PRIVACY POLICY (GDPR STANDARD)

Security and protection of personal data

Definitions 

The Publisher (Editor): the person, natural or legal , who publishes (edits) the services(departments) of communication to the online public.
The Site: all the sites, the webpages and the online services proposed by the Publisher(Editor).
The User: the person using the Site and the services(departments).

NATURE OF THE COLLECTED DATA

Within the framework of the use of Sites, the Publisher(Editor) may collect the categories of data
Following ones concerning his(her) Users:

Data of registry office(civil status), identity, identification …
Data of connection (IP addresses, newspapers of events)

COMMUNICATION OF THE PERSONAL DATA TO THIRD PARTIES

No communication in third parties
Your data are the object of no communication to third parties. You are however informed that they can be revealed in enforcement of a law, a regulation(payment) or by virtue of a decision of a competent statutory or judicial authority.

PRELIMINARY INFORMATION FOR THE COMMUNICATION OF THE PERSONAL DATA IN THIRD PARTIES IN CASE OF FUSION(MERGER) / ABSORPTION

Preliminary information and possibility of opt-out before and after the fusion(merger) / acquisition
In case we would take part in an operation of fusion(merger), acquisition or in any other shape of asset disposal, we make a commitment to guarantee the confidentiality of your personal data and to inform you before these are transferred or subjected(submitted) to new rules(rulers) of confidentiality.

IDENTITY DATA COLLECTION

Carry out operations relating to the management of clients concerning

contracts ; orders ; deliveries ; invoices ; accounting and in particular the management of customer accounts
a loyalty program within one or more legal entities customer relationship management such as satisfaction surveys, complaints and after-sales service management
the selection of customers to carry out studies, surveys and product tests (without the consent of the persons concerned obtained under the conditions laid down in Article 6, such operations must not
lead to the establishment of profiles likely to reveal sensitive data – racial or ethnic origins, philosophical, political, trade union, religious, sex life or health opinions
of people)

Carry out operations relating to prospecting
management of technical prospecting operations (including technical operations such as standardization, enrichment and deduplication)

the selection of people to carry out loyalty, prospecting, polling, product testing and promotion actions. Unless consent has been obtained from the persons concerned under the conditions laid down in Article 6, such operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life or health of persons).

Management of requests for access, rectification and opposition rights

Managing people’s opinions on products, services or content

DATA AGGREGATION

Aggregation with non-personal data
We may publish, disclose and use aggregate information (information about all our Users or specific groups or categories of Users that we combine in such a way that an individual User can no longer be identified or referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other business purposes.

Aggregation with personal data available on the User’s social accounts
If you connect your account to an account of another service for the purpose of sending cross mailings, that service may share your profile information, login information, and any other information that you have authorized for disclosure. We may aggregate information relating to all our other
Users, groups, accounts, to the personal data available on the User.

IDENTITY DATA COLLECTION

Free consultation
Consultation of the Site does not require prior registration or identification. It can be carried out without you communicating personal data concerning you (name, first name, address, etc). We do not record any personal data for the simple consultation of the Site.

IDENTIFICATION DATA COLLECTION

Use of the user’s identifier for proposals and commercial offers
We use your electronic identifiers to search for present relations by connection, by e-mail address or by services. We may use your contact information to enable others to find your account, including through third-party services and client applications. You can upload your address book so that we can help you find acquaintances
on our network or to allow other Users on our network to find you. We can offer suggestions to you and other Network Users from contacts imported from your address book. We may work in partnership with companies that offer incentives. To support this type of promotion and incentive offer, we may share your electronic ID.

TERMINAL DATA COLLECTION

Collection of profiling and technical data for service delivery purposes
Some of the technical data of your device is collected automatically by the Site. This information includes your IP address, Internet service provider, hardware configuration, software configuration, browser type and language, etc. The collection of this data is necessary for the provision of services.

Collection of technical data for advertising, commercial and statistical purposes
The technical data of your device are automatically collected and recorded by the Site, for advertising, commercial and statistical purposes. This information helps us personalize and continually improve your experience on our Site. We do not collect or store any personal data (surname, first name, address, etc.) that may be attached to technical data. The data collected may be sold to third parties.

COOKIES
How long cookies are stored
In accordance with CNIL recommendations, the maximum storage period for cookies is 13 months maximum after their first deposit in the User’s terminal, as is the duration of the validity of the User’s consent to the use of these cookies. Cookies do not last longer each visit. The User’s consent must therefore be renewed at the end of this period.

Purpose cookies
Cookies may be used for statistical purposes, in particular to optimise the services provided to the User, by processing information concerning the frequency of access, the personalisation of pages and the operations carried out and information consulted. You are aware that the Publisher may place cookies on your device. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of the consultation…) that we can read during your subsequent visits.

User’s right to refuse cookies
You acknowledge that you have been informed that the Publisher may use cookies. If you do not want cookies to be used on your device, most browsers allow you to disable cookies by using the setting options.

TECHNICAL DATA STORAGE
Retention period for technical data
The technical data are kept for the time strictly necessary to achieve the purposes referred to above.

TIME LIMIT FOR STORING PERSONAL DATA AND ANONYMISATION
Retention of data for the duration of the contractual relationship
In accordance with Article 6-5° of Law No. 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties, personal data subject to processing shall not be kept beyond the time necessary to fulfil the obligations defined when the contract was concluded or the predefined duration of the contractual relationship.

Retention of anonymised data beyond the contractual relationship / after deletion of the
reckoning
We retain personal data for the time strictly necessary to achieve the purposes described in these TOS. Beyond this period, they will be anonymised and kept exclusively for statistical purposes and will not give rise to any exploitation of any kind whatsoever.

Deleting data after account deletion
Means for purging data shall be put in place in order to provide for their effective deletion as soon as the conservation or archiving period necessary for the fulfilment of the purposes determined or imposed has been reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the right to delete your data which you can exercise at any time by contacting the Publisher.

Deletion of data after 3 years of inactivity
For security reasons, if you have not authenticated on the Site for a period of three years, you will receive an e-mail inviting you to connect as soon as possible, failing which your data will be deleted from our databases.

ACCOUNT DELETION
Deleting the account on demand
The User has the possibility to delete his Account at any time, by simple request to the Publisher OR through the Account deletion menu in the Account settings if applicable.

Deletion of the account in case of violation of the TOS
In the event of a violation of one or more provisions of the TOU or any other document incorporated into the
present by reference, the Publisher reserves the right to terminate or restrict, without prior notice and at its sole discretion, your use of and access to the Services, your account and all the Sites.

INDICATIONS IN THE EVENT OF A SECURITY BREACH DETECTED BY THE PUBLISHER
User information in the event of a security breach
We undertake to implement all appropriate technical and organizational measures to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of personal data concerning you. In the event that we become aware of illegal access to your personal data stored on our servers or those of our providers, or unauthorized access resulting in the realization of the risks identified above, we undertake to :

– Notify you of the incident as soon as possible;
– Examine the causes of the incident and inform you;
Take the necessary measures within reasonable limits to mitigate the negative effects, and
damage that may result from the said incident

Limitation of Liability
Under no circumstances may the commitments defined in the above point relating to notification in the event of a security breach be assimilated to any admission of fault or liability with regard to the occurrence of the incident in question.

TRANSFER OF PERSONAL DATA ABROAD
Data transfer in countries with an equivalent level of protection
The Publisher undertakes to comply with the applicable regulations relating to data transfers to foreign countries and in particular according to the following procedures:
The Publisher transfers the personal data of its Users to countries recognised as offering an equivalent level of protection.

The Publisher transfers the personal data of its Users outside the countries recognised by the CNIL as having a sufficient level of protection: The Publisher has obtained authorization from the CNIL to carry out this transfer.

For a list of these countries: CNIL – La protection des données dans le monde

CHANGES TO CGU AND PRIVACY POLICY
In the event of a change to these TOU, an undertaking not to lower the level of confidentiality by
substantially without prior information of the persons concerned
We undertake to inform you in the event of substantial changes to these TOU, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.

APPLICABLE LAW AND REDRESS PROCEDURES
Arbitration clause
You expressly agree that any dispute that may arise from these TOU, including its interpretation or performance, shall be governed by arbitration proceedings subject to the rules of the arbitration platform chosen by mutual agreement, to which you will adhere without reservation.

DATA PORTABILITY
Data portability
The Publisher undertakes to offer you the possibility of having all the data concerning you returned to you on request. The User is thus guaranteed a better control of his data, and keeps the
possibility of reusing them. This data should be provided in an open and easily reusable format.

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LEGAL INFORMATION

1. PRESENTATION OF THE SITE.

Pursuant to Article 6 of Act No. 2004-575 of 21 June 2004 on confidence in the digital economy, users of the site www.redwood-talentpartners.com are informed of the identity of the various parties involved in its implementation and monitoring:

Owner: Redwood Talent Partners – SAS – 91 rue du Faubourg Saint-Honoré 75008 Paris

Designer: Steeve Benabou

Publication Manager : Marie-Laurence Leroy – marielaurence.leroy@redwood-talentpartners.com

The publication manager is a natural person or a legal entity.

Webmaster: Steeve Benabou – +33 6 24 86 05 22

Host: OVH – 2 rue Kellermann 59100 Roubaix

2. GENERAL CONDITIONS OF USE OF THE SITE AND THE SERVICES OFFERED.

The use of the www.redwood-talentpartners.com site implies full and complete acceptance of the general conditions of use described below. These conditions of use may be modified or supplemented at any time. Users of the www.redwood-talentpartners.com site are therefore invited to consult them regularly.

This site is normally accessible at any time to users. However, Redwood Talent Partners may decide to interrupt the service for technical maintenance reasons and will make every effort to inform users of the dates and times of the service beforehand.

The site www.redwood-talentpartners.com is regularly updated by Marie-Laurence Leroy. In the same way, the legal notices may be modified at any time: they are nevertheless binding on the user who is invited to refer to them as often as possible in order to read them.

3. DESCRIPTION OF SERVICES PROVIDED.

The purpose of the www.redwood-talentpartners.com site is to provide information concerning all the company’s activities.

Redwood Talent Partners strives to provide as accurate information as possible on the www.redwood-talentpartners.com website. However, it cannot be held responsible for omissions, inaccuracies or deficiencies in the update, whether caused by itself or by third party partners who provide it with this information.

All the information indicated on the site www.redwood-talentpartners.com is given as an indication, and are likely to evolve. The information on www.redwood-talentpartners.com is not exhaustive. They are given subject to modifications that have been made since they were put online.

4. CONTRACTUAL LIMITATIONS ON TECHNICAL DATA

The site uses JavaScript technology.

The website cannot be held responsible for material damages related to the use of the site. Furthermore, the user of the site undertakes to access the site using recent, virus-free material and with an up-to-date browser.

5. INTELLECTUAL PROPERTY AND COUNTERFEITING

Redwood Talent Partners is the owner of the intellectual property rights or holds the rights of use on all the elements accessible on the site, in particular the texts, images, graphics, logo, icons, sounds, software.

Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the site, whatever the means or the process used, is prohibited, except prior written authorization from : Redwood Talent Partners.

Any unauthorized use of the site or any of the elements it contains will be considered as constituting an infringement and prosecuted in accordance with the provisions of articles L.335-2 and following of the Intellectual Property Code.

6. LIMITATIONS OF LIABILITY

Redwood Talent Partners cannot be held responsible for any direct or indirect damage caused to the user’s equipment when accessing the www.redwood-talentpartners.com site, resulting either from the use of equipment that does not meet the specifications indicated in point 4, or from the appearance of a bug or incompatibility.

Redwood Talent Partners shall also not be liable for any indirect damages (such as loss of market or opportunity) arising out of the use of the www.redwood-talentpartners.com. site.

Interactive spaces (possibility to ask questions in the contact area) are available to users. Redwood Talent Partners reserves the right to remove, without prior notice, any content deposited in this space that contravenes the legislation applicable in France, in particular the provisions relating to data protection. If necessary, Redwood Talent Partners also reserves the right to hold the user liable under civil and/or criminal law, in particular in the event of racist, insulting, defamatory or pornographic messages, whatever the medium used (text, photograph, etc.).

7. PERSONAL DATA MANAGEMENT

In France, personal data is protected in particular by Act No. 78-87 of 6 January 1978, Act No. 2004-801 of 6 August 2004, Article L. 226-13 of the Criminal Code and the European Directive of 24 October 1995.

When using the www.redwood-talentpartners.com site, may be collected: the URL of links through which the user accessed the www.redwood-talentpartners.com site, the user’s access provider, the user’s Internet Protocol (IP) address.

In any event Redwood Talent Partners collects personal information about the user only for the purpose of certain services offered by the site www.redwood-talentpartners.com. The user provides this information in full knowledge of the facts, in particular when he enters it himself. It is then specified to the user of the site www.redwood-talentpartners.com the obligation or not to provide this information.

In accordance with the provisions of articles 38 and following of the law 78-17 of January 6, 1978 relating to data processing, files and freedoms, any user has a right of access, rectification and opposition to personal data concerning him, by making his written and signed request, accompanied by a copy of the identity document with signature of the holder of the document, specifying the address to which the reply must be sent.

No personal information of the user of the www.redwood-talentpartners.com site is published without the user’s knowledge, exchanged, transferred, transferred or sold on any medium to third parties. Only the hypothesis of the purchase of Redwood Talent Partners and its rights would allow the transmission of the said information to the possible purchaser who would be in his turn held of the same obligation of conservation and modification of the data vis à vis the user of the site www.redwood-talentpartners.com.

The site is not declared to the CNIL because it does not collect personal information. .

The databases are protected by the provisions of the law of 1 July 1998 transposing Directive 96/9 of 11 March 1996 on the legal protection of databases.

8. HYPERTEXT LINKS AND COOKIES.

The www.redwood-talentpartners.com site contains a number of hypertext links to other sites, set up with the permission of Redwood Talent Partners. However, Redwood Talent Partners does not have the ability to verify the content of such sites, and will not assume any liability as a result.

Browsing the www.redwood-talentpartners.com site may cause cookies to be installed on the user’s computer. A cookie is a small file, which does not allow the identification of the user, but which records information relating to the navigation of a computer on a site. The data thus obtained are intended to facilitate subsequent navigation on the site, and are also intended to allow various measures of attendance.

Refusal to install a cookie may make it impossible to access certain services. The user can however configure his computer in the following way, to refuse the installation of cookies:

Under Internet Explorer : tool tab (pictogram in the form of a cog at the top right) / internet options. Click on Privacy and choose Block all cookies. Confirm with Ok.

Under Firefox: at the top of the browser window, click the Firefox button, then go to the Options tab. Click on the Privacy tab.
Set Retention Rules to: Use custom settings for history. Finally uncheck it to disable cookies.

Under Safari: Click on the menu pictogram at the top right of the browser (symbolized by a cog). Select Settings. Click Show Advanced Settings. In the “Privacy” section, click Content Settings. In the “Cookies” section, you can block cookies.

Under Chrome : Click on the menu pictogram at the top right of the browser (symbolized by three horizontal lines). Select Settings. Click Show Advanced Settings. In the “Privacy” section, click on Preferences. In the “Privacy” tab, you can block cookies.

9. APPLICABLE LAW AND JURISDICTION

Any litigation related to the use of the www.redwood-talentpartners.com site is subject to French law. The competent courts of Paris shall have exclusive jurisdiction.

10. THE MAIN LAWS CONCERNED

Act No. 78-87 of 6 January 1978, in particular amended by Act No. 2004-801 of 6 August 2004 relating to data processing, files and freedoms.

Act No. 2004-575 of 21 June 2004 on confidence in the digital economy.

11. GLOSSARY

User: Internet user connecting, using the above-mentioned site.

Personal information: “information that allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies” (Article 4 of Act No. 78-17 of 6 January 1978).