PRIVACY POLICY
INTRODUCTION
The purpose of this document is to describe and inform you about how THUASNE, acting as Data Controller in the field of the Platform, undertakes to collect, use and protect your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), with all the required care and exclusively for the legitimate purposes for which they were collected.
If you have any questions regarding our privacy policy, please contact us at: partner-fr@thuasne.com.
The Data controller and responsible entity for processing your personal data is:
THUASNE SAS, a Company existing under the laws of France, with a share capital of 1 950 000 €, registered at the Nanterre Trade Register under N° 542 091 186
Having its Head Office at 120, rue Marius Aufan 92300 LEVALLOIS-PERRET, FRANCE.
1. DEFINITIONS
For the purposes of the Privacy Policy, the following terms are defined as follows:
“Platform”: refers to Thuasne Partner website and include all of its functionalities.
“Services”: refers to the functionalities offered by the Platform.
“Company”: refers to the overarching company the User is representing. The name of the Company that the Users represents.
“User(s)” or “You”: refers to professional customers or customer’s employees visiting, accessing the Platform and using the Services.
“we,” “us” and “our”: refers to THUASNE.
“Personal Data” or “Data” : refers to personal data as defined in article 4.1 GDPR.
“Platform”: refers to Thuasne Partner website and include all of its functionalities.
“Services”: refers to the functionalities offered by the Platform.
“Company”: refers to the overarching company the User is representing. The name of the Company that the Users represents.
“User(s)” or “You”: refers to professional customers or customer’s employees visiting, accessing the Platform and using the Services.
“we,” “us” and “our”: refers to THUASNE.
“Personal Data” or “Data” : refers to personal data as defined in article 4.1 GDPR.
2. DATA POLICY
In order to provide our Services, we need to collect Personal Data. These Data are stored on our servers or servers from our service providers. In this document we provide transparency about the Data we collect via the platform and how we use it to provide our Services.
3. PERSONAL AND COMPANY DATA
In order to provide our Services and to give you access to the Platform, we collect the following Data related to You:
· Business email address
· Business phone number
· Full name
· Function title in the Company
THUASNE generally collects Data about You that You agree to provide us directly, both from the Platform and via other channels
4. PURPOSES
Depending on the business relationship we have with you and/or the Company you are working for, we collect and use your Data for the following purposes:
· Conduct our business relationship with You or the Company (including sales contracts conclusion, customer relationship management, contact, send personalized messages and offers…)
· Create a profile of the Company and its employees to create user accounts, recommend products and provide service. We can use these Data to contact you in order to provide our Services.
· To improve our products and Services and more generally to give you access to the Platform and the Services.
5. LEGAL BASIS
The processing of your Data for the above-mentioned purposes is necessary for :
· the performance of the contract (to be) concluded between You and us (Art. 6.1 b GDPR) for example when You place an order;
· to respond to Our legitimate interest (Art. 6.1 f GDPR) for example to send You personalized messages and offers or to improve our products and Services.
6. LINKS TO OTHER WEBSITES
Our Platform contains links to others platforms or services both from the Thuasne Group and/or third parties. This Privacy Policy only governs the use of all content located on this Platform.
Make sure to read the privacy policy documentation of all external services and websites linked to the Platform. The Thuasne Group will not be held accountable for privacy protection on any external websites not managed by companies' part of the Thuasne Group.
7. RECIPIENTS AND DATA PROCESSOR
The Data we collect is intended for THUASNE’s internal services. However, we may share your Data when You use our Platform and Services, particularly when it is necessary for the management of the Platform and the provision of associated Services.
Under no circumstances will THUASNE transmit your Data to third parties for other commercial and/or promotional purposes without your consent. THUASNE reserves the right to transmit Data to subcontractors (service providers), for the purposes mentioned above, for example for the management, execution, processing of your orders and contracts, as well as for marketing operations, in compliance with current regulations and, exclusively in order to achieve the purposes described.
We also inform You that we may be required to transmit your data to the competent administrative or judicial authorities, at their request, if current regulations require it.
8. STORAGE AND PROCESSING
All Data collected is stored on servers located within the European Union.
However, We may be required to transfer your Data to subcontractors located outside the European Union, notably in the United States.
When we transfer your Data to our subcontractors located in the United States, we ensure that they have adhered to the EU-US Data Privacy Framework governing data transfers between the European Union and the United States, in accordance with the adequacy decision made by the European Commission on July 10, 2023.
In the event that one of our subcontractors is required to transfer your Data outside the European Union to a country that has not been the subject of an adequacy decision by the European Commission, we ensure that the latter undertakes to provide and implement security measures and a specific framework (Standard Contractual Clauses of the European Commission, BCR etc.).
9. DATA RETENTION PERIOD
The Data proceed under the execution of the agreement will be kept by THUASNE for the duration of the commercial relationship with the Customer and for 5 years as from December, 31 of the year during which the commercial relationship has ended in order to respect the applicable limitation period.
Data proceed to give You access to the Platform are removed after 3 years without any connexion to the Platform or any contact or action from You.
You also have the possibility to remove your account and Data by yourself from your customer area on the Platform.
In addition, You can also refuse to receive promotional information from THUASNE by clicking on the unsubscribe link at the bottom of our e-mail.
Before any Data can be deleted all invoices have to be satisfied and the eCommerce account must be closed.
We will need additional information to verify your identity before providing or deleting any personal or Company Data.
You also have the right to lodge a complaint with our Data Protection Officer or the national supervisory authority.
10. SECURITY
We are doing everything possible to protect your Data and prevent data breaches or hacks. In order to ensure the confidentiality, integrity, and availability of your Data, we implement a number of security measures including:
o The encryption of data transiting between your browser and our Platform, as well as those stored on our servers.
o We strive to maintain our Platform at an optimum level of security according to current recommendations.
o Rigorous access controls to Data strictly limited to THUASNE and its Data Processor or authorized third parties who need it in order to provide the Services. Specific access levels are defined based on the responsibilities of each individual.
However, we do not control all the risks associated with the operation of the internet and draw your attention to the existence of potential risks inherent in its use and operation. By accepting our Privacy Policy and using our Services, You acknowledge having been informed of this risk and agree to use our Services at your own risk. In case of a data breach, we will inform You via the contact details that You have provided, it may be your email address, your phone number or your postal address
11. COOKIES
This website is using cookies. A cookie is a small file that is placed by our webserver on your computer. These files are typically used to identify that computer and the user. Once you agree to allow our website to use cookies, you also agree to use the data it collects regarding your online behaviour (analyse web traffic, web pages you spend the most time on and websites you visit).
This data is collected by using cookies to:
· Keep you logged in across different sessions
· Optimise the website with the user data
· Save your preference across sessions
Please note that cookies do not allow us to gain control of your computer in any way. They are strictly used to identify your computer to provide the services as described above.
· Google Analytics 4
Cookie name | Service | Cookie type | Expiration date | Purpose |
_ga | Google Analytics | Tracking | 2 years | Used to distinguish users. |
_ga_* | Google Analytics | Tracking | 2 years | Used to persist session state. |
_Guide | Google Analytics | Tracking | 1 day | Used to distinguish users. |
· Hotjar
Cookie name | Service | Cookie type | Expiration date | Purpose |
_hjAbsoluteSessionInProgress | Hotjar | Tracking | 30 minutes | Used to detect the first pageview session of a user. |
_hjFirstSeen | Hotjar | Tracking | 30 minutes | Identifies a new user’s first session. Used by Recording filters to identify new user sessions. |
_hjIncludedInSessionSample_* | Hotjar | Tracking | 2 minutes | Set to determine if a user is included in the data sampling defined by your site's daily session limit. |
_hjSessionUser_* | Hotjar | Tracking | 1 year | Set when a user first lands on a page. Persists the Hotjar User ID which is unique to that site. Hotjar does not track users across different sites. |
_hjSession_* | Hotjar | Tracking | Durée : 30 minutes | Holds current session data. Ensures subsequent requests in the session window are attributed to the same session. |
· Thuasne
Cookie name | Service | Cookie type | Expiration date | Purpose |
Autorisations | Thuasne | Technical | 1 year | Allows to keep the user's choice on the cookies he has approved. |
connect.sid | Thuasne | Technical | Session | Allows to keep the session of the connected user. |
hasConsent | Thuasne | Technical | 1 year | Lets us know if the user has already approved cookies. |
Cookies can be removed at any time by visiting your web history and removing all data. You can also remove cookies specific to our website via most browsers. You can also prevent cookies from being placed by blocking cookies in your browsers. Since our websites relies on cookies to function, our website will no longer function properly.
We also use third-party cookies set by our partners. These third-party cookies are managed directly by the companies that issue them and must also comply with data protection regulations.
· Audience measurement cookies: to evaluate site traffic (number of visits, pages viewed, shopping cart abandonment, etc.) and improve our performance
· Advertising cookies: to provide you with advertising content related to your interest in the brand, the products, and our company.
12. QUESTIONS AND COMPLAINTS
In accordance with the provisions of Law No. 7817 of January 6, 1978, relating to data processing, files and freedoms and EU Regulation 2016/679 on data protection of April 27, 2016, You have the following rights:
• a right of access and rectification allowing You to modify, complete or update your personal data;
• a right to delete inaccurate, incomplete, ambiguous, outdated data;
• a right to object to the processing of your data for legitimate reasons;
• a right to object without reason, to the use of your data for prospecting purposes;
• a right to define directives relating to the fate of personal data after death;
• a right to data portability, in a structured, commonly used and machine-readable format;
• a right to limit processing, in the terms and conditions referred to in Article 18 of European Regulation No. 2016/679 of April 27, 2016;
• the right to lodge a complaint with the competent supervisory authority (the National Commission for Informatics and Freedoms - the “CNIL”). To learn more about your rights, you can find more information on the CNIL-website https://www.cnil.fr/fr/comprendre-vos-droits.
Excluding the right to complain to the CNIL, all of the aforementioned rights can be exercised at any time, by attaching proof of identity, to:
DPO Thuasne, 120 rue Marius Aufan, 92300 Levallois-Perret or at the following email address: dpo@thuasne.fr
13. MODIFICATION OF THE PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, so we invite You to consult it regularly. Changes and clarifications will take effect immediately after their publication on the website. If we make changes to the content of this policy, we will notify You here that it has been updated, so that you know what information we collect, how we use it, and under what circumstances we disclose it, if it is appropriate to do so.
Furthermore, it is specified that in case of contradiction or difference between the provisions of this version of the Privacy Policy and its French version made available on the Platform, the French version will prevail.