Privacy policy

The publisher gives the highest importance to protecting your personal data. That is why we undertake to respect the privacy and the confidentiality of the personal data that we collect.

This privacy policy will provide you with information on how the Site uses and protects the information that you send us when you are browsing on the Site.

Please note that the Policy is subject to change or be supplemented at any time by the Publisher of the Site, in particular for the purposes of complying with any legislative, regulatory, jurisprudence or technological change. In such a case, the date is was updated will be identified clearly in the header of this policy. The modifications are binding on the User as soon as they are placed online. The User should consequently consult this confidentiality and cookie usage policy on a regular basis in order to become aware of any modifications therein.

1) Definitions

Site: concerns the site lefaillet.fr.
User: as a Site visitor, you become a user of the content and services offered by the Site.
Terminal: this is the device that you use to access and browse the Site (computer, tablet, smartphone…).

2) Personal data collected

We are likely to collect and process the following data:

• The information that you forward to us directly:
  When browsing on the Site, you may need to send us information, of which some of it allows you to be identified (your “Personal Data”). This is in particular the case when you use a contact form, publish a comment, participate in a survey, a study, a game contest, or you register for the newsletter…
  This information can in particular contain the following Personal Data:
  – last and first name
  – email address
  – telephone
  – mailing address
  – and the other information that you may send to us in the framework of an exchange or contact.
• The information that we collect automatically through interactivity with the Site:
  This is data collected from cookies, in particular by Google Analytics, with for example the following information:
  – information concerning the devices that you use to access the Site (computer, tablet, smartphone)
  – IP address, connection and location data (IMPORTANT: we have set up a system for rendering anonymous the IP addresses collected as such by Google Analytics)
  – operating system and platforms
  – data concerning your browsing path on the Site (url of the pages consulted, consultation duration, search terms used, etc.).
  In the event you use the social network features that are made available to you, we will have access to certain information (in particular, your first name, last name, photograph, email address and number of friends) for your account on said social network in accordance with the general conditions of use for the social network concerned. We are also likely to collect some of your Personal Data when you interact with the features of these social networks, such as the “I like” functionality.

3) Cookies

Cookies are small text data files in alphanumeric format that are placed on your hard drive when you are browsing on an internet site. These files are generated by the server of the site visited or by a third-party server (analytic web service, advertising department, etc.).

Cookies make it possible to identify you (through your computer), when you return to the site you initially visited. Cookies cannot retrieve or transmit any data from your hard drive, or transmit viruses.

The Site can use cookies and similar technologies in order to facilitate browsing by memorising your user preferences such as for understanding the use that you make of the services and content proposed by the Site, this is for the purposes of trying to improve the pertinence and ergonomics of them, in particular.

We can also include tracking pixels in our emails and newsletters, which a small image files which make it possible to determine if the messages have been opened and if the links that are included therein have been consulted.

The cookies and similar technologies that we use can be:

• functional: i.e. required to perform a functionality, such as identifying you for correspondence, a comment, or where applicable an on-line order, for example;
• analytical and performance: i.e. linked to the follow-up and marketing analysis of the consultation frequency of the Site;
• advertising and targeting: in case of recourse to advertising, these cookies can record your visits and your browsing on the pages of the Site or your location, in such a way as to allow the Site and its advertising partners to provide you with advertising that is coherent with your centres of interest and/or your geographical situation;
• social networks: these are cookies placed by the social network share buttons.

These cookies can come from the Site server or from third parties (such as Google Analytics, for example).

During your initial browsing on the Site, you are asked for your consent for this use of cookies and at any time you can revoke your consent, if you so desire, in the following way:

• By configuring your internet browser:
– Chrome: https://support.google.com/accounts/answer/61416?hl=en
– Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
– Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies
– Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• By deactivating the cookie services online:
– Analytical and performance cookies: Google Analytics
– Social network cookies: Facebook – Twitter – YouTube – LinkedIn – Instagram

If you refuse the recording of cookies on your Terminal, you can continue to brose the Site, but certain parts or features may not work correctly.

4) Purpose of collecting and processing your Personal Data

We use your Personal Data, with your consent, to:

• provide you with the content that you requested (in particular the newsletter etc.),
• establish a contact and/or correspondence with you in order to provide you with information on our activities and/or services,
• allow you, where applicable, to communicate with the other Site visitors, in particular through article comments,
• obtain frequency statistics in order to allow us to improve the management of the Site (presentation, organisation, adaptation of the content to your device, etc.) and your user experience,
• allow you to customise your profile so as to offer you content and offers that are in line with your expectations and centres of interest,
• provide you, where applicable, with the products or services that you may have ordered on the Site,
• receive, where applicable, payments in exchange for the product or services provided,
• provide us with assurance of compliance with our general conditions of use of the Site, with our Confidentiality Policy and applicable regulations.

This processing is based on your consent and/or legitimate interest in measuring the effectiveness of our services and compliance with our respective obligations.

5) Recipients of the information collected

The activity of the Publisher is not to sell your Personal Data.

Consequently, your Personal Data is shared only in the following cases:

• with our web analytics service providers (Google Analytics);
• with our email service provider (MailChimp or SendinBlue);
• with our subscriber and/or client file management service provider (such as Zoho CRM where applicable);
• with our payment service providers (such as PayPlug, PayPal or Stripe, where applicable);
• with our suppliers of products or services that are sold via the Site (where applicable) and the corresponding logistics;
• in the framework of legal requirements or to enforce compliance with our conditions of use of the Site and, generally, to protect our rights;
• and when you request them, such as for example, when where applicable, you use a method of authentication supplied by a social network or if you arrive on the Site because you clicked on an ad or link on a partner site.

6) Personal Data retention time

Your Personal Data is retained by the Publisher and/or its service providers for the time required to provide the services that correspond to the collection of this data or to respond to your request.

7) Personal Data Protection

We give great importance to securing the Site and your Personal Data. The latter will be retained on our server at our hosting service provider in a secure environment, in compliance with the GDPR.

Our security system in particular includes the following elements:

• Protection of the Site via a Let’s Encrypt certificate under the SSL (Secure Sockets Layer) system.
• Firewall and malware monitoring by Wordfence from Defiant.
• Specific encrypting for email addresses by Email Encoder Bundle.
• Rendering your IP address anonymous with regards to Google Analytics processing using Google Analytics Germanized.
• Administrator access is protected by complex passwords.

On your side, you are responsible for protecting your ID and password and must prevent unauthorised access to the latter; in particular, if you share a Terminal, you must sure that you are fully disconnected after each use.

8) Your rights pertaining to your Personal Data

You have the following rights pertaining to your Personal Data:

• right to access: you can access your Personal Data that we may hold about you;
• right to correction: you can update your Personal Data where applicable in the management interface of your parameters or ask us to update it.
• right to deletion: you can ask us to delete your Personal Data.
• right to transfer: you may ask us to return the Personal Data that you have provided us with in the form of a file that can be read by a machine.

To exercise one or the other of these rights, use the contact button in the last paragraph below. We will do our best to provide you with this information or modify or delete it within a period of 30 days following receipt of your request, accompanied, because of our security and confidentiality obligation, proof of your identity, and excluding requests that are manifestly abusive in terms of their number or their repetitive or systematic nature.

We are however likely to retain some of your Personal Data when the Law requires or for a legitimate reason, and in particular to avail ourselves of our rights in case of dispute.

9) Applicable regulations

The Site is governed by French law and in particular the General Data Protection Regulation adopted by the European Parliament and the Council on 27 April 2016, and the Data Protection Act of 6 January 1978 amended.

For further information concerning the regulations in effect, you can consult the CNIL website.

10) Contact

Formulation of legal notices and privacy policy: © Accompagnement & Stratégie SAS.