Personal data is defined as any information relating to an identified or identifiable individual (referred to below as the "data subject"); an "identifiable individual " is one who can be identified, directly or indirectly, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

Data controller

GINETEX, within its remit and subject to the information processed and/or stored, is responsible for processing personal data pursuant to Articles 24 et seq. of Regulation No. 2016/679 on the protection of personal data.

Data collected

The personal data that we may collect when you browse the Site, use the features and services offered on the Site and/or sign up for our programmes (see the "Purposes" article for further details) is the following:
Identification data (surname, first name, title, gender, date of birth, postal address, e-mail address, telephone number, pseudonym, photograph and copy of an identity document only in certain cases to combat fraud or to verify your identity in the event of a request to exercise rights, if necessary).
Sponsorship data: information about sponsored persons, i.e. their email address.
Your requests: the content of the messages and/or requests you send us (for example, when you contact GINETEX).
Cookie data managed by Axeptio (www.axeptio.eu is published by the company Agilitation, whose registered office is at 15 rue du Général Campredon 34000 Montpellier - a simplified joint stock company with capital of €76,130.00 - Registered with the Montpellier Trade and Companies Register under no. 821947009 - APE: 5829C - Intra-Community VAT: FR62821947009 - contact: Romain Bessuges-Meusy // contact@axeptio.eu): information on your use of the Site recorded via cookies or other tracers: your IP address, Internet service provider, type of browser used, operating system, pages of the Site visited, date and time of access, or data relating to behavioural analysis of actions and choices made, statistics and data on the number of visits to the Site's pages.

Purposes

When you voluntarily provide personal data about yourself, you agree to provide accurate information that is not prejudicial to the interests or rights of third parties.
The information you provide is collected and processed for the following purposes:

1. To run our programmes (legal basis: performance of the agreement/legitimate interest)
- Delivering programmes to programme members,
- Developing our consumer/customer knowledge and establishing statistics and performance of the Programme,

2. Canvassing and/or personalisation (legal basis: subject to obtaining your consent)
- Allowing your company logo to be published within the framework of the Clevercare.info ambassador programme

3. Processing your requests (legal basis: performance of the agreement/legitimate interest)
- Responding to your requests, in particular via the contact form, dedicated email addresses or social media,
- Processing and responding to your requests relating to the exercise of the rights granted to you pursuant to the applicable regulations on the protection of personal data,

4. Prevention of fraud, maintenance and security (legal basis: performance of the agreement/legitimate interest)
- Combatting fraud, i.e. to verify the information provided in the event of suspected fraud, to prevent fraudulent activities, unauthorised access to the Site and other illegal activities,
- Maintaining and protecting the security of the Site,
Lastly, we use cookies and other tracers to enable you to access the Site and its functionalities, to compile statistics on Site activity to measure satisfaction and the quality of services, and to improve and optimise the Site.

Legal basis for processing

The legal basis for processing is the performance of the agreement, your consent and/or our legitimate interests.
You can send us a request to obtain further information on the checks we have carried out to ensure that we are able to process your personal data.
The fields marked with an asterisk on the agreement and registration forms on the Site must be completed for us to process and respond to your request. If you fail to provide this information, we will not be able to process or respond to your request.

Transfer of Data outside the European Union

The protection of your personal data is important to us.
In this respect, we do everything possible to avoid transferring your personal data to a country outside the EU. However, where a transfer to a country outside the EU is necessary, we ensure that your personal data is protected and transferred under optimum conditions of security, pursuant to the applicable laws. To this end, we ensure, for example, that this transfer is made to countries recognised as providing an adequate level of protection for your personal data or that the recipient of your personal data has signed an agreement incorporating the "Standard Contractual Clauses" approved by the European Commission imposing an obligation of strict protection of your personal data. We will also take the necessary technical and organisational measures to protect your personal data to ensure a level of protection equivalent to that of the country of origin.
You can contact us for more information on how your personal data is protected in the event of a transfer outside the EU.

Data retention period

We will retain your personal data pursuant to applicable legal data retention requirements and our internal policies. Data retention will vary depending on the type of data and the purposes of processing.
In this respect:
- Personal data collected for the purposes of commercial canvassing is kept in an active database for a period of three (3) years from your last contact with us or your last activity, unless you have exercised your right to withdraw consent, your right to object or your right to erasure. It is then archived pursuant to provisions in force, in particular those set out in the French Commercial Code, the French Civil Code and the French Consumer Code.
- If your account is inactive or if you do not contact us for three (3) years, your personal data will be deleted from the active database and then archived pursuant to provisions in force, in particular those set out in the French Commercial Code, the French Civil Code and the French Consumer Code.
- Archiving: only the history of your actions (logs) will be archived for the purposes of managing any disputes for five (5) years after you unsubscribe or request the deletion of your data, or two (2) years after the deletion of your account due to inactivity or lack of contact on your part.
- Any copies of your identity document are kept only for the time required to confirm your identity, in the event of suspected fraud, for a maximum period of 60 days, after which they will be destroyed. In the event of proven fraud, they may nevertheless be kept for the time required to manage any disputes relating to such fraud.
At the end of the interim storage period, your personal data will be permanently deleted. We may also permanently anonymise personal data for research and statistical purposes.

Data recipients

The recipient of the data collected is GINETEX and, as applicable, if you have given your consent to receive commercial canvassing, our partners.
We may also pass your personal data on to third parties, but only in the following cases:
- When you have given us your prior consent to share this information,
- In the event of a merger, acquisition or sale of all or part of the assets of data controllers, to the successors in title of the entity,
- When we need to share this information with our providers and, inter alia, our technical service providers to ensure the technical maintenance of the Site or our personal data processing software, for the hosting, backup, administration or processing of the data and/or our emails. Such third parties will only have access to personal data to the extent necessary to ensure the smooth and/or secure technical processing of the Site, and to ensure the provision of responses to requests made via the contact form. In all cases, such access to your data will only be pursuant to with applicable law, including Data confidentiality, privacy and security obligations,
- When we subcontract certain services, in particular within the framework of managing our customer service, managing your requests to exercise your rights or organising or managing events,
- When we use third parties to study and measure the performance of our programmes,
- When required by law, when we receive a request from the courts, an administrative authority, governmental authorities or any administrative authority authorised by law requesting the disclosure of this information in accordance with laws in force.

Description of your rights

Pursuant to applicable regulations, you may exercise the rights listed below with regard to the personal data we hold about you.


1. Information rights
You have the right to clear, transparent, understandable and easily accessible information about how we use your personal data and about your rights. This is why we provide you with the information in this policy.

2. Right of access to your personal data
You can access all the personal data we hold about you, find out the provenance of this personal data comes from and obtain a copy of it in an understandable format.
You may also exercise your right of access to your personal data to check its accuracy and have it corrected or deleted. You are not required to give grounds to exercise your right of access.

3. Right to rectify your personal data
To prevent inaccurate or incomplete personal data concerning you from being processed or disseminated, you may ask us to rectify it.

4. Right to deletion of your personal data
You may request the erasure or deletion of personal data held by us. This is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:
- if you have withdrawn your consent to processing,
- if you have validly objected to the processing of your data,
- when the data is no longer necessary for the purposes for which it was originally collected or processed,
- if the data is processed unlawfully (e.g. publication of pirated data),

5. Right to object to the processing of your personal data
When we process your Personal Data on the basis of our legitimate interests, you may object at any time to the processing of your Personal Data on grounds relating to your particular situation. We may nevertheless, on a case-by-case basis, refuse to comply with such a request on the grounds that there are compelling legitimate grounds for processing such data which override your interests, rights and freedoms, or where such data is necessary for the establishment, exercise or defence of legal claims.

6. Right to object to commercial canvassing
You can unsubscribe or object, at any time and without giving reasons, to receiving commercial canvassing messages and, inter alia, from our clevercare.info ambassador programme by contacting GINETEX at the following address: ginetex@ginetex.net.

7. Right to restrict the processing of your personal data:
The right to limitation is in addition to any other rights you may have. This right means that our processing of your data is restricted, so we can keep the data but may not use it or process it in any other way. This right applies in specific circumstances:
- if you dispute the accuracy of your personal data. In this case, processing will be restricted for a period that allows us to verify the accuracy of the personal data,
- where the processing is unlawful and you object to the erasure of your personal data and request instead that its use be restricted,
- where we no longer need the personal data for the purposes mentioned above, but the data is still required for the establishment, exercise or defence of legal claims,
- where you have objected to processing based on the legitimate interests pursued by the Data Controllers, you may request that the processing be restricted for the time necessary to determine whether we can comply with your objection (i.e. the period necessary to verify whether or not the legitimate interests we are pursuing prevail over yours).

8. Right to the portability of your personal data
You may request to recover the personal data you have provided to us, in a structured, commonly used and in a machine-readable format, for your personal use or for disclosure to a third party of your choice.
This right applies only to personal data that you have provided to us directly or indirectly and that has been processed using automated processes, where the processing is based on your consent or the performance of an agreement. We invite you to consult the list of legal bases for our processing of personal data to find out whether our processing is based on the performance of an agreement or on consent.

9. Right to withdraw your consent at any time to the processing of personal data carried out on the basis of that consent
Please consult the dedicated section of this policy to identify the purposes for which the processing of your personal data is based on your consent.

10. Right to give instructions on the fate of your personal data after your death
You may give instructions concerning the retention, deletion and disclosure of your personal data after your death. These instructions may be general, i.e. concerning all your personal data, or specific, i.e. concerning only certain processing operations.
If you wish to exercise any of the above rights, please contact us at the following address: ginetex@ginetex.net
If we have reasonable doubts about your identity, we may ask you to enclose any document that proves your identity, to prevent identity theft.
If your request is sent to us electronically, we will also reply electronically unless you specify that you would like a reply by another means, for example by post.
We will reply as soon as possible, and in any event within one month of receiving your request. This period may be extended by two months depending on the complexity of the request or the number of requests received. In such a case, we will inform you no later than one month after receiving your request, specifying the reasons for the extended response time.

Right to appeal

If you feel we are in breach of this Policy, if you are not satisfied with the way we have handled your request or if your request has been refused, you may also file a formal complaint with your competent data protection authority (in France, this is the Commission Nationale de l'Informatique et des Libertés (CNIL): CNIL official website). https://www.cnil.fr/
Please contact us using the methods set out in the contact section below before filing a complaint with the competent data protection authority.

Our programmes are not available to minors.

We may amend this Privacy Policy from time to time. If we wish to use your personal data in a manner different from that provided for in the Privacy Policy in force at the time of collection, these changes will be notified visibly on the Site, and in the event of a substantial change or a particular event you will also be notified by email if you have signed up to the Newsletter and/or have a user account.

If you have any questions about this Privacy Policy, please contact us at the following address: ginetex@ginetex.net.