Confidentiality Charter

1. Preamble and scope of application

This confidentiality charter (hereinafter, the “Charter”) allows you to know how and why the CESP, which publishes the internet site https://www.cesp.org (hereinafter, the “Site”), collects, processes and protects your personal data.

 

This Charter also lists all of your rights and details the means that you possess to manage the use that we make of your personal data.

 

We attach fundamental importance to the protection of your privacy and we make an effort to offer you a service that is fully in compliance with the strict legislative and regulatory framework relating to the protection of privacy and personal data resulting from the provisions of the General Data Protection Regulation No. 2016/679/EU of 27 April 2016 which entered into force on 25 May 2018 (hereinafter, the “GDPR” or the “Regulation”), the law No. 78-17 of 6 January 1978 in its last version in force (the “Data Protection Act”) as well as its application decrees or orders.

 

This Charter applies to all processing of personal data that we implement, as data controller, with regard to any user of the Site, whether this is a simple visitor or a member of the CESP (“You”).

 

Finally, when you use our Site, you may see content containing links to third party web sites (for example, to the digitaladtrust.fr platform). We inform and alert you that we have no control over the cookies or the other functions used by these third party web sites and that the processing of personal data that they may implement is not governed by this Charter.

 

 

2. The controller responsible for the collection and processing of the data on the Site

The data controller for your personal data is:

The Centre d’Étude des Supports de Publicité

A non-profit association governed by the French law of 1 July 1901

With its registered office located at 55 rue Anatole France in Levallois-Perret (92300)

Siret No. 775 690 589 00079

Tel.:  01.40.89.63.60

e-mail: cesp@cesp.org

 

The representative of the data controller is Mr Gérard Noel.

 

 

 

3. Acceptance of our confidentiality rules

By connecting to, using, viewing or by creating an account on our Site, you are declaring that you have read, understood and agreed to be bound by this Charter, without any limitation or reservation. Also, if you do not agree with any of its terms, you may decide not to use our Site or our services, and you must not in any event communicate your personal data to us.

 

 

4. Types of information collected

Our activity makes it necessary to collect certain of your personalised information. However, in the context of providing our services, we scrupulously observe the principle of minimisation, which means that we undertake only to collect the data that are strictly necessary for the purposes defined in paragraph 6 below.

 

              4.1 In the event of a request for information via the “Contact” heading on our Site

 

In connection with a request for information, we collect the personal information appearing in our contact form, namely: your name, e-mail address, the subject of the message and any comments that you make.

 

 

              4.2 At the time of a request for membership

 

In the event that you request to become a member, whether in order to access the audits or to participate in our colleges, we collect the personal information that you have agreed to communicate to us, namely, the company name and address of your company, the full name and e-mail address of the contact at your company.

 

              4.3 When creating your account on the Site as a member

 

When creating your member space on the Site, we collect the personal information that you have agreed to communicate to us, namely, your company name or full name, e-mail address, mobile or landline telephone number and postal address.

 

             4.4 At the time of an on-line application via our heading “Recruitment”

 

When you decide to apply on-line via the heading “Recruitment” on our Site, we collect your full name, e-mail address, telephone number and, potentially, your CV.

 

              4.5 When subscribing to our newsletter

 

In connection with subscribing to our French or international newsletter, we only collect your e-mail address.

 

4.6 When downloading a document from the « Lab CESP » on our website

 

When you download a document from the « Lab CESP », we only collect your name and email address.

 

              4.7 When viewing the Site

 

When viewing our Site, cookies are deposited on your computer, your mobile phone or your tablet.

 

A cookie (or a tracer) is a proof of connection consisting of a text file that a web site may store on your computer, your tablet or your mobile phone at the time of your first connection.

It allows the issuing web site to identify the terminal on which it was recorded throughout the period for the registration or the validity of the cookie. It does not damage either the computers or the files and cannot, as such, be used to discover the identity of the internet user. Note that the cookies are managed by your internet browser.

The use of the Site may cause cookies to be deposited on your connection terminal. The cookies that we use are principally intended to store your session information on our server, to perform statistics, particularly in order to measure the audience of the Site and to improve your browsing experience.

 

As this concerns primarily cookies that are strictly necessary, they are essential for the correct operation of the Site and may not be deactivated from our systems. They are generally only activated in response to actions that you carry out and which correspond to a request for services, such as the configuration of your confidentiality preferences, the connection to the Site or completing forms. Your browser may be configured to block or to alert you to the use of these cookies. However, if this category of cookies, which do not store any personal data, is blocked, certain parts of the Site cannot function.

 

With regards to performance cookies, these allow us to determine the number of visits and the sources of traffic to our Site in order to measure this and to improve performance. They allow us to identify the pages that are more or less visited and to assess how internet users navigate the Site. The information collected by these cookies is aggregated and thus is anonymised. If this category of cookies is not accepted, it will be impossible for us to know when you visited our Site.

 

Finally, with regards to functionality cookies, these allow us to improve the functionalities and the personalisation of our Site and, more specifically:

 

=> if you deposit a comment on our Site, it will be suggested that you register your name and e-mail address in order to avoid having to input this information again if you deposit other comments later. These cookies will be destroyed upon the expiration of a period of one year after they are deposited on your terminal;

 

=> if you have a membership account and you connect to our Site, a temporary cookie will be created in order to determine whether your browser accepts cookies. It does not contain any personal data and will be deleted automatically when you close your browser;

 

=> at the time of connecting to your membership area, a certain number of cookies will be put in place which allow your connection information and your screen preferences to be recorded. It is noted that the lifespan of a connection cookie is two days and that the lifespan of a screen option cookie is one year. Moreover, if you decide to check the box “remember me,” the connection cookie will be retained for two weeks. Finally, if you disconnect from your account, the connection cookie will be deleted;

 

=> by modifying or publishing content, an additional cookie will be recorded in your browser. This cookie does not contain any personal data, but it only indicates the ID of the content that has been modified. It expires at the end of 24 hours.

 

Naturally, you will be informed of the existence of the cookies and their purposes as of your first connection to the Site by the presence of an information banner placed on the top of the home page. You may then decide whether to accept them by clicking on “I accept” or you may refuse them. You may deactivate the cookie function by configuring your browser. As the functions for each browser are different, we invite you to refer to the “Help” section in your browser for more information on how to refuse or deactivate the use of cookies.

 

 

5. Optional or mandatory character of the data collection

In our on-line forms, the mandatory fields are marked with an asterisk. If they are not completed, the CESP will not be able to respond to your request. The fields in a form which are not mandatory are left to your discretion; it is up to you whether or not to complete them.

 

 

6. Purposes of the collection

The processing that we implement complies with legitimate, explicit and clearly determined purposes. Your personal data may thus be processed only for the purposes set out below, which are justified by one of the legal bases provided for by the applicable regulations in terms of data protection:

 

• in order to allow us to process your requests for information or your on-line job applications and, more generally, to respond to all of your questions concerning our membership terms or our services. The processing thus relies on your consent (Article 6-1-a of the GDPR). Naturally, as provided for in Article 7 of the GDPR, it will be possible for you to withdraw your consent at any time, without this withdrawal compromising the lawfulness of the processing based on the consent made before this withdrawal;

• for the management of the relationship with our members (monitoring the relationship, access to the member space, accounts monitoring and the performance of the administrative tasks). In this connection, the processing shall be justified by the performance of the membership agreement;

• for any other use that may improve our offers and the operation of our Site. We consider that it is in our legitimate interest to ensure that our Site satisfies the expectations of our members to the extent possible, in order to preserve and develop our activity. Naturally, this goal shall be pursued without any harm to your rights and liberties;

It is specified that your personal data shall not be processed later in any manner that is not compatible with the purposes described above. If a use of your personal data is planned in any manner other than as set out above, your express advance consent shall naturally be requested.

 

7. Recipients of the Collected Data

Your personal data collected on the Site are addressed, within the limit of their attributes, to the internal services of the CESP and to its sub-contractors, and to the partners of the CESP if you have consented to that.

 

The recipients of your personal data are, more specifically, the following:

 

When viewing the Site:

 

– the internal services of the CESP;

– the companies operating the social networks whose plug-ins appear on the Site;

– the internal services of the CESP;

– the service providers and sub-contractors acting for the correct performance of the membership agreement, and in particular:

 

=> for the hosting of personal data: we use the services of the company OVH, whose confidentiality policy is accessible at the address: https://www.ovh.co.uk/files/2018-06/plaquette-gdpr-web-EN-FINAL.pdf

 

These trusted service providers shall process your personal information on our behalf, according to our instructions, and in accordance with the terms of this Charter. These third parties shall only have access to your personal data in order to perform the purposes established at the time of collecting such data and shall moreover be held to the same obligations of confidentiality and security as the CESP.

 

Finally, in accordance with the applicable legal provisions, we may have to disclose your personal data if:

 

• we are required to do so by law or by regulations or if this disclosure is made necessary for the correct performance of an inquiry or an administrative or court procedure of any nature, whether in France or abroad;
• a merger or an acquisition of all or part of the CESP is to be conducted by a third party, and which you accept;
• we need to protect ourselves against any harm to the rights or the property of the CESP, including the need to have this Charter observed.

 

8. Storage of the data

Your personal data are retained for a period limited to the performance of the purposes for which they were collected and processed. Your personal information may however be retained for a longer period so that we can comply with our legal obligations and in particular the applicable statutes of limitation. Obviously, we encourage you to delete such data upon the expiration of these various periods:

 

• the data collected in connection with requests for information shall be retained for the period necessary to process such requests and, in any event, for a maximum period of twelve (12) months following your request in the absence of establishing a contractual relationship;

• the data relating to your membership as your payments shall be retained for the entire duration of our contractual relationship, namely as long as the contact remains active. The closure of your member account shall then result in the deletion of all of the personal data allowing you to be identified. However, we may retain certain of your personal data for a period after the closure of your user account in order to satisfy our legal, accounting and tax obligations, within the limit of the applicable statutes of limitations. Obviously, in this case, if the contact becomes inactive, your personal data will be deactivated and will no longer be accessible on-line, but will be retained solely in the form of archives;

• if necessary, throughout the duration of litigation and until all appeals have been exhausted.

 

9. Security of your personal data

The protection of your privacy is of major importance for the CESP and we have put in place technical and organisational measures to limit any type of incident that may cause the unauthorised destruction, alteration, modification, access or disclosure of the personal data that we hold.

 

Obviously, our sub-contractors have also deployed appropriate measures to ensure the security and the integrity of your personal data.

 

From the organisational point of view, we have limited the number of persons who have access to your personal data. Their access is limited to employees and service providers of the CESP who have a need for this access in order to perform their assignments. All persons who have access to your personal data are bound by a confidentiality obligation and are subject to sanctions if they do not comply with their obligations.

 

However, even though we ensure an appropriate level of security, considering the current state of knowledge and the purposes of the processing as well as the probability of risk, no measure of security is infallible and it is impossible for us to guarantee you absolute security. Also, we invite you to choose a password that is sufficiently protective when you create your member account on our platform and not to communicate this to anyone. If your computer is shared, do not forget to disconnect or to change your session before leaving our service.

 

 

10. What are your rights and how to exercise them?

In accordance with the applicable regulations, and in particular Articles 15 through 22 of the GDPR and Articles 48 through 56 of the Data Protection Act of 6 January 1978 in its latest version, provided that you present proof of your identity, you may at any time exercise:

 

• a right of information and access which allows you, for example, to verify the data that we retain concerning you;
• a right to rectification and erasure. You may thus require that the information concerning you that is inaccurate, incomplete, ambiguous or expired be rectified, completed, clarified, updated or erased;
• a right to restriction of processing;
• a right to portability. You have the right to have returned to you the personal data that you provided or, when this is technically possible, to have them transferred to a third party;
• a right to object any processing;
• a right to erasure;
• a right to give instructions concerning the later processing of your personal data after your death;
• a right to withdraw your consent. For example, if you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time. This withdrawal does not affect the lawfulness of the processing operations carried out before this;
• a right not to be subject to an automated individual decision, including profiling.

For more information, we invite you to visit the internet site of the Commission Nationale de l’Informatique et des Libertés (the French Data Protection Authority).

 

You may exercise the rights listed above at any time by contacting us at the e-mail address: cesp@cesp.org or by post at the following address: CESP – 55 rue Anatole France – 92300 Levallois-Perret.

 

We undertake to respond to you within a period of one month after receiving your request, but we reserve the possibility to extend this period by two months because of complexity or the number of requests. You will then be informed of the postponement within a period of one month after we receive your request.

 

In the event of a challenge or a disagreement, you have the possibility to bring a claim before a supervisory authority such as the CNIL either:

– directly on-line: www.cnil.fr;

– by letter: CNIL – 3 Place de Fontenoy – 75007 Paris

 

 

11. Your personal data and the social networks 

The Site uses plug-ins for social networks, particularly Facebook, Twitter, LinkedIn, YouTube

 

In the case of interactions on the Site by means of these plug-ins, the information relating to your use of the Site and your membership in these social networks will be transmitted, recorded and processed on a server of the company operating the social network in question and connected with your user account, according to the conditions proposed by it.

 

If you do not wish for your personal information to be transmitted from the Site to the social network, we recommend that you:

– avoid any interaction with these social networks by clicking on the plug-ins accessible on the Site;

– deactivate your account on the social network in question before using our Site;

– use the “Private” mode on your browser.

 

 

12. Updating and modification of our Charter

Considering the constant legislative and regulatory changes in terms of the protection of privacy and with regard to the development of our Site and its settings, or for any other legitimate reason, we reserve the right to update this Charter at any time.

 

In this event, the date of updating the Charter shall appear at the top of this document. It is thus recommended that you consult it regularly.

 

If we make changes to our confidentiality rules that we consider substantial, you will naturally be kept informed of this by means of an advisory published on our Site, as well as by sending an e-mail to the address that you have

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