercise any of the rights described above by writing to AFALULA, Données personnelles, 82 rue de Courcelles 75008 Paris, France or by emailing firstname.lastname@example.org
You will not pay any fees to access your Personal Data (or to exercise any other right). However, we may charge you reasonable fees if your request is clearly baseless, repetitive or excessive. In such an event, we may also choose not to respond to your request.
AFALULA will be entitled, as appropriate, to object to requests that are manifestly abusive by their systematic and repetitive nature or by their number.
We may ask you for specific information to confirm your identity and provide you with access to your Personal Data (or allow you to exercise any right). This is a security measure to guarantee that said Personal Data are not delivered to an unauthorised person. We may also contact you for more information about your request so that we can provide a quicker response.
We endeavour to respond to all legitimate requests within a month. This time frame may be exceeded in the event of especially complex or several requests. In such a case, we will inform you accordingly.
ARTICLE 11 - COMPLAINT LODGED WITH THE DATA PROTECTION AUTHORITY
If you feel that AFALULA breaches its obligations in respect of your Personal Data, you can lodge a complaint with the competent authority. In France, the competent authority is CNIL to which you can submit a request electronically at: https://www.cnil.fr/fr/plaintes/internet.
ARTICLE 12 - POLICY ON COOKIES
A) GENERAL INFORMATION ON COOKIES PRESENTS ON THE SITE
AFALULA, as Publisher of this Service, may place cookies on your hard drive of your device (computer, tablet, mobile phone, etc.) to guarantee a fluid and optimal surfing experience on our website.
Cookies are small text files that allow us to recognise your computer, your tablet or mobile phone in order to customise the services we provide you.
The information collected through cookies does not allow us in any manner whatsoever to identify you by name. It is used solely to meet our own needs to improve our Service’s interactivity and performance and send you content that reflects your interests. None of this information is shared with third parties except where AFALULA has first obtained your consent or where disclosure of the information is required by law, at the request of a court or any administrative or judicial authority empowered to receive it.
To better inform you of the information that cookies identify, there is a table below listing the different types of cookies that can be used by AFALULA’s Service, their name, purpose, as well as how long they are placed the address.
B) SETTING YOUR COOKIE PREFERENCES
You can accept or reject the placing of cookies at any time.
When you first use the Service https://www.afalula.com, a banner briefly presenting information on the placing of cookies and similar technologies appears at the bottom of your screen. The banner advises that by continuing to surf on the site for AFALULA’s Service (by loading a new page or by clicking on various elements of the Service, for example), you are accepting the placing of cookies on your device.
Depending on the type of cookie concerned, obtaining consent to place and read cookies on your device may be necessary.
C) COOKIES EXEMPTED FROM CONSENT
In line with the recommendations of the Commission Nationale de l’Informatique et des Libertés (CNIL), some cookies are exempted from the requirement to first obtain your consent because they are not strictly necessary for the operation of the Service or are exclusively aimed at enabling or facilitating electronic communication. These mainly are session ID, authentication, load balancing cookies, as well as cookies for the personalisation of your interface. These cookies are all subject to this policy because they are issued and managed by AFALULA.
D) COOKIES REQUIRING YOUR PRIOR CONSENT
This requirement relates to cookies issued by third parties and described as “persistent” because they remain on your device until they are erased or expire.
Since such cookies are issued by third parties, their placing and use are subject to the third parties’ own privacy policies to which you will find a link below. The cookie family regroups web analytics and advertising cookies which AFALULA does not use, as well as social network sharing cookies (for social networks like Facebook, YouTube, Twitter, LinkedIn, etc.). Social network sharing cookies are issued and managed by the publisher of the social network concerned. Subject to your consent, these cookies allow you to easily share part of the content published by the Service, including by using the share “button”, depending on the social network in question.
E) TOOLS FOR SETTING COOKIES
Most Internet browsers by default are set to authorise the placing of cookies. Your browser gives you the opportunity to change the standard settings so that all cookies are systematically rejected or only some them are accepted or rejected depending on their issuer.
PLEASE NOTE: We would like to draw your attention to the fact that your refusing to have cookies placed on your device can affect your user experience, as well as your ability to access to some services and features of this Service. Where applicable, AFALULA assumes no responsibility for the consequences of the deterioration of your surfing conditions owing to your decision to reject, delete or block the cookies necessary for the operation of the Service. Those consequences may not constitute injury and you may not claim any compensation on these grounds.
Your browser also allows you to delete cookies present on your device or inform you when new cookies are likely to be placed on your device. These settings do not affect your surfing experience but can cause you to lose any benefits provided by the cookie.
Please acquaint yourself with all the tools made available to you so that you can set up your browser to reject the cookies placed on your computer.
F) SETTING UP YOUR INTERNET BROWSER
Every Internet browser has its own cookie management settings. To know how to change your cookie preferences, below is a link to the support you need to access the menu of your browser designed for this purpose.
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
For more information about cookie management tools, you can visit CNIL’s website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
G) LIST OF COOKIES
The detailed list of cookies used on https://www.afalula.com is available at the following address: email@example.com
All rights reserved - 15 April 2019