Introduction
U10 pays close attention to respect of privacy and undertakes to protect the security and confidentiality of personal data collected.
Consequently, U10 falls within the remit of law no. 78-17 of 6th January 1978 pertaining to data protection and freedom of information, amended by law no. 2004-801 of 6th August 2004 and then by (EU) Regulation 2016/679 the General Data Protection Regulation of 27th April 2016 which became effective as at 25th May 2018 (hereinafter referred to as the “GDPR”), which sets forth the principles to be respected at the time of collection, processing and storage of personal data and adapted by law no. 2018-493 of 20th June 2018 on personal data.
U10 has, consequently, implemented this Data Protection Charter which is aimed at informing you of all processing activities pertaining to use of your Data.
We wanted to draft a streamlined Charter so as to provide you with clear and transparent information as to the manner in which your personal data is collected, processed and used.
Definitions
„Collect“ refers to the collection of personal data. This collection may notably be undertaken using online questionnaires or forms.
„Consent“ refers to any free, specific, enlightened and unequivocal expression of acceptance by which you agree, by way of a declaration or clearly positive action, that your personal data be processed.
„Personal Data“ refers to any information directly or indirectly identifying a natural person (for instance, a name, postal or email address, telephone number, photograph, date of birth, or IP address are all forms of Personal Data).
„We“, „Us“, „Our“ refer to U10 and/or Service Providers who may, under certain conditions outlined hereunder, be led to collect, use, store or share Personal Data created or modified at the time of accessing or using Our Services.
„Service Provider(s)“ refers to any company which may be led to process Data on Our behalf, pursuant to Our instructions.
„Regulation“ refers to all of the provisions in force applicable to processing Personal data and, notably the GDPR as defined in the introduction, the data protection and freedom of information act no. 78-17 of 6th January 1978 as amended by law no 2004-801 of 6th August 2004 pertaining to the protection of natural persons in light of personal data processing and law no. 2018-493 of 20th June 2018 pertaining to personal data.
„Site“ refers to all services proposed by U10, in their online, mobile and tablet version, accessible by a wireless or wired network, from a browser or app, independent of the means used for access.
„You“, „Your“, „User“ refers to any natural person who accesses the services or uses any of Our Services governed by this Data Protection Charter.
1. Our commitments concerning Data we collect
U10 faithfully and transparently collects Personal data of any natural person having accepted to send their data.
U10 refrains from collecting Personal data without informing the people concerned.
U10 collects data with the purpose of rendering those services requested by the natural person who sends his Personal data and to respond to management requirements.
U10 provides information as to the use of Data collected.
U10 oversees the pertinence of Personal data collected to ensure a quality services whilst respecting individuals.
U10 informs web users of the fact that cookies and other tracing tools are stored on the Sites it publishes.
2. What Data do we collect?
Personal data refers to Data which allows you to be identified, such as surname and given names, postal or email addresses, login and password information, landlines/mobile telephone numbers, age, sex, invoicing or transaction data, bank details or any other financial data, the manner in which you want to be contacted as well as any other similar data.
You may be led to provide Personal data, notably when You complete a form on the Site, when You subscribe to a newsletter, or when You make a purchase. Some Personal data is compulsory to use some of Our Services. Other data, which is optional, allows you to occasionally receive information or commercial offers, subject to granting your consent.
3. When and why do we collect information about you?
Data collected is required notably so as to create and manage your account, respond to your requests, send you information or establish statistics.
U10 may use the Date you provide, including personal Data:
If you are a shareholder:
- to keep you informed of General Meetings and send you documents required for voting in resolutions;
If you are a client:
- to assist you in completing a transaction or delivering you the products or services requested;
- to invoice products or services purchased;
- to provide you with continued service and support and exchange with you about any problems encountered;
- to fulfil our obligations or ensure respect of our rights resulting from any contract signed with you;
- to inform you of any changes made to our Websites, applications, products or services;
- to improve our Websites, applications, services and products, notably by generating Data analysis and reports on their use by Users such as You or any other person;
- to send you an email, or communicate with you by any other means, with commercial prospection or promotions on products or services of U10 likely to interest you;
- for any other purpose for which you provide this Data;
- to register you in our internal sales management tool;
- in any other manner that we indicate when you provide your Data;
If you are a Website User:
- to process elements provided in the contact form accessible on the U10 Site. Use of this information has the sole purpose of establishing contact with the User having entered Data online. Said User may be contacted by telephone and/or email. Processing of this Personal Data is based on the consent of the User.
U10 undertakes not to use your Personal Data for any other purposes than those for which provision is made herein.
4. Communication of Personal Data
Your Data is processed by U10. This Data will not be sold or made accessible to any third party subject to providers and service providers of U10 and/or any subsidiary for reasons which are purely technical or logistical.
Recipients of your Data may be located abroad, including outside of the European Economic Area. Any transfer of your Data outside of the European Economic Area is undertaken in return for the appropriate guarantees, notably contractual, in compliance with Data Protection Regulation applicable.
This Data will not be communicated to any external party other than those indicated hereinabove and only to fulfil legislative and regulatory obligations, or at the request of any administrative or legal authority, to respond to national security requirements, combating fraud or application of any law.
5. What measures are taken to secure Personal Data?
U10 takes all security measures adapted to the level of sensitivity of Personal Data to guarantee protection against any malicious intrusion, loss, alteration or disclosure to unauthorised third parties.
U10 issues authorisations to access its information system solely to those people who require access to perform their activities.
U10 informs its employees of the protection of Personal Data provided in the framework of their functions and ensures that they respect rules in force and the code of ethics in operation within the firm.
U10 imposes the obligation that its service providers comply with its security principles.
6. What is the term of storage of Data?
Your Personal Data is stored for as long as necessary to fulfil the objective sought by its collection. For instance, when you place an order, we store Personal Data allowing us to perform the contract which you specifically accepted, during a sufficient period to process or respond to claims, or information requests concerning the purchase.
U10 stores Data for the term of contractual relations increased by one (1) year.
U10 may use Data collected for electronic communication pertaining to its offers, news and events. Each time electronic communication is sent and notably for commercial purposes, the recipient of the communication has the option of no longer receiving this in future thanks to an unsubscription link. Users may, at any time, choose to no longer receive commercial communications by sending an email to the following address dpo@u10.fr so as to request that they no longer receive emails.
Your Data will also be deleted within a maximum term of one (1) month from your request for unsubscription and this may be extended to two (2) months in line with the complexity and number of requests.
Your Personal Data may also be stored for longer by virtue of specific legal obligations or in light of terms of legal prescription applicable.
In the framework of combating fraud and counterfeit, U10 attaches a great deal of importance to the protection of its brands, products, expertise and image. In this framework, U10, in parallel and in collaboration with public authorities, pools all information pertaining notably to counterfeit, which it may detect or which is reported to it, concerning brands and products it holds, or any other infringement of its image rights. In this framework, U10 may be led to collect and process a certain amount of Personal Data concerning people suspected of committing such infringements or involved in such matters as well as people witnessing such infringements. This information is only stored for the necessary requirements and duration for verification of the facts detected or reported and then, where necessary, to take legal action or so as to bring a definitive end to the case.
7. How can you access, amend or delete Data?
You have a right to access, amend, rectify, delete and object for any legitimate ground excluding the specific case of commercial prospection, the right to limit processing, the right to withdraw your consent, the right to set out directives pertaining to the future of your Personal Data after death and, in certain cases, the right to portability allowing you to ensure that this information is sent to the person concerned or a third party over your data at any time.
Request of this nature should be made by email to the following address: dpo@u10.fr or by recorded delivery letter outlining the content of the claim sent to the Data Protection Officer at the following address:
U10
1 Place Verrazzano
CP 610
69258 Lyon Cedex 09
For any question in relation with the collection and processing of your Data by U10, you can contact us at the following email address: dpo@u10.fr or by post by writing to the above postal address and sent to the Data Protection Officer.
U10 undertakes to respond to questions as soon as possible and within a maximum of one (1) month after receipt in the event of a request for deletion. This may be extended by two (2) months in line with the complexity and number of requests.
If your request cannot be accepted, U10 will inform you of the reasons within a maximum of one (1) month.
Moreover, all messages sent to you include an option to object to subsequent processing of Data for commercial purposes. You can unsubscribe from the issue of publicity messages at any time by clicking on the unsubscribe link at the bottom of publicities sent electronically.
If you have a U10 client account, you also have the option of accessing, amending, correcting and deleting Personal Data directly via the „my U10 client space“ page in your account(https://auth.U10/Account/Login). In this area you can also amend your consent to receive communications and/or offers from U10.
Finally, it is reiterated that you are entitled to make a claim with a control authority and notably the National Data Protection Authority (CNIL) (https://www.cnil.fr/fr/plaintes).
8. How are cookies managed?
- What is a cookie?
A cookie is a small text file which is stored on the Workstation (computer, tablet or other device connected to the Internet) of the User and stored on the hard disk at the request of the server managing the Website visited. It includes information about browsing undertaken on Website pages.
Users may deactivate these cookies via browser settings.
Cookies have multiple uses: they may be used to memorise your client password, to trace your browsing history for statistical or publicity purposes.
We use various cookies to improve interactivity of the Website, its operation and our services.
- In concrete, how do cookies work?
In your computer, the browser (Internet Explorer, Firefox, Chrome, Safari, etc.) which manages cookies and receives the order to store these from the server (the principle of cookies is part of the HHTP protocol used for Web exchanges).
It stores these and enables them to be controlled in line with web user preferences. It is also possible to prohibit any storage of cookies (but access to many sites, or at least the use of their functions, is then impossible). Browsers allow these to be located, listed and even deleted. Even if you do not delete them, they will disappear as they have a maximum lifetime of thirteen (13) months.
A cookie does not identity you. Generally, it stores information pertaining to browsing on your computer on our Website which we can read during subsequent visits. Consequently, it is not necessary to once more complete forms we have requested that you complete.
- Terms of storage of cookies on Websites operated by U10:
During browsing by the User on the Website operated by U10 (other than login information, pages consulted and IP addresses), the term of storage of cookies is thirteen (103) months maximum from their last storage date.
- Consent:
No cookie will be stored on the User Workstation insofar as it has not given its consent, with the exception of cookies exempt from consent insofar as they are strictly necessary for provision of a service requested expressly by the User.
An information strip informs Users of the presence of cookies on the Website and offers it the option to accept or refuse cookies.
The term of validity of consent of cookies is increased to thirteen (13) months.
Users may, at any time, accept or refuse use of cookies and modify their preferences.
So as to manage the storage of cookies on the Website operated by U10, the User may manage settings on the Website in question.
- How can you accept/refuse the overall use of cookies?
Browser settings:
You can authorise or refuse the storage of cookies on your workstation with the appropriate browser settings. Here is how to set up the acceptance of cookies with the most commonly used browsers:
For Internet Explorer™ : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ;
For Safari™: https://support.apple.com/kb/ph21411?locale=fr_CA ;
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™ : http://help.opera.com/Windows/10.20/fr/cookies.html ;
Use of a cookie management platform:
Users may decide to refuse behavioural publicity by using the tool provided on this website (http://www.youronlinechoices.com/fr/). Cookies stored in the event of using share buttons are also included on this platform.
9. How do social networks use your Personal Data?
Websites using plug-ins (or extension modules) on social networks, notably Facebook and Twitter (hereinafter referred to as „Social Networks“).
If you interact on the Websites using these plug-ins, for instance by clicking on the „Like“ or „Share“ buttons, your browsing information and your access to these social networks will be sent, stored and processed on a server operating the Social Network concerned and attached to your User account, in line with its terms and conditions of use.
If you do not want your personal information to be sent from the Website to the social networks, we advise in this instance:
- that you not interact with these social networks by clicking on the plug-ins available on the Websites;
- deactivate your account on the social network in question before browsing on our Websites;
- browse in „Private“ mode via your browser;
What type of personalised publicity do we undertake?
In line with your browsing data and purchase history, personalised publicity banners may be displayed during your browsing on the Websites.
If you do not wish that we use your browsing history and/or purchase history for targeting and distributing publicity, you can set up your cookies or refer to terms and conditions to deactivate targeted publicities visible in the banner.
10. Modification of the Personal Data Charter
U10 may be led to amend this Charter. We hereby invite you to regularly check this page so as to ensure you agree with any modification. We are also likely to inform you of any modifications to this Charter by email.