T&C
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Capitalized terms not defined below have the meanings given in the general terms and conditions of use of the website www.havea.com.
This privacy policy allows us to present to Users in a clear and precise manner what personal data may be collected when browsing the Website www.havea.com.
We are committed to respecting the privacy of Users. Therefore, we set out below the conditions under which the personal data of Users, when browsing the Website, are likely to be subject to Processing of their Data.
I. Definitions
« Data » : any information relating to an identified or identifiable natural person (as defined by the GDPR);
« GDPR » : means the European Regulation on the Protection of Personal Data n°2016/679 of April 27, 2016;
« RT » ou « we » : means the Host;
« Processing » : means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” (GDPR definition)
« User(s) » ou « you » : means any natural person(s) who browses the Website and accesses its features and content.
II. Data Collection
1. Le moment de la collecte des Données
This privacy policy applies to all Data that you communicate to us or that we collect, directly or indirectly, in particular by:
- Browsing the website ;
- Subscribing to the newsletter ;
- Requesting any information, in particular via the Website contact form.
When the collection of specific Data is necessary for the associated Processing, we indicate the mandatory fields with an asterisk. Your Data may also have been collected from third parties, subject to having obtained your consent in advance.
2. Details of Data processing
The table below allows you to have an overview of the Data processed by the RT, the purposes of Data Processing as well as the legal basis of said Processing.
| Processing | Data collected | Purpose of data processing | Legal basis(s) for data processing |
| Management of commercial communications (including newsletters) | Email Last name First name | This data will allow us to:
| User Consent Legitimate interest |
| Management of Internet user knowledge, statistics and performance of the Website | Connection data Navigation data Last name First name | Ces données vont nous This data will allow us to :
| Legitimate Interest User Consent |
| The management of all types of requests (in particular through the contact form) | Civility Last name First name Full postal address Telephone number | All information transmitted concerning you (including health data) This data will allow us to :
| User Consent Legitimate interest Legal obligation |
| Online navigation management | Connection data Navigation data | This data will allow us to :
| User Consent Legitimate interest |
In addition, we may use certain techniques referred to as “profiling”, namely, any form of automated processing of personal data consisting of using the Data collected to analyze and evaluate certain personal aspects relating to a natural person, in particular to analyze and/or deduce, via dynamic segmentation, the development of scenarios, audiences, certain elements and/or behaviors relating in particular to personal preferences, interests, etc.
On the basis of these analyses and deductions, we send you and/or display communications and/or content (concerning HAVEA GROUP and its subsidiaries) tailored to your interests/needs that we have identified. It is also possible that automated decisions are made based on profiling, in particular we may use this type of process to determine whether or not it is relevant to send you certain communications.
You have the right, in certain circumstances, to object to the use of your data for “profiling” purposes. In this case, please refer to point 7 below.
3. The destination of the Data
The Data subject to Processing is intended for the internal teams of the RT (and its subsidiaries) and possibly to the service providers that the RT may call upon (considered as subcontractors within the meaning of the GDPR). The Data may be transmitted to third-party service providers to whom we entrust your Data to carry out commercial or marketing missions on our behalf (in particular web analytics, advertising agencies as part of the implementation of marketing and commercial campaigns). Some service providers may contact you in order to send you commercial offers as well as satisfaction surveys in order to assess the quality of their service. If you wish to object to this, we invite you to contact the said service providers directly at the initiative of these sendings.
In addition, the Data could also be transmitted to any police, judicial or administrative authorities (within the framework of a legal obligation or the legitimate interest of the RT).
4. Minors’ Data
The Website is accessible to any person, whether an adult or a minor. However, the prior consent of the holder of parental authority is required for minors under the age of fifteen whose Data would be processed by the RT.
5. Data Retention
Your Data is retained for a period of time that complies with legal provisions or is proportional to the purposes for which it was processed. Certain retention periods may meet the legitimate interest of the RT.
For example:
- All prospect data is kept for three (3) years from the collection or the last contact from the prospect;
- Browsing data is kept for a maximum of thirteen (13) months.
Archiving in an intermediate database is also possible for administrative reasons, in particular in matters of litigation, commercial, civil or even tax, in the context of compliance with a legal obligation.
In any event, when their retention is no longer justified by legal, commercial, marketing requirements or linked to the legitimate interest of the RT or if the User has exercised a right of modification or deletion or opposition (except in the case of retention for the purposes of compliance with a legal obligation), we anonymize or delete them securely.
6. Transfer of your Data
We store your Data within the European Union. However, it is possible that the Data may be transferred to subcontractors and/or partners located in other countries, particularly outside the European Union. In the event of such a transfer, we ensure that the Processing is carried out in accordance with this privacy policy and that it is governed by the standard contractual clauses of the European Commission, which guarantee a sufficient level of protection of the Data and allow respect for the privacy and fundamental rights of individuals.
7. The methods for exercising User rights
In accordance with the regulations on the protection of personal data (and in particular the GDPR), you have the right to access, rectify, erase, oppose, limit and port your Data. You also have the possibility of formulating directives concerning the fate of your Data after your death.
To exercise these rights, simply send a formal, written and complete request accompanied by any element allowing your identification (identity document, customer number, etc.) using the following reception methods:
- By email: dpo@havea.com;
- Via the contact form (if existing); or
- By post: HAVEA GROUP – Service Consommateurs – Parc d’activité Sud Loire, 85612 Montaigu Cedex.
The precise terms and conditions relating to the exercise of your rights are mentioned in the GDPR and also on the CNIL website.
Before responding to any request, we may verify your identity and/or ask you to provide us with more information to respond to your request.
Upon receipt of any written and complete request, we undertake to respond to any request within one (1) month, this period may be extended by two (2) months in the event of a complex request.
In the event that we have not responded satisfactorily to your request, a complaint may be filed with the National Commission for Information Technology and Civil Liberties (CNIL) via its website https://www.cnil.fr/fr/.
8. Data Security
As RT, we implement appropriate technical and organizational measures in accordance with the applicable legal provisions, to protect your Data against alteration, accidental or illicit loss, use, disclosure or unauthorized access.
9. Changes to the Privacy Policy
We may occasionally modify this Privacy Policy (in particular for reasons of legislative or regulatory changes). Users are therefore advised to regularly consult this page to learn about any changes or updates made to this Privacy Policy.
III. Applicable law and attribution of jurisdiction
This Privacy Policy is governed by French law.
In the event of a dispute and in the absence of an amicable agreement, the User may refer the matter to either one of the courts with territorial jurisdiction under the Code of Civil Procedure, or to the court of the place where he or she resided at the time of the conclusion of the contract or the occurrence of the damaging event.