The purpose of this Privacy Policy is to enable users of the website (hereinafter referred to as "Users") to learn more about the processing of their personal Data (hereinafter referred to as "Personal Data" or "Data") that may be implemented when consulting and using the website accessible at the following URL address www.ddg.fr (hereinafter referred to as the "Site").
By using the Site, the User accepts the terms of this Privacy Policy in their entirety, and therefore agrees to the collection and use of his/her Personal Data in the manner described herein.
Any User who disagrees with any of these terms is free to stop using the Site.
Cabinet Deprez Guignot et Associés (hereinafter "DDG" or the "Firm") collects Personal Data from Users, in particular via the " contact " section and the User's subscription to the "newsletter".
Data may be collected when the User :
As the party responsible for processing the User's Personal Data, the Firm makes every effort to protect the privacy of the Site's Users, and in particular processes Personal Data in compliance with applicable laws and regulations.
Personal Data is defined as " any information relating to an identified or identifiable natural person.
An " identifiable natural person" is defined as " a natural person who can be identified, directly or indirectly, in particular 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 his or her physical, physiological, genetic, mental, economic, cultural or social identity ".
The term " Regulations " refers to the regulations relating to Personal Data, and in particular to Regulation no. 2016/679 known as the General Data Protection Regulation, the French Data Protection Act no. 78-17 of January 6, 1978, as well as Law no. 2018-493 relating to the protection of personal data.
The Personal Data collected by the Firm are :
DDG takes into account the principles of minimization and protection of Personal Data from the outset of processing, and of data protection by default. As a result, DDG only collects information that is relevant, adequate and limited to what is necessary for the purposes for which it is processed.
Certain Personal Data must be provided in order to benefit from certain functionalities on the Site (for example, the e-mail address in order to receive the newsletter). This information is indicated by a "*" sign on the data collection medium. In such cases, the User's refusal to provide such information may result in limiting access to certain services or features offered by the Firm, notably on the Site.
Apart from these cases, the User is free to provide or not all or part of his Personal Data.
It is important that the information provided and shared by the User is correct, both at the time of registration and at any time during the User's use of the Site.
Each User therefore undertakes to update the data and information concerning him or her. In this respect, he/she guarantees the truthfulness, accuracy and completeness of the information transmitted on the Site and will be solely responsible for any error, omission or failure to update.
DDG does not process any Personal Data qualified as "sensitive" (racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person) within the meaning of the Regulations.
Information communicated on the Site may be collected and processed insofar as it enables DDG to :
DDG may also use personal data for administrative purposes or for any other purpose required by law.
DDG is solely responsible for the processing of Personal Data collected within the framework of its services and on the Site, and is the sole recipient thereof.
DDG may transmit the Personal Data of users of the Site to third parties only in the cases listed below:
As soon as DDG gives access to Users' Personal Data to third parties, the latter are bound by an obligation of confidentiality. In particular, DDG requires recipients of Personal Data to undertake to comply with the Regulations.
In the event of recourse to affiliates or service providers located outside the European Union, DDG undertakes to verify that appropriate measures have been put in place to ensure that Personal Data benefit from an adequate level of protection.
DDG keeps the Personal Data communicated to it for a period of time strictly necessary to achieve the purposes for which it is to be used. The Firm may also retain such Data for a longer period in order to comply with its legal obligations.
In particular, DDG retains :
However, certain data (invoices, quotes, credit notes) may be kept for a commercially reasonable period, in particular for backup, archiving or auditing purposes.
DGG may also retain the Data for research or statistical analysis, it being specified that the Data will then be anonymized, and may thus be retained without any specific time limit.
The Firm may also retain Data for a longer period in order to comply with its legal obligations.
DDG will no longer contact Users who have not opened a newsletter for more than three (3) years.
The Personal Data processed by DDG are hosted by OVH (SAS with capital of €10,069,020, registered with the CS Lille Métropole under number 424 761 419 00045 and whose registered office is located at 2 rue Kellermann - 59100 Roubaix - France) and/or DDG's partners in order to ensure the functionality of the services, in particular for the sending and management of the newsletter.
In any event, DDG has implemented appropriate technical measures to maintain the security of Personal Data.
7.1 Rights concerned
Each User of the Site has a certain number of rights, by virtue of the Regulations in force, in particular:
Users' consent must be given clearly and unambiguously. For this reason, DDG endeavors to provide Users with concise, transparent, understandable and easily accessible information on the conditions of Personal Data processing and current practices.
Users may withdraw their consent at any time. Registered Users who no longer wish to receive communications, particularly in the form of newsletters, may unsubscribe by clicking on the link at the bottom of each e-mail sent by DDG. However, in accordance with applicable law, the withdrawal of consent is valid only for the future and does not call into question the lawfulness of the processing carried out prior to such withdrawal.
These rights allow the User to receive confirmation as to whether or not their Personal Data is being processed, and the conditions of such processing. They may also access and receive a copy of the Personal Data that DDG holds about them.
This right allows Users to request the correction of inaccurate information concerning them, by simple request to DDG, as soon as possible.
The applicable regulations provide that this right may be invoked in certain cases, in particular the following:
- the accuracy of the Personal Data is disputed;
- it can be established that the processing of the Personal Data is unlawful but the User objects to the erasure of the Personal Data and demands instead the limitation of the processing;
- when DDG no longer needs the Personal Data but they are still necessary for the User, in particular for the establishment, exercise or defense of legal claims;
- when the User objects to processing that would be based on the legitimate interests of the data controller, during verification as to whether the legitimate grounds pursued by the data controller prevail over those of the data subject.
This right allows the User to request from DDG the deletion, as soon as possible, of Personal Data, when one of the following legal grounds applies:
- The Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed;
- The consent on which the processing of the Personal Data was based is withdrawn and there is no other basis justifying such processing;
- It can be established that the Personal Data has been processed unlawfully; and
- The Personal Data must be erased by virtue of a legal obligation.
Where processing is based on consent (including contractually expressed consent), this right to portability allows the User to request to receive Personal Data provided to DDG in a structured, commonly used, machine-readable format and to transmit such Personal Data to another data controller without DDG being able to object.
Where technically possible, the User may also request that his or her Personal Data be directly transferred to another data controller by DDG.
This right of opposition allows the User to object to his or her Data being used by an organization for a specific purpose, provided that he or she specifies "the reasons relating to [his or her] particular situation".
When the processing is carried out for the purpose of commercial prospecting, the User may object to the processing at any time, without giving any reason.
However, if the User's opposition request does not concern commercial prospecting, the organization may justify its refusal on the grounds that :
- there are legitimate and compelling grounds for processing the Data, in particular if the Data is necessary for the establishment, exercise or defence of legal claims;
- the User has previously consented - the User must then withdraw that consent and not object;
- a contract binds the User with DDG;
- a legal obligation requires DDG to process the Data;
- the processing is necessary to safeguard the vital interests of the data subject or another natural person.
This right allows the User to regulate the fate of his or her Personal Data post-mortem by adopting general or specific directives, which DDG undertakes to respect. In particular, the User may decide to have his or her data passed on to his or her next of kin, or to have it deleted.
DDG may, however, even in the absence of directives, give heirs the possibility of exercising certain rights, notably the right of access, in order to enable the settlement of the deceased's estate.
If, despite the efforts made by DDG to preserve the confidentiality of Users' Personal Data, the User believes that his or her rights have not been respected, the User may at any time lodge a complaint with a supervisory authority, in particular the CNIL.
7.2 Exercise of the rights concerned
For any question relating to this Privacy Policy and/or to exercise the rights as described above, the User may at any time, and at no cost, send a request to DDG, by :
DDG undertakes to reply to the User concerned as soon as possible, and in any event within one month of receipt of the request, it being specified, however, that this period may be extended by two months in view of the complexity and number of requests sent simultaneously to DDG. In this case, DDG will inform the User of the reasons for the extension.
DDG may not act on the User's request, in particular for legal reasons. In this case, DDG undertakes to inform the User of the reasons for its inaction and of the possibility for the User to lodge a complaint with a supervisory authority, in particular the CNIL, and/or to take legal action.
DDG takes care to protect and secure Personal Data in order to ensure its confidentiality and to prevent any damage, destruction or disclosure to unauthorized third parties.
8.1. Data integrity
All Personal Data collected is stored on secure servers. Procedures have been put in place to manage any breach of personal data.
8.2. Malicious use
Without prejudice to the foregoing, in order to avoid any capture of Data by malicious third parties, independent of DDG, it is the responsibility of Users to exercise caution to prevent any unauthorized access to their personal data, and in particular to
8.3. Spoofing/ Phishing
DDG undertakes not to solicit Users by e-mail asking them to provide personal information.
The User is invited not to respond to such solicitations and to immediately forward to DDG any request that may seem suspicious.
Depending on the settings of their cookies, each User accepts that the Site may store information concerning their browsing, in order to ensure the proper functioning of the Site, to draw up traffic statistics and to optimize its conditions of use and the services offered.
9.1 What is a cookie?
A cookie is a small text file deposited on the terminal's hard disk when an Internet site is consulted. It contains some data relating to the connection, in particular the name of the server concerned, most often an identifier in the form of a unique number and, possibly, an expiry date. This identifier may enable the Site to recognize the User's computer, browser, cell phone or tablet on each visit. Cookies are managed by the User's browser.
9.2 What types of cookies are used by DDG?
Only the issuer of a cookie is likely to read or modify the information contained therein. DDG may be required, subject to Users' choices, to install various cookies on their terminal that enable it to recognize the browser of your terminal during the period of validity of the cookie concerned, in particular :
Functional cookies
They enable us to improve the quality of navigation on the Site, in particular by saving the preferences that the user has expressed during the visit to the Site (language used, display resolution, operating system).
Audience measurement cookies
These cookies are used by the Site to produce anonymous statistics. They make it possible to recognize visitors, count them and identify the way they move around the Site as they use it. This makes it possible to improve the operation of the Site and the interest and ergonomics of its services, for example by ensuring that Users can easily find what they are looking for.
Cookie enabling third parties to provide social sharing tools
Subject to acceptance by the User, when using one of the sharing buttons on the Site, a cookie may be installed by the relevant social network in order to share the content instantly on the social network. The Site does not block cookies from these third-party sites and has no control over their installation. The User is invited to consult the cookie policy of these social networks for further information.
9.3 User's choice concerning cookies
Several options are available to enable the User to manage cookies. All settings are likely to modify Internet browsing and the conditions of access to certain services requiring the use of cookies.
The registration of a cookie on a terminal is subject to the will of the User of the terminal, which can be expressed at any time and free of charge according to his navigation software.
If the User's browser software accepts the storage of cookies on his/her terminal, the cookies integrated into the pages and content consulted may be stored temporarily in a dedicated space on his/her terminal, and may be read by their issuer.
The User may choose to refuse cookies, in whole or in part.
The User may delete all cookies or only some of them. Deleting cookies does not prevent browsing or their reinstallation during browsing. Rejecting cookies allows the User to control his browser's cookie library at any given time.
Technical cookies, necessary for navigation, will be reinstalled as soon as the User returns to the Site.
It is possible that such a refusal may result in the Internet User being unable to use the Site properly, or even to benefit from a certain number of functionalities that may be necessary to navigate in certain areas of the Site. This is particularly the case when content or services require the User to identify him/herself.
Where applicable, DDG declines all responsibility for the consequences related to the degraded operation of its services resulting from the impossibility for it to record or consult the cookies necessary for their operation that the User would have refused or deleted.
However, DDG informs the User that certain cookies cannot be deleted insofar as they are strictly necessary for the technical operation of the Website.
If the User wishes to modify his cookie preferences, he may do so at any time on the Site or by configuring his browser settings:
Below, we explain how to refuse cookies, depending on your browser.
For Chrome™: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=fr
For Firefox™: https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites
For Internet Explorer™: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
For Safari™: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
Depending on these settings, browsing may be altered and access to the Site's services more or less limited. In particular, the deactivation of so-called functional cookies will alter, or even render impossible, the visit to the Site.
The procedure to follow is explained below according to the browser.
Chrome
In the Chrome menu, select "Settings"
Display the advanced settings
Go to the "Privacy" section
Click on "Content settings"
In the "Cookies" section (first section), click on "Cookies and Site data"
Find the cookies you want to delete and click on "OK". You can also choose to delete all your cookies.
Firefox
In the Firefox menu, go to "Tools" then "Options"
On the "Privacy" tab, click on "Show cookies"
Find the cookies you want to delete and click on "Delete cookies".
Internet Explorer
Internet Explorer does not allow cookies to be managed on a case-by-case basis. To delete all your cookies:
Click on "Tools", then on "Internet Options"
In the "General" tab, under "Browsing history", click on "Delete"
Tick the "Cookies" box, then click on "Delete".
Safari
In the Safari menu, select "Preferences"
In the window that opens, go to the "Security" tab
Click on "Show cookies"
In the window that opens, find and select the cookies you want to delete, and click on "Delete".
Deactivation of third-party cookies
The User may choose to deactivate third-party cookies that are not usually required to take advantage of the resources available on the Internet. The procedure for refusing third-party cookies is explained below, depending on the browser.
In Chrome:
In the Chrome menu, select "Settings"
Display the advanced settings
Go to the "Privacy" section
Click on "Content settings"
In the "Cookies" section (first paragraph), check the "Block cookies and data from third-party sites" box, and click on OK to confirm your choice.
Firefox
In the Firefox menu, go to "Tools" then "Options"
On the "Privacy" tab, set the "Retention rules" menu to "Use personalized settings for history".
Finally, uncheck the "Accept third-party cookies" box.
Internet Explorer
In the menu select Internet Options
Then in the "Privacy" tab and on the "Advanced" button, bring up the Advanced Privacy Settings window.
Then check the "Ignore automatic cookie handling" box, and select "Refuse" in the "Third-party cookies" column.
The Site is not intended for minors under the age of 16.
However, if the Site collects information on a minor under the age of 18, the minor's legal representative must give his or her prior consent and validate the communication of the data.
DDG may modify its Privacy Policy from time to time. The revised Privacy Policy will be posted on the Site by the company with the last update date.
The User is therefore required to check the Site regularly to remain informed of any changes or updates to the Firm's Privacy Policy.
Any modification will only apply to users of the Site and the Application after the said modification.
