PRIVACY POLICY

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PRIVACY POLICY


(NB: To view the General Terms and Conditions of Sale, click here)
Last updated: May 24, 2018

This page explains how DENAIVE DIFFUSION SARL, hereinafter referred to as “Dominique Denaive,” uses and protects the information you provide to it, where applicable, when you use its platform accessible through the following domain: denaive.com (hereinafter referred to as the “Site”).

Please note that this Privacy Policy may be amended or supplemented by Dominique Denaive, particularly to comply with any legislative, regulatory, case-law, or technological developments. In such a case, the date of its update will be clearly stated at the top of this page. These changes are binding on the User as soon as they are posted online. Users should therefore regularly consult this privacy and cookie use policy to learn about any updates.

I. PERSONAL DATA

In principle, you may visit the Dominique Denaive Site without providing any personal information about yourself. You are under no obligation whatsoever to provide any information to Dominique Denaive.
However, in the event of refusal, you may be unable to access all the information or services you requested. Accordingly, Dominique Denaive may, in certain cases, ask you to provide your first name, email and postal address, and/or telephone number (hereinafter, your “Personal Information”). By providing this information, you expressly agree that it may be used by, for the purposes set out in section 2 below and those mentioned at the end of each form.
In accordance with the General Data Protection Regulation (General Data Protection Régulation) adopted by the European Parliament on April 14, 2016, and the amended French Data Protection Act of January 6, 1978, Dominique Denaive informs you of the following:

1. IDENTITY OF THE DATA CONTROLLER

The data controller is DENAIVE DIFFUSION SARL, a simplified joint-stock company registered with the Paris Trade and Companies Register under SIREN 443 099 874 00028, with share capital of €7,500, whose registered office is located at 7 rue du 29 juillet, 75001 Paris (hereinafter: “Dominique Denaive”).
Dominique DENAIVE can be contacted at the following details:
Postal address: 7 rue du 29 juillet, 75001 Paris
Email address: contact@denaive.com

2. PURPOSES OF PROCESSING

Dominique Denaive may process your Personal Information:
(a) for the purpose of providing you with the information and/or services you requested (in particular: sending emails and Newsletters, ebooks, videos, commercial offers, or responses to an online quiz; and/or)

(b) for the purpose of collecting information enabling it to improve its Site, products and/or services (in particular through cookies); and/or

(c) for the purpose of contacting you about events related to Dominique Denaive, including in particular updates to certain features, the launch of new products and/or customer support.

3. RECIPIENTS

Dominique Denaive is the sole recipient of your Personal Information. This information, whether in individual or aggregated form, will never be disclosed to a third party, except for processors engaged by Dominique Denaive (for more information on this subject, see section 7 below). Neither Dominique Denaive nor any of its processors markets the personal data of visitors and Users of its Site.

4. RETENTION PERIOD

Your Personal Information is retained by Dominique Denaive only for the period corresponding to the purpose of the collection, as indicated in section 2 above, and may not exceed 2 years.

5. DATA PROTECTION RIGHTS

You have the following rights concerning your Personal Information, which you may exercise by writing to Dominique Denaive at the postal address mentioned in section 1 or by completing the following contact form https://www.denaive.com/contact/

o Right of access to and communication of data
You have the right to access the Personal Information concerning you.

However, due to Dominique Denaive’s obligation to ensure the security and confidentiality of personal data processing, your request will be processed provided that you can prove your identity, in particular by supplying a digital or paper copy of a valid identity document.

Dominique Denaive informs you that it reserves the right, where applicable, to refuse requests that are clearly abusive (whether due to their number or their repetitive and/or systematic nature).

To assist you with your procedures, you will find a sample letter prepared by the French Data Protection Authority (the “CNIL”) by clicking the following link:
https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

o Right to data rectification
The law entitles you to request the rectification, updating, restriction, or deletion of data concerning you that may, where applicable, prove to be inaccurate, incorrect, incomplete, or outdated.

You may also set directives regarding what will happen to your personal data after your death. Where applicable, the heirs of a deceased person may require their relative’s death to be taken into account and/or make the necessary updates.

To assist you with your request, you will find, by clicking the following link, a template letter prepared by the CNIL to complete and return to the postal address mentioned in section 1.
https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

o Right to object
This right may be exercised only in one of the following two situations:
1. When exercising this right is based on legitimate grounds; or
2. When exercising this right is intended to prevent the collected data from being used for direct marketing purposes.

To assist you with your request, you will find, by clicking the following link, a template letter prepared by the CNIL to complete and return to the postal address mentioned in section 1:
https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

6. RESPONSE TIMES

Dominique Denaive undertakes to respond to your request for access, rectification, or objection, or to any other request for information, within a reasonable period and no later than 1 month from the date your request is received.

7. AUTHORIZED SERVICE PROVIDERS AND TRANSFERS TO A THIRD COUNTRY OUTSIDE THE EUROPEAN UNION

Dominique Denaive informs you that it uses authorized service providers to facilitate the collection and processing of the data you have provided to us. These service providers may be located outside the European Union and may have access to data collected through the various forms available on the Dominique Denaive Website.

Dominique Denaive has previously ensured that its service providers offer strict guarantees regarding the confidentiality, use, and protection of private data. Particular attention was paid to the existence of a legal basis for carrying out any transfer of data to a third country. In this regard, our service providers comply not only with Standard Contractual Clauses but also with the Privacy Shield when located in the United States.

8. COMPLAINT TO THE COMPETENT AUTHORITY

If you believe that Dominique Denaive is not complying with its obligations regarding your Personal Information, you may submit a complaint or request to the competent authority.

In France, the competent authority is the CNIL, to which you may submit a request electronically by clicking the following link: https://www.cnil.fr/fr/plaintes/internet.

II. COOKIE POLICY

When you first visit the Dominique Denaive Website, a banner at the bottom of the screen informs you that information about your browsing may be recorded in files called “cookies”.
This cookie policy notably informs you about all the cookies present on the Dominique Denaive Website, their purpose (Part I), and explains how to configure them (Part II).

1. GENERAL INFORMATION ABOUT COOKIES PRESENT ON THE DOMINIQUE DENAIVE WEBSITE

As the publisher of the websites mentioned in the preamble, Dominique Denaive informs you that it may place a cookie on the hard drive of your device (computer, tablet, mobile device, etc.) to ensure smooth and optimal browsing on its websites.

“Cookies” (or connection tokens) are small text files of limited size that make it possible to recognize your computer, tablet, or mobile device in order to personalize the services offered to you.

The information collected through cookies is anonymous and in no way makes it possible to identify you by name. It is used exclusively to improve the interactivity and performance of the various websites, in order to provide you with content that is most relevant to your interests.

None of this information may be disclosed to a third party without first obtaining your consent, or when disclosure of the information is required by law, for example by order of a court or any duly authorized administrative or judicial authority.

To provide you with more information about the data identified by cookies, below you will find a list detailing the different types of cookies that may be used on the Dominique Denaive Website, their names, purposes, and retention periods.

2. CONFIGURING YOUR COOKIE PREFERENCES

You can accept or refuse cookies being placed at any time
When you first visit the Dominique Denaive Website, a banner appears at the bottom of your screen. This banner informs you that by continuing to browse the Dominique Denaive Website (for example, by loading a new page or clicking various elements of the site), you agree to cookies being placed on your device. Likewise, by clicking the “X” icon on the right of the banner at the bottom of your screen, you indicate your agreement to cookies being placed.

a. Cookies exempt from consent
In accordance with the recommendations of the French Data Protection Authority (CNIL), certain cookies are exempt from the requirement to obtain your prior consent insofar as they are strictly necessary for the operation of the website or are used exclusively to enable or facilitate communication by electronic means. These include session ID, authentication, load-balancing session, and interface personalization cookies. These cookies are fully subject to this policy insofar as they are issued and managed by Dominique Denaive.

b. Cookies requiring your prior consent
This requirement concerns cookies issued by third parties that are classified as “persistent” because they remain on your device until they are deleted or reach their expiration date.
Since such cookies are issued by third parties, their use and placement are subject to their own privacy policies, a link to which you will find below. This cookie category includes audience measurement cookies, particularly Google Analytics; personalization cookies, particularly Proof and Deadline Funnel; advertising cookies, which Dominique Denaive does not use; and social media sharing cookies, particularly those from Facebook, Instagram, and YouTube.
Audience measurement cookies compile statistics concerning visits to and use of various elements of the website, such as the content/pages you have visited. This data helps improve the user-friendliness of the Dominique Denaive website.
An audience measurement tool is used by Dominique Denaive:

o Google Analytics, whose privacy policy is available at the following link : https://www.google.fr/intl/fr/policies/technologies/cookies/
Personalization cookies help improve and enhance the user experience while browsing the Dominique Denaive website:
o Proof, whose privacy policy is available at the following link: https://useproof.com/privacy
o Deadline Funnel, whose privacy policy is available at the following link: https://deadlinefunnel.com/tos
Social media sharing cookies are issued and managed by the publisher of the relevant social network. Subject to your consent, these cookies allow you to easily share some of the content published on the Dominique Denaive website, in particular via a sharing “button” provided by the relevant social network. Three types of social media sharing cookies are present on the Dominique Denaive website:
o Facebook, whose cookie policy can be viewed at the following link: https://fr-fr.facebook.com/policies/cookies/
o Instagram, whose cookie policy can be viewed by clicking the following link: https://help.instagram.com/1896641480634370/
o YouTube, whose complete cookie policy can be found at the following link: https://www.google.fr/intl/fr/policies/technologies/cookies/

C. YOU HAVE VARIOUS COOKIE CONFIGURATION TOOLS AVAILABLE

Most internet browsers are configured by default to allow cookies to be placed. Your browser gives you the option to modify these standard settings so that all cookies are systematically rejected or only some cookies are accepted or refused depending on their issuer.

WARNING: Refusing to allow cookies to be placed on your device may impair your user experience and your access to certain services or features. If applicable, Dominique Denaive accepts no liability for the consequences of degraded browsing conditions resulting from your choice to refuse, delete, or block cookies necessary for the operation of the Site. Such consequences shall not constitute damage, and you may not claim any compensation on this basis.

Your browser also allows you to delete existing cookies from your device or notify you when new cookies may be placed on your device. These settings do not affect your browsing, but they mean you will lose all the benefits provided by the cookie.
Please review below the various tools available to you so that you can configure the cookies placed on your device.

d. Configuring your internet browser
Each internet browser offers its own cookie management settings.
For further information about cookie management tools, you can visit the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

For any questions or requests for additional information regarding this Privacy Policy, you may write to Dominique Denaive at the postal address mentioned in section 1 or by completing the following contact form https://www.denaive.com/contact/