Privacy policy

Last updated on February 8, 2021

Preamble

The purpose of this document is to define the policy for the protection of personal data and the use of cookies in compliance with the Personal Data Regulations of EDISOUND (RCS Nanterre 893 537 589), whose registered office is located at 8 rue Barthélémy Danjou - 92100 Boulogne Billancourt.

EDISOUND is the publisher of content, products and services available on various physical and digital media. This includes websites (hereinafter referred to as the "Sites") and their mobile versions, official social networks, themed newsletters, magazines, competitions, commercial prospecting and targeted advertising campaigns by electronic means (e-mail, SMS, MMS) and any other existing or future medium (hereinafter referred to as the "Media").

EDISOUND collects Personal Data on its own behalf, as part of its business and is as such, a Data Controller within the meaning of EU Regulation 2016/679 of April 27, 2016 and Law No. 78-17 of January 6, 1978 as amended relating to information technology, files and freedoms known as the "Loi Informatique et Libertés") hereinafter referred to as the "Personal Data Regulations".

When EDISOUND collects Personal Data on the Media on behalf of third parties, it acts as a processor within the meaning of the aforementioned Regulations.

EDISOUND takes the protection of Personal Data very seriously. The present document informs you and specifies the procedures for collecting Personal Data in accordance with the Personal Data Regulations.

EDISOUND reserves the right to modify the provisions of the present document at any time and without prior notice, in particular to comply with any regulatory, editorial or technical developments. Modifications come into force and become enforceable on the date of their publication on the Supports.

1. Definitions

The terms defined below have the following meanings.

Personal Data: Any information relating to an identified or identifiable natural person, directly or indirectly (e.g. surnames, first names, identifiers, e-mail address, location data, etc.) is personal data (hereinafter "Personal Data(s)").

User Account: A "User Account" is the space reserved for and accessible by entering information in a form on a Site.

Content: Refers to any information published on EDISOUND's Media, i.e. texts, images, photos, videos, excluding content published by the User him/herself when he/she is given the opportunity to contribute in the form of a comment or share on the Sites, their mobile version and official social network, the latter remaining the sole responsibility of the User.

Minor: A "minor" is defined as a child under the age of fifteen (15) within the meaning of article 45 of law no. 78-17 of January 6, 1978, as amended.

Data controller: Refers to the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of processing.

Services: By "Services" we mean the provision by EDISOUND of Content on the media offered on the Sites and paper media such as newsletters, competitions, loyalty programs, without this list being limitative, to users.

Sites: On entend par " Sites ", tout service de communication au public en ligne édités par EDISOUND.

Medium: "Medium" means any means of collecting Personal Data made available by EDISOUND in paper and/or digital format.

User: by "User" we mean any natural person, customer, prospect or simple Internet user who uses EDISOUND's Services.

2. The Personal Data we collect

What Personal Data do we collect directly from you?

EDISOUND collects Personal Data when you register for Services on its Sites, on its mobile applications, by telephone or when you subscribe or participate in a marketing operation (game, study, survey, contest), regardless of the medium.
Before collecting your Personal Data, EDISOUND informs you of the mandatory or optional nature of the data to be filled in on its digital or paper forms.

The data collected directly includes :

- Your identification data (surname, first name, date of birth, gender, pseudonym, connection identifier, age, customer number, etc.);

- Contact data (postal address, telephone number, e-mail address);

- Your bank details (credit card number, expiry date, cryptogram, transaction number, purchase details);

- Data relating to your habits and/or preferences;

- Data relating to the organization and processing of contests, or any other promotional offer

promotional offers enabling you to receive our communications by filling in the

contact forms (date of participation, answers given, nature of prizes won);

- Your contributions and comments.

Where the Service requires consent, information relating to the Minor may only be provided by the latter only with the consent of the persons holding parental authority (see article 9 below).

Pursuant to Law No. 2014-344 of March 17, 2014, you can oppose telephone canvassing by registering on the "Bloctel" national opposition list: https://conso.bloctel.fr.

What Personal Data do we collect indirectly from you?

Indirectly collected data includes :

- Data from cookies and other tracking devices. For more information, please refer to article 6 of this document;

- Data relating to interaction between you and EDISOUND: subscription to our newsletter mailing list, clicks on links inserted in newsletters sent to us to enable us to adapt our exchanges with you;

- Browsing data: connection data (date, time, duration of connection, browser type, IP address, etc.);

- Geolocation data when you activate the systems provided for this purpose on mobile applications;

- The URL address of the web page consulted;

- The operating system and configuration of your terminal.

EDISOUND ensures that only the Personal Data necessary for the provision of our Services is collected and processed from the persons concerned, in particular when subscribing to a subscription, registering for a communication campaign or during sales promotions.

Who has access to your Personal Data?

In particular, the following may have access to your Personal Data:

- The publisher of the Services, in its capacity as Data Controller;

- Certain employees of EDISOUND for the management of the Services;

- Business partners, mainly marketing and advertising agencies (any entity that has entered into a contract governing the provision of data and presenting sufficient technical and organizational protection measures);

- Subcontractors used by EDISOUND, in particular for the following operations:

o Secure payment on the Sites;

o Shipment of your orders;

o Managing incoming and outgoing calls and sending postal mail;

o maintenance and technical development of Internet infrastructures;

o Sending emails and mobile notifications for commercial prospecting;

How do we use your Personal Data?

EDISOUND is authorized to use Personal Data only if it has a valid legal basis. As a customer, prospect or simple User of our Services, EDISOUND collects your Personal Data on the basis of several legal grounds: the execution of a contract (such as the processing and execution of orders); the execution of a legal obligation (such as the retention of invoices, purchase orders); the expression of your express and prior consent or possibly according to our legitimate interest as a magazine publisher.

In particular, your Personal Data may be processed for the following purposes:

- taking out a subscription to one of EDISOUND's services in order to manage your subscription (renewal, unsubscription, cancellation...), ordering, delivery, payment transactions;

- the creation of a User Account on one of the EDISOUND Sites in order to access the various Services;

- subscription to newsletters or marketing communications (telephone, e-mail) or, where applicable, those of EDISOUND's commercial partners;

- participation in competitions/advertisements organized by EDISOUND;

- participation in surveys organized by EDISOUND or to test products offered to subscribers and/or prospects;

- the collection of your Personal Data to send you targeted advertising;

- audience measurement and statistical studies of the visibility of our Sites

- statistics, analysis and segmentation of customers and prospects to improve our Services;

- tools to measure the visibility and traffic of our Sites and mobile applications;

- sharing information with our commercial partners;

- access to our premises;

- video surveillance on our premises...

EDISOUND collects this data in compliance with its appropriateness and relevance, and in strict compliance with the purposes for which this Personal Data is processed.

the purposes for which the Personal Data is processed.

Under no circumstances will your Personal Data be further processed in a manner incompatible with these purposes, except with your prior and express consent.

In accordance with the Personal Data Regulations, it is in EDISOUND's legitimate interest to carry out commercial canvassing by e-mail concerning a product or service similar to that previously provided to the User, provided that this canvassing is not of a commercial nature.

Similarly, your consent will not be required for telephone or postal canvassing once your Personal Data has been transmitted to EDISOUND.

In both these situations, you may at any time exercise your rights as detailed in article 8 below.

3. To whom are your Personal Data transmitted?

Personal data is intended for EDISOUND.

However, it may be transmitted to third parties:

- EDISOUND's commercial partners, with your consent (advertisers, agencies, advertising agencies, etc.);
- To sub-contractors appointed by EDISOUND (statistical studies, data analysis, processing of mailing campaigns, management of information flows from our subscriptions, re-subscription, payments, outstanding debts, etc.);
- Your Personal Data may be transmitted to the competent authorities upon request;
- In the event of restructuring of EDISOUND (sale, transfer, merger, etc.).

In addition, EDISOUND may use and share certain non-personal technical or aggregated data concerning you, in particular navigation data, on the understanding that such non-personal data does not allow the persons concerned to be identified.

4. Is your data transferred outside the European Union?

As a matter of principle, Personal Data is only hosted within the European Union and is not transferred outside this territory.

Some of EDISOUND's partners may be located or process Personal Data outside the European Union. Personal Data may therefore be transferred to countries outside the European Union, whose legislation on the protection of personal data differs from that of the European Union. In such cases, EDISOUND will take all necessary steps to ensure the security and confidentiality of such data, and will ensure that any such transfer complies with the applicable legal framework.

In this respect, EDISOUND strictly requires its partners to use Personal Data only to manage or provide the requested services. EDISOUND also asks its partners to always act in compliance with applicable laws on the protection of personal data and to pay particular attention to the confidentiality of such data.

5. Policy on the use of cookies and other tracking devices

This policy on the use of cookies and other tracking devices applies to all websites and mobile applications published by EDISOUND.
EDISOUND.This usage policy explains how cookies and other trackers (hereinafter "Cookies") are used on digital media and how you can control their use.
By using digital media, you agree that this policy applies to you.

A. What is a Cookie?

A Cookie is a text file that may be saved, subject to your choices, in a dedicated space on the hard disk of your terminal (computer, smartphone, tablet, etc.) when you consult the Website using your browser software. It is transmitted by the website server to your browser. Its purpose is to collect information relating to your browsing and to send you specialized information or services in return.

When using a digital medium, you will be informed of the various cookies and their associated purposes, and your consent will be sought via our Consent Management Platform (CMP). Subject to your choice, cookies will be stored in the memory of your computer, smartphone, tablet, cell phone, etc. The information collected in this way may be used for other purposes. The information collected in this way may be used by EDISOUND or by a third party, such as an advertising agency or any other partner. The cookie is valid for a maximum of 13 (thirteen) months from the date on which you gave your consent to the integration of the cookie.

You can delete them at any time in your browser settings. There are several types of Cookies and different ways of objecting to them (see point B. of this article). You have the option of refusing the recording of Cookies on your device and you can do so at any time via your browser software, according to the procedure described in point C. of the present article.

However, the refusal of certain Cookies may lead to the degradation of a certain number of functions necessary for browsing the Sites (recording or display difficulties, etc.). EDISOUND cannot be held responsible for such malfunctions.

In addition, deactivating advertising cookies does not mean that you will not receive advertising, but simply that it will no longer be adapted to your interests.

B. The different types of Cookies present on digital media :

Functional cookies: These cookies enable us to recognize you when you use and return to the Site, by storing the various choices you made during your last visit to the Site. They enable us to offer you these choices again to personalize your experience, simplifying and facilitating your browsing.

Audience/statistical cookies: These cookies enable us to record certain connection data for the purpose of analyzing and quantifying the number of visitors to our digital media, and then to draw up qualitative studies aimed at improving the presentation of the website and the information disseminated about our products and services. These cookies are used to optimize our digital media.

You can refuse the use and deposition of these Cookies on your device by going to :

- Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=fr

- AT Internet: http://www.atinternet.com/politique-du-respect-de-la-vie-privee/

- Dynatrace: https://www.dynatrace.com/company/trust-center/cookie-policy/

Browsing cookies: This type of cookie enables you to browse digital media and use their various functions. This type of Cookies is necessary to ensure your identification and access to your account on the Website. Without these Cookies, the digital media would not function properly and you would not be able to use all or part of the Website's functionalities.

Advertising cookies: These are cookies used to send you targeted advertising. These cookies make it possible to identify the pages and sites you visit while browsing the digital medium, as well as other websites and services offered by third parties on which we issue cookies. Your browsing profile does not contain any personal information (such as your name, for example). By establishing your browsing profile, we are able to optimize the relevance of advertising banners compared with advertising served in the standard way.

We remind you that disabling advertising cookies by adjusting your browser settings does not mean that you will not receive advertising, but simply that it will no longer be tailored to your interests.

Specificity applicable to mobile terminals and applications:

For mobiles running Android OS and Apple IOS:
Sync technology is based on the display of Content when the mobile detects a relevant audio track. It thus enables contextual elements, advertising or Content to be proposed to the user on his mobile application when he is watching television. The aim is to make advertising less intrusive, as it is contextual and informative. When the microphone is switched on, all processing is carried out locally, using coded and compressed 500-millisecond chunks of sound. Sync therefore transmits no sound outside the mobile application. These 1/2-second chunks of sound never leave the device. The method used ensures absolute confidentiality. Sync2AD uses the AID as its sole reference. This is a virtual number created by Google Android for this purpose. No personal information is transmitted.

Third-party advertising cookies: These are cookies placed by advertisers on digital media. They are used by third-party advertisers and/or their agencies (partners) to send you targeted advertising. These cookies make it possible to identify the pages and sites you visit while browsing digital media. You can express your choice on the use of these Cookies by configuring your browser via CMP. The list of partners is accessible via CMP.

You can also visit the websites of the main advertising networks

You can then choose to accept or refuse advertising cookies from each advertising network.

- http://www.networkadvertising.org/choices/ (NAI)

- http://www.youronlinechoices.com/fr/controler-ses-cookies/ (EIDAA),

Social network cookies: We use third-party software modules to enable you to share Content on digital media with others via "social network sharing buttons". If you are connected to the social network in question at the time you are browsing the digital media, the application buttons may make it possible to link the pages consulted to your user account, and in any case, to transmit your Personal Data to this social network. As soon as you click on the social network, your browsing on the digital medium will enable the latter to collect your Personal Data directly on its server.

If you do not wish the social network to link the information collected via the Site to your user account, you may disconnect from the social network before visiting the Site.

We invite you to consult the privacy protection policies of the social networks in order to learn about the purposes for which they may use the browsing information they may collect through these application buttons, and in particular for advertising purposes:

For Facebook: http://www.facebook.com/about/privacy/

For Twitter: https://twitter.com/privacy

For Linkedin: http://fr.linkedin.com/legal/cookie-policy

For Google: http://www.google.com/intl/en/policies/privacy/

For Pinterest: https://about.pinterest.com/it/privacy-policy

Microphone Data: Data collected via microphones refers to Data that EDISOUND collects directly or indirectly via the microphones on the mobile terminal. This Data is collected by EDISOUND's partner(s) for the purpose of displaying targeted advertisements on the mobile terminal according to the sounds coming from the audiovisual media near the Internet user.

Internet users who have given their consent to the collection of Data via the microphone may withdraw this consent at any time by going to the settings and/or parameters of their mobile terminal.

Geolocation data: Geolocation data refers to data collected via Software Development Kit (SDK) by EDISOUND's partner(s), when the Internet user activates geolocation systems on his/her mobile terminal, and subject to his/her prior and express agreement. These geolocation services use data such as GPS signals, terminal sensors, WIFI access points, advertising identifiers and base station identifiers to derive or estimate the precise position of the User's mobile terminal. This data is collected for commercial and/or marketing analyses based on terminal geolocation, and for profiling and geo-targeted advertising purposes.

Internet users who have given their consent to the collection of geolocation data may withdraw this consent at any time by going to the settings and/or parameters of their mobile terminal.

C. Browser settings

To manage cookies and your choices, the configuration of each browser is different. It is described in your browser's help menus, which will enable you to modify your cookie preferences.

This menu tells you which cookies are stored on your device and asks you :

- whether or not to accept them,

- accept or refuse them on a case-by-case basis,

- to refuse them systematically.

To set your cookie preferences, please follow the link for your browser:

For Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

For Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

For Microsoft Edge: https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

For Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

For Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

For Safari: http://support.apple.com/kb/PH5042

"Adobe Flash Player"™ is a computer application that enables the rapid development of dynamic content using the "Flash" computer language. Flash (and similar applications) memorizes the settings, preferences and use of these contents thanks to a technology similar to Cookies. However, "Adobe Flash Player"™ manages this information and your choices via an interface different from that provided by your browser software.

Insofar as your device is likely to view content developed with Flash language, we invite you to access your Flash Cookie management tools, directly from http://www.adobe.com/fr/.

D. More information about Cookies

https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser

6. How long do you keep your Personal Data?

The length of time we keep your Personal Data varies according to the purpose of the processing (article 3 of this document). Except in the case of mandatory legal provisions, your Personal Data is kept only as long as is necessary for the proper fulfillment of the purpose for which it was collected, through our contractual relationship and the management of your commercial relationship.

The Personal Data of prospective customers is kept for the period of use of the Services and deleted three (3) years after the last contact with the prospective customer, unless the latter agrees to continue to receive commercial solicitations.

However, EDISOUND reserves the right to archive or anonymize your Personal Data, depending on the purposes for which it is to be used.

Information stored in the terminal (e.g. cookies), or any other element used to identify and enable traceability, as well as raw attendance data associating an identifier, will not be kept beyond thirteen (13) months.

7. What are your rights? How can you exercise your rights?

Your rights

You have the right to withdraw your consent at any time, the right of access, rectification and deletion, the right to restrict processing, the right to portability, the right to object, and the right to define directives concerning the fate of your Personal Data in the event of your death, by proving your identity by any means. You may, for legitimate reasons, object to the processing of such data.

Right of access : the right of access enables you to find out whether data concerning you is being processed, and to obtain communication and a copy of it in a comprehensible format. This right also enables you to check the accuracy of your data and, if necessary, have it corrected or deleted.

Right of rectification : This right allows you to correct inaccurate or incomplete information about yourself (age, address) in connection with the purpose of the processing. This right prevents EDISOUND from using or distributing incorrect information about you.

Right to erasure ("right to be forgotten"): the right to erasure consists of asking the Data Controller to delete your personal data. You can exercise this right when one of the following grounds applies (Article 17 RGPD):

- Your Personal Data is used for prospecting purposes;

- Your Personal Data is not or is no longer necessary for the purposes for which it was originally collected or processed;

- You withdraw your consent to the use of your Personal Data;

- Your Personal Data has been processed unlawfully (e.g. publication of pirated data);

- Your Personal Data was collected when you were a minor in the context of the information society (blog, forum, social network, website, etc.);

- Your Personal Data must be deleted to comply with a legal obligation;

- You have objected to the processing of your Personal Data and the file manager has no legitimate or compelling reason not to comply with this request.

Right to limit processing: the right to restrict processing allows the Data Controller to verify or examine your request for a certain period of time. During this period, your Personal Data will be frozen and the Data Controller will no longer have to use this Personal Data, but will retain it.

Right to portability : this right offers data subjects the possibility of recovering part of their Personal Data in an open, machine-readable format. Data subjects can thus easily store or transmit data from one information system to another in order to:

- Recover their Personal Data for personal use;

- Ensure their re-use for re-use by another organization.

Right to object : Any person may object, for legitimate reasons of their own, to being included in a file, and may refuse, without having to justify themselves, to have their Personal Data used for commercial prospecting purposes. When exercising this right, you must indicate that you are exercising your right for "reasons relating to your particular situation", except in the case of commercial prospecting, to which you may object without giving any reason.

To exercise your right to object and unsubscribe from our communications, you can use the unsubscribe links on each of our communications, which allow you to unsubscribe from a particular communication or from all of our communications.

The possibility of organizing the fate of personal data after death: individuals may give instructions concerning the retention, deletion and communication of their Personal Data after their death. A person may be appointed to carry out these instructions when the person concerned has died.

Exercise your rights and contact details of our Data Protection Officer

In accordance with Regulation (EU) 2016/679, known as the General Data Protection Regulation (GDPR), and Law No. 78-17 of January 6, 1978, as amended, on data processing, data files and individual liberties (hereinafter the "Data Processing and Individual Liberties" law), you may exercise your rights by contacting our Data Protection Officer, Magellan Consulting:

Either by post to the following address

EDISOUND

customer relations department / exercising your rights

8 rue Barthélémy Danjou

92100 Boulogne Billancourt

Or by e-mail: [email protected]

The information collected by our Data Protection Officer contains Personal Data within the meaning of the French Data Protection Act. It is intended for use by EDISOUND to process requests from the persons concerned and to communicate with them. The information collected may be transmitted to EDISOUND's partners for the purpose of processing your request. This information is confidential and kept by EDISOUND, its subsidiaries or partners.

Subject to the limitations provided for by the regulations in force, you may exercise your rights at any time and free of charge.

Where the request is admissible, well-founded and non-excessive, EDISOUND undertakes to grant the request within two (2) months of receipt of the request.

Where the request is inadmissible, manifestly unfounded or excessive, in particular due to its repetitive nature, EDISOUND reserves the right to refuse to grant the person's request.

Pursuant to Decree no. 2019-536 of May 29, 2019, any request to exercise one of your rights with EDISOUND in its capacity as Data Controller must be made in writing, dated and signed. The request must specify the address to which the reply should be sent.

In the event of serious doubt as to the identity of the person making a request, EDISOUND reserves the right to request additional information, such as a photocopy of an identity document bearing the holder's signature.

8. What protection and security measures have we put in place?

Safety and protection

The Personal Data collected by EDISOUND is kept in a secure environment and is hosted by the service provider identified in our Legal Notice.

EDISOUND undertakes to take all technical and organizational measures to guarantee the security of your Personal Data in order to protect them in particular against any loss, destruction, alteration, fraudulent access or retention. These measures include the physical security of our premises and the security of our computer systems.

Where subcontractors are used, EDISOUND ensures that they comply with Personal Data Regulations.

Where necessary, you may be asked to create a password for access to your Customer Account. In this case, it is your responsibility to keep this password strictly confidential, to limit third-party access to your equipment and to log off after using our Services.

Social networking

You can join EDISOUND's services on social networks (Facebook, Instagram, Twitter...) to follow our Contents, to propose you advertising offers. The use of social networks may lead to data exchanges between EDISOUND and these social networks.

In this respect, EDISOUND may collect anonymous data about you for statistics on the number of subscribers.

EDISOUND invites you to contact the social networks concerned to consult their privacy policies and exercise your rights.

Minors

Under no circumstances may Minors alone give their consent to the processing of their Personal Data for the purposes of providing the Services. Minors may only provide the information necessary for the Services with the prior consent of the persons holding parental authority. The use of the Services by a Minor remains under the full responsibility of the persons holding parental authority.

Holders of parental authority are invited to monitor their children's use of access to the Services and to bear in mind that the Services are intended to reach a wide audience and that, in their capacity as legal guardians, it is the parents' responsibility to determine which Service is or is not appropriate for their child(ren) and to monitor their use thereof.

The Minor expresses his/her consent jointly with that of the holder of parental responsibility. The creation of a User Account by a Minor implies the prior authorization of the holder of parental authority.

EDISOUND reserves the right to verify at any time the consent given by the holder of parental responsibility for the Minor.

9. Applicable law and remedies

This document is governed by French law. In the event of a dispute relating to the interpretation, execution or exercise of the rights pertaining to your Personal Data, EDISOUND undertakes to first seek an amicable solution.

Failing this, the person concerned may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) at the following address: http://www.cnil.fr/fr/plaintes or refer the matter to the competent courts.

The present Personal Data and Cookies Policy applies in addition to the General Terms and Conditions of Sale and the General Terms and Conditions of Use.