ARTICLE 1: PREAMBLE
• How their personal data is collected and processed. All data that can identify a user must be considered as personal data. This includes the first and last name, postal address, e-mail address, or IP address.
• What are the rights of the users regarding this data?
• Who is responsible for processing the personal data collected and processed?
• To whom this data is transmitted.
• Eventually, the site’s policy regarding “cookies” files.
ARTICLE 2: GENERAL PRINCIPLES ON DATA COLLECTION AND PROCESSING
In accordance with the provisions of Article 5 of the European Regulation 2016/679, the collection and processing of data of the users of the site respect the following principles:
• Legality, fairness, and transparency: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his/her data is being collected and for what purpose his/her data is being collected.
• Minimization of data collection and processing: only the data necessary for the proper execution of the objectives pursued by the site are collected.
• Conservation of data reduced in time: the data is kept for a limited period of time, of which the user is informed. Where this information cannot be provided, the user is informed of the criteria used to determine the retention period.
• Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.
To be lawful, and in accordance with the requirements of Article 6 of the European Regulation 2016/679, the collection and processing of personal data may only take place if it complies with at least one of the conditions listed below:
• The user has expressly consented to the processing.
• The processing is necessary for the proper performance of a contract.
• The processing is in response to a legal obligation.
• The processing is necessary to protect the vital interests of the data subject or of another natural person.
• The processing may be necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• The processing and collection of personal data is necessary for the legitimate and private interests pursued by the controller or by a third party.
ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED WHEN BROWSING THE SITE
A. DATA COLLECTED AND PROCESSED AND METHOD OF COLLECTION
When the user writes a comment via the contact form, the personal data collected on the Novolyze website are the following:
• Last name, first name, email, company, position, country, phone and free comment
When the user subscribes to the newsletter, the personal data collected on the Novolyze website are the following:
• Last name, first name, email, company, area of interest
When the user downloads documents shared by Novolyze, the personal data collected on the Novolyze website are the following:
• Last name First name, email, phone, company, type of company, position, city state, province, country, postal code.
When the user registers or connects to the private part of the website, the personal data collected on the Novolyze website are the following:
• Last name, First name, e-mail, type of company, position, address, country, language
When the user uses the website chat, the personal data collected on the Novolyze website are the following:
• Last name, First name, email, conversation
The data controller will keep in its computer systems of the site and in reasonable security conditions all the data collected for a period of 5 years.
The collection and processing of data is for the following purposes:
Any information collected on the website is done so for the purpose of using our platform.
The data processing carried out is based on the following legal grounds:
The user’s consent
B. TRANSMISSION OF DATA TO THIRD PARTIES
The personal data collected by the site are not transmitted to any third party and are only processed by the site editor.
C. DATA HOSTING
The Novolyze website is hosted by:
Microsoft France SAS
39 quai du Président Roosevelt
92130 Issy Les Moulineaux
Tel 09 70 01 90 90
VAT NUMBER: FR95327733184
The data collected and processed by the site may be transferred to the following country: United States of America. This transfer of personal data outside the European Union is justified by the following reasons:
• Subsidiary present in the United States of America.
ARTICLE 4: DATA CONTROLLER
A. THE DATA CONTROLLER
The person in charge of processing personal data is Novolyze SAS, represented by its legal manager Karim-Franck Khinouche. He can be contacted as follows:
By phone: +33 (0)9 83 69 42 13, by email: firstname.lastname@example.org
The data controller is responsible for determining the purposes and means of processing personal data.
B. OBLIGATIONS OF THE DATA CONTROLLER
The data controller undertakes to protect the personal data collected, not to transmit them to third parties without the user’s knowledge and to respect the purposes for which the data were collected.
Furthermore, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this would entail disproportionate formalities, costs and steps for him.
In the event that the integrity, confidentiality or security of the user’s personal data is compromised, the data controller undertakes to inform the user by any means.
ARTICLE 5: USER’S RIGHTS
In accordance with the regulations concerning the processing of personal data, the user has the following rights
In order that the data controller to comply with the request, the user is required to provide the following information: first and last name, e-mail address and, if relevant, account number or personal or subscriber number.
The data controller is obliged to respond to the user within a maximum of 30 (thirty) days.
A. PRESENTATION OF THE USER’S RIGHTS REGARDING DATACOLLECTION AND PROCESSING
a. Right of access, rectification, and deletion
The user may view, update, modify or request the deletion of data concerning him/her, by following the procedure set out below:
Send an email to email@example.com
If he/she has one, the user has the right to request the deletion of his/her personal space by following the procedure below:
Send an email to firstname.lastname@example.org
b. Right to data portability
The user has the right to request the portability of his personal data, held by the site, to another site, by complying with the following procedure:
Send an email to email@example.com
c. Right to limit and object to the processing of data
The user has the right to request the limitation of or to oppose the processing of his/her data by the site, without the site being able to refuse, except in the case of demonstrating the existence of legitimate and compelling reasons, which may prevail over the interests and rights and freedoms of the user.
To request the limitation of the processing of his/her data or to formulate an objection to the processing of his/her data, the user must follow the following procedure:
Send an email to firstname.lastname@example.org
d. Right not to be subjected to a decision based exclusively on an automated process
In accordance with the provisions of Regulation 2016/679, the user has the right to not be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him or her, or significantly affects him or her in a similar way.
e. Right to determine the fate of data after death
The user is reminded that he/she can organize what should be the fate of his/her collected and processed data if he/she dies, in accordance with the law n°2016-1321 of 7 October 2016.
f. Right to refer to the competent supervisory authority
In the event that the data controller decides not to respond to the user’s request, and the user wishes to contest this decision, or if he/she believes that one of the rights listed above has been infringed, he/she is entitled to refer the matter to the CNIL (Commission Nationale de l’Informatique et des Libertés, https://www.cnil.fr) or to any competent judge.
B. PERSONAL DATA OF MINORS
In accordance with the provisions of Article 8 of the European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.
If the user is a minor under the age of 15, the consent of a legal representative will be required in order that personal data to be collected and processed.
The site editor reserves the right to verify by any means that the user is over 15 years of age, or that he has obtained the agreement of a legal representative before browsing the site.
ARTICLE 6: USE OF “COOKIES” FILES
The site may use “cookie” techniques.
A “cookie” is a small file (less than 4 kb), stored by the site on the user’s hard drive, containing information about the user’s browsing habits.
These files allow us to process statistics and information on traffic, to facilitate navigation and to improve the service for the user’s comfort.
For the use of “cookies” files involving the storage and analysis of personal data, the user’s consent is necessarily requested.
This consent of the user is considered valid for a maximum period of 6 (six) months. At the end of this period, the site will again request the user’s permission to save “cookies” files on his or her hard drive.
a. Opposition of the user to the use of “cookies” files by the site
Cookies that are not essential to the operation of the site are only deposited on the user’s terminal after obtaining his consent. The user can withdraw his consent at any time by following the link on the page footer of the site.
More generally, the user is informed that he/she can oppose the recording of these “cookies” by configuring his/her browser.
For information, the user can find at the following addresses the steps to follow in order to configure his navigation software to oppose the recording of “cookies” files:
• Chrome: https://support.google.com/accounts/answer/61416?hl=fr
• Firefox : https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences
• Safari: http://www.apple.com/legal/privacy/fr-ww/
• Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• Opera: http://www.opera.com/help/tutorials/security/cookies/
In the event that the user decides to deactivate the “cookies” files, he/she will be able to continue browsing the site. However, any malfunctioning of the site caused by this manipulation could not be considered as being due to the site editor.
b. Description of the “cookies” files used by the site
The site editor draws the user’s attention to the fact that the following cookies may be used during navigation:
– cookies that manage the consenting cookies
– cookies for authentication and security services (robot access)
– cookies that customize the user interface (languages, etc…)
– audience measurement cookies
– cookies related to advertising displayed or not
– cookies related to sharing on social networks
The site editor reserves the right to modify it in order to ensure its conformity with the law in force.