Privacy Policy

1. SUBJECT

When using the Services of the website www.pulse.groupe-sos.org whose details are in Article 2 below, GROUPE SOS PULSE is required to collect personal data from Users (the "Personal Data").

The purpose of this Personal Data Protection Charter (hereinafter the "Charter") is to inform Users of the use made by GROUPE SOS PULSE of Personal Data. This use is made in compliance with Law n° 78-17 of 6 January 1978 relating to Information Technology and Civil Liberties, amended by Law n°2004-801 of 6 August 2004 and by Law n° 2018-493 of 20 June 2018 (the "Information Technology and Freedoms Law - French law on Data Protection”), and with Directive of 12 July 2002 amended by Directive 2009/136/EC (the "ePrivacy Directive"), and with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regards to the processing of personal data and on the free movement of such data (the "GDPR"), and with any national transposition text or any subsequent text that would succeed them (all of those laws/directives are the "Applicable Regulations").

The Charter may be modified at any time by GROUPE SOS PULSE in order to comply with any legislative, regulatory, jurisprudential, editorial or technical changes. Users must therefore refer to the latest version of the Charter before any navigation.

2. DEFINITIONS

The terms "personal data" ("Personal Data"), "Process/Processing", "Process supervisor", "Sub-processor", "Recipient(s)", "Consent", have the same meaning as set out in Article 4 of the GDPR.

"User(s)" means any natural person accessing the website without having created a Member Account and using only certain functionalities of the website;

"Third Parties" refers to any natural person or legal entity that is a third party to GROUPE SOS PULSE, to a User or a Member;

"Services" refers to all or part of the services offered by GROUPE SOS PULSE on its website;

"Website" refers to the internet website published by GROUPE SOS PULSE, the Services available at www.pulse.groupe-sos.org or any other website related to the Services.

3. PURPOSES AND PERSON RESPONSIBLE FOR PERSONAL DATA

We attach the utmost importance to the respect of your privacy and your Personal Data protection. That is why GROUPE SOS PULSE processes your Personal Data, in compliance with the Applicable Regulations, for the following purposes:

- contact with Users and management of the relationship with them

- to inform Users of news, events and other activities related to the corporate purpose of GROUPE SOS PULSE;

- to offer Services related to the activities of GROUPE SOS PULSE and the sector it represents;

- to consult and store information relating to navigation on the website that may be recorded in "cookie" files (defined in Article 9 below).

For these purposes only, the Controller is GROUPE SOS PULSE - SIRENnumber. 500 176 896 whose address is: 102C rue Amelot 75011 Paris, whose contact details can be found in Article 10 below.

4. WHAT PERSONAL DATA IS COLLECTED AND FOR WHAT PURPOSES?

At the time when the Personal Data is collected, the User is informed whether certain Personal Data is mandatory or optional. If the Personal Data required is not provided, access to certain features of the Services would be impossible.

GROUPE SOS PULSE may collect the following categories of Personal Data:

- Surname, first name and email address in order to receive GROUPE SOS PULSE’s newsletter. The declaration of Consent is made by the voluntary transmission of this User’s information in each of the fields provided for this purpose in the Newsletter Sending Form. The User has the possibility to refuse the sending of newsletters at any time by using the corresponding link in the newsletter or by sending a message. The e-mail address will then be deleted from GROUPE SOS PULSE’s distribution list.

- The surname, first name and e-mail address required to contact a GROUPE SOS PULSE interlocutor. The declaration of Consent involves the voluntary transmission of this information by the User in each of the fields provided for this purpose in the Contact Form.

- Any other information constituting Personal Data according to the Applicable Regulations voluntarily provided in the "Leave your message" section of the Contact Form, the spontaneous application form or by any other appropriate means.

- Navigation data as detailed in Article 9 below.

5. THE RECIPIENTS OF THE PERSONAL DATA

The Personal Database created by using Services is strictly confidential. GROUPE SOS PULSE undertakes to take all useful precautions and implement appropriate organizational and technical measures to preserve the security, integrity and confidentiality of Personal Data, particularly to prevent it from being distorted, damaged or accessed by unauthorized Third Parties.

5.1 Data transferred to public authorities and/or public bodies

In accordance with the Applicable Regulations, Personal Data may be communicated to the competent authorities upon request and particularly to public bodies in order to comply with legal obligations, court officials, judicial officers and bodies in charge of debt collection.

5.2 Data accessible to Third Parties

The Personal Data may be used by GROUPE SOS PULSE, its Sub-Contractors, the co-processors, its affiliates and/or, where applicable, its partners, for the purposes described in Article 3 above.

- The authorized personnel of GROUPE SOS PULSE, by virtue of their duties, the departments in charge of control (in particular the statutory auditor) and the subcontractors of GROUPE SOS PULSE shall have access to the Personal Data collected when using Services;

- GROUPE SOS PULSE partners who assist it in providing Services;

- Social networks: if the User has accounts on social networks and accesses the Services, these may include plug-ins such as "Like" buttons or share or redirect buttons, enabling content from the Services to be published on social networks. In this case, the relevant social networks may receive information relating to the use of the Services by the User.

5.3 Transfers outside the European Union

The User's Personal Data may be Processed outside the European Union, including via remote access. GROUPE SOS PULSE is committed to not transferring Personal Data outside the European Union without implementing the appropriate guarantees in accordance with Applicable Regulations.

6. THE USER'S RIGHTS

The User has right of access, rectification and opposition to his Personal Data, as well as a right to erasure under the conditions of the Applicable Regulations by contacting GROUPE SOS PULSE electronically as mentioned in Article 10 below.

The User has to send a demand to GROUPE SOS PULSE with a copy of an official identity document

When the User exercise his right to object, GROUPE SOS PULSE will stop Processing Personal Data, except in the event of legitimate and compelling reason(s) for the Processing or to ensure the establishment, exercise or defense of its rights in court in accordance with the Applicable Regulations. Where applicable, GROUPE SOS PULSE will inform the User of the reasons why his rights cannot be satisfied in whole or in part.

The User also has the right to recover his Personal Data in a structured, commonly used and machine-readable format in order to transmit them to another Process Supervisor conditional upon a demand from the User with a copy of an official identity document

The User has the right to provide GROUPE SOS PULSE with instructions concerning the fate of his Personal Data after his death.

When appropriate, GROUPE SOS PULSE will inform the User of the reasons why his rights cannot be satisfied in whole or in part.

7. DURATION OF RETENTION OF PERSONAL DATA

In accordance with the Applicable Regulations, Users' Personal Data will not be stored beyond the strictly necessary time for the purposes set out in Article 3 above.

In particular:

- The Personal Data collected to manage requests to oppose Processing are stored within a maximum period of 5 (five) years from the closing date of the opposition request;

- Personal Data Processed to manage requests for access and rectification of Personal Data are stored within a maximum period of 5 (five) years from the closing date of the opposition request;

- Personal Data relating to the management of interactions with GROUPE SOS PULSE contacts (particularly through the "Contact" section) are stored within a maximum period of 3 (three) years from the last interaction initiated by the User.

- Personal Data may be stored beyond the periods described above insofar as they are necessary for the purposes of research, the establishment and prosecution of criminal offences for the sole purpose of allowing, if necessary, the Personal Data to be available to the judicial authority or for other storage obligations, in particular for accounting or tax purposes. Archiving implies that these Personal Data will be subject to access restrictions and will be stored on an autonomous and secure support.

8. SECURITY

In accordance with the Applicable Regulations, GROUPE SOS PULSE processes Personal Data in complete security and confidentiality.

In particular, GROUPE SOS PULSE implements all technical and organizational measures necessary to guarantee the security and confidentiality of the Personal Data collected and Processed in order to prevent it from being distorted, damaged or communicated to unauthorized Third Parties, thus by ensuring a security level appropriated to the risks linked to Processing and to the nature of the Personal Data, regarding the technology level and the cost of implementation.

However, GROUPE SOS PULSE cannot guarantee the confidentiality of Personal Data made public by the User in the public areas of the website and Services.

The Website may include links to other Internet websites or external sources. The User acknowledges that the Charter only applies to the use of the website and Services. The Charter does not cover the information collected and/or Processed on external websites or sources whose link appears on the Website. Consequently, GROUPE SOS PULSE cannot be hold responsible for the practices of these external sites or sources in terms of collection and Process of Personal Data that governed, when applicable, by the specific personal data policies of each of these external websites or sources.

9. COOKIE POLICY

9.1 What is a cookie?

Among all Personal Data, GROUPE SOS PULSE may collect data resulting from the deposit of cookies.

A cookie is a small text, image or software file that is placed and stored on the User's computer or smartphone, as well as on any device enabling him to browse on the Internet ("Terminal").

Cookies allow a website to recognize the User and to signal his passage on such and such pages, and thus allow to provide him additional services such as: improving their browsing comfort, securing their connection or adapting the content of a page to his interests.

The information are recorded by the cookies for a limited period of time and mainly relate to the visited pages, the advertisements on which the User has clicked, the type of browser he uses, his IP address, the information his has entered on the Services (in order to avoid re-entering it).

Cookies are not active files and therefore cannot host viruses. For more information, please visit www.allaboutcookies.org.

9.2 What is the purpose of the cookies issued on the websites?

Only the issuer of a cookie can read or modify the information it contains.

Cookies are used for the purposes described below and are subject to your choices, which you can express and modify at any time via the parameters of the browser software used during your browsing on the websites (hereinafter the "Cookies").

9.2.1 Browser Cookies

Browser Cookies help improve the performance of GROUPE SOS PULSE in order to provide a better use of the website. These Cookies do not require the User's information or prior consent to be stored on the Terminal.

Browsing Cookies allow:

- to adapt the presentation of the websites to the display preferences of the Terminal (for example language used, display resolution, operating system used, etc.) during Users visits, depending on the hardware and viewing or reading software contained by the Terminal;

- to memorize the users’ preferences as well as the display and reading parameters they use in order to facilitate their next navigation on the websites. They notably allow access to a reserved area subject to an identifier or password;

- to memorize the information the users entered on different forms present on the website in order to avoid to fill them again.

9.2.2 Statistical Cookies

In order to adapt the websites to the User's needs, GROUPE SOS PULSE measures the number of visits, the number of pages consulted as well as the User's activities and their return frequency. These Cookies allow to establish statistics to analyze the number of visits, which allows to improve the content of the websites according to the success of a given page.

The results of these analyses are processed anonymously and exclusively for statistical purposes.

9.3 Period of validity of cookies

Cookies issued on the websites are session Cookies (whose duration is limited to the time of connection) and persistent Cookies (whose duration, however limited, is greater than the duration of connection).

Session Cookies are only active for the duration of the visit and deleted when the User closes his browser. Persistent Cookies remain stored on the hard disk of the User's Terminal even once the browser is closed.

As required by the Applicable Regulations and the recommendations of the Commission Nationale Informatique et Libertés ("CNIL"), Cookies are kept for a maximum period of 13 (thirteen) months after their first deposit. At the end of this period, the User's Consent must be collected again for the Cookies that are subject to expressed consent.

9.4 your choices regarding cookies

All the rights recognized in Article 6 above are also applicable to the User.

Several possibilities are offered to them to manage Cookies. The User understands that Cookies improve the comfort of navigation on the websites and are essential to access certain secure areas. Any settings that the User may make will be likely to modify his browsing on the websites and his conditions of access to certain services requiring the use of Cookies. GROUPE SOS PULSE shall not be held responsible for the consequences of a less efficient functioning of the websites, when it is due to the impossibility of installing or reading necessary Cookies once the User has rejected or deleted them.

Users can configure their browser software so that Cookies are saved in their Terminal or, on the contrary, rejected, either systematically or according to their issuer. Users can also configure their browser software so that they are offered the possibility of accepting or rejecting Cookies from time to time, before a Cookie is likely to be saved on their Terminal.

The help menu or the dedicated section of your browser will allow you to know how to express or modify your preferences regarding Cookies:

- For the Internet Explorer™ :

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

- For Safari™ :

https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

- For Chrome™ :

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

- For Firefox™ :

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

- For Opera™ :

https://help.opera.com/en/latest/web-preferences/#cookies

- For iOS :

https://support.apple.com/fr-fr/HT201265

- For Android:

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=fr

- For Blackberry:

https://global.blackberry.com/fr/legal/cookies

- For Windows Phone :

https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

For a better knowledge and control of Cookies of any origin and not only those of our website, the User is invited to consult the website Youronlinechoices, published by the Interactive Advertising Bureau France (IAB), in order to find out which companies are registered on this platform and which offer the possibility of refusing or accepting the Cookies they use to adapt the navigation information of the advertisements likely to be displayed on the Terminal http://www.youronlinechoices.com/be-fr/controler-ses-cookies.

10. CONTACT AND COMPLAINTS

For any request or in case of a disagreement between GROUPE SOS PULSE and the User concerning the Process of his Personal Data the User may send his request or complaint to GROUPE SOS PULSE at the following e-mail address: contact-rgpd.action-internationale@groupe-sos.org.

GROUPE SOS PULSE will endeavor to find a satisfactory solution to ensure compliance with the Applicable Regulations.

In the absence of a response from GROUPE SOS PULSE or if the disagreement persists despite the GROUPE SOS PULSE proposal, the User has the possibility of lodging a complaint to the CNIL or the supervisory authority of the European Union Member State in which the User is habitually resident and of mandating an association or organization mentioned in paragraph IV of Article 43 of the amended Law No. 78-17 of 6 January 1978.