PRIVACY POLICY

1.    Management of personal data

The Customer is informed of the regulations concerning marketing communication, the law of 21st June 2014 for trust in the Digital Economy, the Data Protection Act of 06th August 2004 and the General Data Protection Regulation (GDPR: no. 2016-679).

a.    Responsible for collecting personal data

For Personal Data collected in connection with the creation of the User’s personal account and its navigation on the website, the person responsible for processing Personal Data is: KREADC.  KREADC is represented by DESSEAUX Nicolas, its legal representative.

As the controller of the data it collects, KREADC undertakes to comply with the legal provisions in force. In particular, it is up to the Customer to establish the purposes of its data processing, to provide its prospects and customers, based on the collection of their consents, complete information on the processing of their personal data and to maintain a register of processing according to reality. Whenever KREADC processes Personal Data, KREADC takes all reasonable steps to ensure that the Personal Data is accurate and relevant to the purposes for which KREADC processes it.

b.    Purpose of the data collected

KREADC may process all or part of the data:

  • To enable navigation on the website and the management and traceability of services and services ordered by the user: login and use data of the website, billing, order history, etc.
  • To prevent and combat computer fraud (spamming, hacking, etc.): computer equipment used for navigation, IP address, password (hashed)
  • To improve navigation on the Site: login and usage data
  • To conduct optional satisfaction surveys: email address.
  • For optional communication campaigns (SMS, email): phone number, email address

KREADC does not market your personal data, which is therefore only used out of necessity or for statistical and analytical purposes.

c.    Right of access, correction and opposition

In accordance with the European regulations in force, the Users of KREADC services (1) have the following rights:

  • Right of access (Article 15 GDPR) and correction (Article 16 GDPR), updating, completeness of Users’ data right to lock or erase personal Users’ data (Article 17 GDPR), if inaccurate, incomplete, ambiguous, outdated, or whose collection, use, disclosure or retention is prohibited
  • Right to withdraw consent at any time (Article 13-2c GDPR)
  • Right to limit the processing of Users’ data (Article 18 GDPR)
  • Right to object to the processing of Users’ data (Article 21 GDPR)
  • Right to the portability of the data provided by the Users, when these data are subject to automated processing based on their consent or on a contract (Article 20 GDPR)
  • Right to define the fate of Users’ data after their death and to choose to whom KREADC must communicate (or not) its data to a third party they have previously designated

As soon as KREADC becomes aware of the death of a User and in the absence of instructions on its part, KREADC undertakes to destroy its data, unless their retention is necessary for probative purposes or to meet a legal obligation.

If the User wishes to know how KREADC uses its Personal Data, requests to rectify it or objects to its processing, the User may contact KREADC in writing at the following address:

KREADC – DPO, Nicolas DESSEAUX
15 rue des Halles 75001 PARIS.

In this case, the User must indicate the Personal Data that he would like KREADC to correct, update or delete, by specifically identifying himself with a copy of an identity document (identity card or passport).

Requests to delete Personal Data will be subject to the obligations imposed on KREADC by law, in particular as regards the retention or archiving of documents. Finally, Users of KREADC’s services (1) can file a complaint with the supervisory authorities, including the CNIL (In this case, the User must indicate the Personal Data that he would like KREADC to correct, update or delete, by specifically identifying himself with a copy of an identity document (identity card or passport).

Requests to delete Personal Data will be subject to the obligations imposed on KREADC by law, in particular as regards the retention or archiving of documents. Finally, Users of KREADC’s services (1) can file a complaint with the supervisory authorities, including the CNIL (https://www.cnil.fr/en/plaintes).

d.    Non-closure of personal data

KREADC does not process, host or transfer the Information collected about its Customers to a country outside the European Union or recognized as “inadequate” by the European Commission without first informing the customer. However, KREADC remains free to choose its technical and commercial subcontractors on the condition that they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: no. 2016-679).

KREADC undertakes to take all necessary precautions to protect the security of the Information and in particular that it is not communicated to unauthorized persons. However, if an incident affecting the integrity or confidentiality of the Customer’s Information comes to the attention of KREADC, the latter must inform the Customer as soon as possible and communicate to him the corrective measures taken. KREADC does not collect any «sensitive data».

The User’s Personal Data may be processed by subcontractors (service providers), exclusively to achieve the purposes of this policy.

Within the limits of their respective responsibilities and for the purposes mentioned above, the main persons likely to have access to the data of the KREADC Users are mainly the persons accredited by KREADC.

e.    Incident notification

No matter what efforts are made, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot therefore guarantee absolute security. If we became aware of a security breach, we would notify the affected users so that they could take appropriate action. Our incident notification procedures take into account our legal obligations, whether at national or European level. We are committed to fully informing our customers of all matters relating to the security of their account and to providing them with all the information necessary to help them meet their own regulatory reporting obligations.

No personal information of the user of KREADC’s services (1) is published without the knowledge of the user, exchanged, transferred, assigned or sold on any medium to third parties. Only the assumption of the acquisition of KREADC and its rights would allow the transmission of said information to the eventual purchaser who would in turn be bound by the same obligation of retention and modification of the data vis-à-vis the user of KREADC’s services (1)

f.     Security

To ensure the security and confidentiality of Personal Data and Personal Health Data, KREADC uses networks protected by standard devices.

When processing Personal Data, KREADC takes all reasonable measures to protect it from loss, misuse, unauthorized access, disclosure, alteration or destruction.

2.    Internet “cookies” hyperlinks and tags

KREADC’s services (1) contain a number of hyperlinks to other sites, set up with KREADC’s permission. However, KREADC does not have the possibility to verify the content of the sites visited, and will therefore assume no responsibility for this.

Unless you decide to disable cookies, you agree that the site may use them. You can deactivate these cookies at any time free of charge from the deactivation possibilities offered to you and recalled below, knowing that this may reduce or prevent access to all or part of the Services offered by the site.

a.   The « COOKIES »

A “cookie” is a small file of information sent to the User’s browser and stored within the User’s terminal (e.g., computer, smartphone), (hereinafter “Cookies”). This file includes information such as the User’s domain name, the User’s Internet service provider, the User’s operating system, and the date and time of access. Under no circumstances may Cookies damage the User’s terminal.

KREADC may process the User’s information concerning the use of its services (1). This information enables KREADC to improve the use of its services (1).

As Cookies facilitate the navigation and/or the provision of the services offered by the Site, the User can configure his browser so that it allows him to decide whether or not he wishes to accept them so that Cookies are stored in the terminal or, on the contrary, that they are rejected, either systematically or according to their issuer. The User may also configure his browsing software so that the acceptance or refusal of Cookies is offered to him on an ad hoc basis, before a Cookie is likely to be saved on his device. KREADC informs the User that, in this case, the functionality of its navigation software may not all be available.

If the User refuses the storage of Cookies in his terminal or his browser, or if the User deletes those stored there, the User is informed that his navigation and experience on the Site may be limited. This could also be the case where KREADC or one of its providers cannot recognise, for technical compatibility purposes, the type of browser used by the terminal, language and display settings or the country from which the device appears to be connected to the Internet.

If applicable, KREADC disclaims all liability for the consequences related to the degraded functioning of the Site and the KREADC services (1) resulting from (i) the refusal of Cookies by the User (ii) the impossibility for the services (1) KREADC to save or view the Cookies necessary for their operation by the choice of the User. For the management of Cookies and User choices, the configuration of each browser is different. It is described in the help menu of the browser, which will allow to know how the User can modify his wishes regarding Cookies.

At any time, the User may choose to express and modify his wishes regarding Cookies.  In addition, KREADC may use the services of external providers to assist it in collecting and processing the information described in this section.

Finally, by clicking on the icons dedicated to the social networks Twitter, Facebook, Linkedin and Google Plus appearing on the services (1) of KREADC or in its mobile application and if the User has accepted the deposit of cookies by continuing its navigation on the services (1) kreadc. Twitter, Facebook, Linkedin and Google Plus can also place cookies on your devices (computer, tablet, mobile phone).

These types of cookies are stored on your devices only if you consent to them, by continuing to browse KREADC’s services (1). At any time, the User may nevertheless withdraw his consent to KREADC’s filing of such cookies.

b.        INTERNET TAGS

KREADC services (1) may occasionally use Internet beacons (also known as “tags”, or action tags, one-pixel GIF, transparent GIF, invisible GIF, and one-to-one GIF) and deploy them through a web analytics partner that may be located (and therefore store the corresponding information, including the User’s IP address) in a foreign country.

These tags are placed both in the online advertisements allowing users to access the Site, and on the various pages of the Site.

This technology allows KREADC to evaluate the responses of visitors to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the use of this Site by the User.

The external service provider may collect information about visitors to the Site and other Internet sites through these beacons, compile reports on the activity of the Site for the attention of KREADC, and provide other services related to the use of the Site-here and the Internet.

3.    Compensation

You agree to indemnify and hold harmless KREADC, its officers, directors, shareholders, employees, affiliates and agents from and against any loss, claim, demand, obligation or prejudice, including legal fees due to or arising from: (1) your violation of any clause of these Terms of Use or any other KREADC Condition; (2) your violation of any third-party right, including copyright, access rights, property rights and privacy rights, resulting from your User Platform or User Content and/or your use of KREADC’s services (1) including and without limitation, the achievements of the services (1) KREADC for your benefit; and/or (3) any other type of claim that your User Platform and/or User Content has harmed a third party.

4.    Applicable law and jurisdiction

Any dispute relating to the use of KREADC’s services (1) is subject to French law. Apart from cases where the law does not allow it, exclusive jurisdiction is assigned to the competent courts of the Commercial Court of Paris (France).

5.    Final provisions

For marketing purposes only and unless the Customer expressly agrees in writing, KREADC reserves the right to mention the Customer’s name, together with its logo and a brief description of the use of KREADC’s services (1) in a list of its customer references. If KREADC wishes to present in more detail the projects carried out jointly with the Client, KREADC will ask the Client for permission. In the event of a disagreement notified in writing by the Customer, KREADC shall have a period of ninety (90) days from its receipt to delete any mention of the Customer from the list of its customer references.