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PRIVACY POLICY AND COOKIE POLICY

The website www.open13.fr is edited by the company PAMPELONNE ORGANISATION.

As PAMPELONNE ORGANISATION is concerned about respecting the rules relating to the protection of personal data, this site has been developed in compliance with the General Data Protection Regulation n°2016/679 and the law known as "Informatique et libertés" of 6 January 1978 in its latest version.

PAMPELONNE ORGANISATION is committed to ensuring that your personal data is collected in a lawful, fair and transparent manner.

I) PRIVACY POLICY

The processing of Personal Data referred to in this Privacy Policy is subject to French law, and in particular to the French Data Protection Act of 6 January 1978 as amended, and to the EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data (RGPD), hereinafter referred to as the "Personal Data Regulation".

1. Person responsible for the processing

The person in charge of processing Personal Data is PAMPELONNE ORGANISATION, a simplified joint stock company registered with the R.C.S of Marseille under the number 424 857 779 and located at 10 rue Stanislas Torrents, 13 006 MARSEILLE.
The User is informed that PAMPELONNE ORGANISATION may use subcontractors. In this case, PAMPELONNE ORGANISATION takes care to frame the contracts that bind it to its subcontractors, in accordance with legal and regulatory provisions.

2. Who is our data protection policy aimed at?

This policy applies to all visitors to the www.open13.fr website (hereinafter "our website"), our registered members, as well as those who request information from us.

The term "personal data" (hereinafter "Data") has the meaning defined in the Personal Data Regulation.

In order for you to be able to browse the www.open13.fr website with confidence, we are committed to processing your Data in accordance with the Personal Data Regulation. This privacy policy aims to describe in a transparent manner how and why your Data is processed. The term "data processing" is used here to refer to the collection and processing of Data.

3. Categories of data processed

We may process the following Data:

The data you enter

Newsletter subscription :
- Email address
- Last name, first name
- Country

Advent Calendar Game :
- Email address
- Last name, first name
- City
- Telephone
- Opt-in regulation
- Opt-in information from the Open 13 Provence partners
- Opt-in information from the Open 13 Provence

The Data we collect automatically when you use our services

In order to enable you to access the services offered by our website, we collect Usage Data in order to, for example, measure the audience of our website or the number of page views. We use the login details of your mobile devices, your IP address and cookies to identify you and to record your activity.
We may also collect Technical Data about your internet connection, browser and devices (e.g. iPhone or Android, PC or Mac, font size, etc.). For more information on the use of cookies, see point II) "cookies" below.

Data concerning minors

Our website and/or our thematic promotional campaigns are not intended for minors. If, however, you become aware that a minor for whom you are responsible has registered on our website and you object to this, please contact us and we will immediately remove his or her Data from our databases.

4. Uses of your Data and legal basis

Processing your Data on the basis of the data subject's consent (Article 6 a. of the GDPR)

We process your Data, with your consent, for the following purposes

  • To manage the opening of your account on our website, in order to allow you to use the services offered by our website, such as participating in a promotional action or printing a discount coupon;
  • You send our newsletters;
  • To send you information on the products and services of PAMPELONNE ORGANISATION by e-mail, post or telephone (if you have given us this information);
  • You send promotional actions on behalf of our business partners;
  • Communicate your Data to our commercial partners so that they can contact you for marketing purposes for their products and services, possibly on the basis of your profile and subject to your specific authorization prior to this transfer;
  • Respond to questions via our website or any other communication channel.

You may withdraw your consent at any time under the conditions described in Article 8 below.

Use of your Data on the basis of compliance with our legal obligations (Article 6 c. GDPR)

In order to comply with the legal obligations to which we are, in some cases, subject, which require the processing and/or transmission of certain Data to administrations or institutions determined by law (e.g. police, tax authorities, etc.).

Use of your Data on the basis of our legitimate interest (Article 6 f. GDPR)

Where we have a legitimate interest, either in the context of our marketing activities or in the context of the actual performance of our business activities, we collect and process Data for the following purposes

  • To conduct research, testing and analysis (including customer or market research) to improve our solutions, internal processes and overall service,
  • To perform statistical or trend analysis for financial management, marketing or reporting purposes,
  • In order to prevent and combat possible fraud and abuse.

5. Transmission of your Data to third parties

Your Data may be communicated to third parties in the following cases:

  • To some of our subcontractors in the context of services provided on our behalf (e.g. marketing agency, hosting provider, etc.) and only on the basis of our instructions;
  • To certain of our business partners, provided we have obtained your specific consent in advance.

Transfer of Data outside the European Union

Your Data will not be transferred outside the European Union. If we change our policy, we will ensure that the transfer is to countries recognised as providing an adequate level of protection for your Data or, at least, on the basis of appropriate safeguards provided by law.

6. How long we keep your Data

Your Data is kept for a period strictly necessary for the purposes pursued. The retention period may vary depending on the purpose of the processing.

Categories of Data Retention Periods in Active Database

Your customer account data
Data related to specific requests
Data from your customer account, Data related to specific requests
3 years from the last contact from the customer (last login to your account)
Newsletter opt-in and/or partner opt-in data (subject to your express consent)
The data will be kept for as long as the data subject does not unsubscribe (via the unsubscribe link provided) and for as long as he or she remains a customer.
Cookies
13 months maximum. See Cookies Policy point II.
Data likely to be subject to a judicial requisition (connection data, identity, contact details, transaction data)
12 months from the date of collection.

Data from opt-in newsletters and / or opt-in partners (subject to your express consent) Data retention as long as the data subject does not unsubscribe (via the unsubscribe link provided) and as long as he or she remains a customer.

7. Security of your Data

PAMPELONNE ORGANISATION attaches particular importance to data security.

It has put in place physical, logical, administrative or organisational measures, adapted to the degree of sensitivity of the Data, in order to ensure the integrity and confidentiality of the Data and to protect them against any malicious intrusion, loss, alteration or disclosure to unauthorised third parties.

When it uses a service provider, PAMPELONNE ORGANISATION only communicates the Data to him after having verified the respect of these security principles.

PAMPELONNE ORGANISATION can be led to carry out audits in order to check the good operational application of the rules relating to the security of the Data.

8. Your rights

Exercising your rights

You can send your request to the following address, specifying "OPEN13-personal data" in the subject line:

pampelonneorganisation@open13.org
or
PAMPELONNE ORGANISATION, 10 rue Stanislas Torrents, 13 006 MARSEILLE for the attention of Mr Caujolle.
If you request this information in electronic format, unless you instruct us otherwise, we will also respond electronically.

Please note that your application is linked to the e-mail address you provide to identify yourself. If you have created several accounts by registering several different e-mail addresses, you will have to provide us with all the e-mail addresses concerned by your request.

In accordance with the Personal Data Regulation, your request will be processed within 30 days from the time we have all the necessary elements to process it. If your request is complex, this period may be extended by up to two months, but we will inform you of this beforehand.

Your right of access and rectification

In accordance with the Personal Data Regulation, you have a right to obtain confirmation that your Data is being processed (or not) and a right to access it, if applicable, and to request a copy from us.

You also have the right to ask us to complete and/or rectify the information about you.

Your right to object and to have your Data deleted

This is your right to object at any time and without justification to the processing of your Data by PAMPELONNE ORGANISATION. However, PAMPELONNE ORGANISATION may refuse to comply with your request if there are legitimate (for example, if we need to keep your Data for the time needed to process your participation in a refund offer) and compelling reasons.

You can obtain from PAMPELONNE ORGANISATION that your Data be deleted from our databases, in the manner defined by the Personal Data Regulation, subject to our legal obligations of conservation.

Your right to restrict processing

In the event of a dispute regarding the processing of your Data, you may request that the processing of your Data be suspended while the dispute is investigated. In this case, we will no longer use your Data until the challenge has been resolved.

You may exercise this right if you object to the processing, if you dispute the accuracy of your Data, if you believe that the processing of your Data is unlawful or if you need it for the establishment, exercise or defence of your legal rights.

Your right to the portability of your Data

You may ask us to transfer the Data you have provided to us to another data controller in a structured, commonly used and readable format, within the limits set out in the Personal Data Regulation. In this case, we will transfer it to the recipient of your choice.

Your right not to be subject to a decision based on automated processing

In the course of our activities, we may carry out automated processing of your Data. You have the right not to be subject to a decision based exclusively on automated processing that produces legal effects concerning or affecting you, except where such a decision is necessary for the conclusion or performance of a contract, or is authorised by law.

Your right to bring an action before the CNIL

You can take your complaint to the French supervisory authority, the CNIL (Commission Nationale de l'Informatique et des Libertés) by filing an action.

Your right to give instructions in the event of death

You have the right to give instructions on what to do with your Data after your death.

9. Data Protection Officer

For more information on our data protection policy or if you have any complaints about your privacy, you can contact our Data Protection Officer (hereinafter "DPO") by e-mail at the following address pampelonneorganisation@open13.org
or by mail sent to the head office of PAMPELONNE ORGANISATION (to the attention of the DPO / Mr Caujolle, specifying "OPEN13-personal data" in the subject of your request.

II) COOKIE POLICY

This site and its third party partners provide various services on its websites and mobile applications using cookies. We place cookies on your device to provide you with enhanced and personalised access to key services and to provide you with other services to make your visit more relevant.

1. What is a cookie?

Cookies are small text files placed on the hard disk of your terminal (computer, tablet or mobile phone) by a website or mobile application publisher thanks to your browser software. The cookie assigns a unique identifier to your terminal. However, it does not store your Data and therefore does not recognise you as an individual. It only recognises the terminal you are using.

The cookie helps to navigate from page to page on a website, tailor the content of our services, provide secure connections and remember your browsing preferences.

2. The cookies used on our website

Services provided through the use of cookies include: user login, cart management, protection and security. They are essential to the proper functioning of the site.

Types of cookies (Purposes) Objectives Examples Retention period

Types of cookies (Purposes)
Objectives
Examples
Shelf life
Functional or personalisation cookies
These cookies help the site to function properly from a technical point of view and personalise the browsing experience on the site.

They are used to store information in order to navigate the site. They do not collect any personal information and cannot be used for commercial purposes.
Access to your personal space.

Remember your login details: username / password / language / login info / last product ordered.

Remembering site preferences: display / accepting or refusing cookies / language.

Pre-fill certain fields in our forms.
1 month
Performance or analytical cookies (audience analysis)
They allow us to establish anonymous statistics on the frequentation of the site in order to improve its content. They cannot be used for commercial purposes. They help us to measure the effectiveness of a communication campaign.
Calculation of the number of clicks, error messages, sections and content visited, user path. Measuring the return on campaigns.
13 months

3. Your choices regarding cookies

We invite you to express your choices regarding cookies or to modify them by the means described below.

Managing cookies via your web browser

The "Help" section of Internet browsers tells you how to change your preferences, including how to reject new cookies, how to get a notification that you have received them or how to disable them.

To make it easier for you, here are the links to the "Help" sections of the most commonly used browsers:

For more information on how cookies and targeted advertising work, you can visit www.youronlinechoices.eu and www.allaboutcookies.org. However, these settings are only valid on the browser you are currently using.

  • On iOS, go to the privacy settings, access the "advertising" option and enable "limited ad tracking".
  • On Android, go to the "Google settings" application, activate the "disable interest-based ads" and "reset ad ID" options.

4. Our commitments on Cookies

We are committed to protecting your privacy and to the following two principles:

  • We do not associate any personally identifiable information with your cookies. Cookies do not contain your address, date of birth, telephone number or any other personally identifiable information.
  • We do not provide any personal information to advertisers or third party sites that display our ads based on your interests. If your device is used by more than one person, or if it has multiple browsers, it is possible that the content displayed to other users will match your preferences.

If you wish, you can change your browser settings by visiting the "Managing cookies via your web browser" section above.

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