Legal Notices

Introduction

As part of its commercial activity, the publishing company Orixa Media processes information concerning you. For example, by filling out a registration form, making a purchase on our online services, registering for an event we organize, participating in a contest, browsing our websites or mobile and digital applications, clicking on an advertising link we present to you, you transmit information to us, some of which may identify you ("personal data").

This Privacy Policy informs you about how we collect and process your personal data. We invite you to read it carefully.

We only use your personal data in cases provided for by current regulations: The execution of a contract we have concluded with you, and/or Compliance with a legal obligation, and/or Your consent to the use of your data, and/or the existence of a legitimate interest to use your data. Legitimate interest is a set of commercial or business reasons that justify the use of your data by the publishing company Orixa Media. We never use your data for commercial purposes against your will. For any questions regarding this document, you can contact our data protection officer at dpo@orixa-media.com.

1. WHO IS RESPONSIBLE FOR THE PROCESSING MENTIONED IN THIS DOCUMENT?

The controller for the processing mentioned in this document is the publishing company Orixa Media, SAS with capital of €19,000, registered in the Paris trade and companies register under number 4943341133.

2. WHAT DATA DO WE COLLECT ABOUT YOU AND UNDER WHAT CIRCUMSTANCES DO WE COLLECT IT?

2.1. Data you transmit to us directly

During the various contacts we have with you, you may be required to communicate information concerning you. This is collected in particular when registering for a form, creating an account on our sites and applications, ordering our online services, or to access any other offer or service.

This data includes:

Last names, first names, title, date of birth;
Postal address, email address, telephone number;
Username and encrypted password used to identify you on our sites or applications;
Choices regarding commercial prospecting;
Any other information you wish to bring to our attention

2.2. Data we collect during our commercial relationship

The data we collect during our commercial relationship with you includes:

Information relating to the history of your commercial relationship with the publishing company Orixa Media: form registration, product and service orders, billing and payment where applicable;
Your participation in promotional offers, contests or events;
Information concerning purchases of products and services you have made from our partners.

2.3. Data we collect automatically

During each of your visits to our sites and applications, we collect information relating to your connection and navigation. Different technologies can be implemented to collect this data. The main one is the cookie.

Data collected through cookies

A cookie is a text file deposited when consulting a site, application or online advertisement and stored in a specific space on the hard drive of your computer or mobile device. Cookies are managed by your Internet browser and only the issuer of a cookie can decide to read or modify the information contained therein. A cookie has a limited validity period. Its deposit and storage on your terminal are done in compliance with applicable legislation and subject to the choices you have expressed and which you can modify at any time, under the conditions specified in article 9 below.

A cookie does not personally identify you. It allows its issuer to recognize your terminal and collect a certain amount of information relating to navigation performed from this terminal.

Cookies have several functions, such as allowing you to navigate efficiently on a site or application, remember your choices, goods and services you want to buy, offer you relevant advertising content based on your interests expressed during your navigation. You will find more information about cookies on the following sites:

Cookies deposited by the publishing company Orixa Media, subject to your choices, give us access to the following information:

Identifiers of the equipment you use (IP address of your computer, Android identifier, Apple identifier, etc.),
Type of operating system used by your terminal (Microsoft Windows, Apple OS, Linux, Unix, BeOS, etc.)
Type and version of browsing software used by your terminal (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.)
Dates and times of connection to our services
Address of the referring web page ("referrer"),
Navigation data on our services, content viewed.

Data collected by standard Internet technologies

We are also likely to use standard Internet technologies, such as scripts, pixels and redirects. Scripts (sometimes called tags), written in javascript language, are programs that run in your browser and perform different actions, for example sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs or Web-bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an email. Redirects make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

The purpose of these technologies is to improve your experience on our sites and applications, including to provide you with personalized content according to your interests. For example, when a user clicks on a share button for an article, a script creates a pixel that counts the share. Thus, we are able to know the total number of shares of an article, and we can establish the ranking of the most shared articles.

These technologies give us access to the following information:

Information relating to your use of our sites and applications;
Information relating to the presence of cookies on your terminal, on the time and date of consultation of a page, and a description of the page where the web beacon is placed;
Information on whether or not you read the emails we send you, on the clicks you make on the links contained in these emails.

Our sites and applications may also include scripts, pixels and redirects from third parties. These technologies allow third-party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites. These third-party service providers process the information they collect for auditing, research, and reporting purposes on our sites and applications and on advertisements viewed on them. We do not share your identification data with these third parties in connection with their use of these technologies.

Data provided by mobile devices

Certain mobile devices, depending on the features you have activated (for example: "Push" or "Geolocation") when downloading one of our applications, send information, including: model of your phone, version of its operating system, type of connectivity, name and version of the application used.

This data, necessary for the proper functioning of the mobile applications we publish, is automatically processed by our servers and those of some of our partners (including AT Internet, SmartAdServer, HockeyApp, Google Analytics...) to be able to provide you with a service and advertisements adapted to the technical characteristics of your device and measure the audience of our application.

Furthermore, if you have accepted this functionality when downloading our applications, we are able to identify the physical location of your device (geolocation), in particular to inform you about content or offers that we think are in line with your expectations or interests or to improve your experience on our mobile applications.

In accordance with applicable law, geolocation functions can be deactivated at any time in your device's system settings.

2.4. Data we assume

We are likely to establish, by comparing the data we have concerning you and general and anonymous statistical information, assumptions about content and services likely to meet your tastes or uses.

2.5. Data relating to minors

In principle, our products and services are intended for adults capable of entering into contractual obligations. Minor users must obtain the consent of their legal guardian prior to communicating personal data concerning them. For registration on our sites and certain of our online services (newsletter for example), the age of 16 is accepted.

An internet user under 18 years of age at the time of publication or creation of an online account benefits from a specific right to erasure of data concerning them. For any questions regarding this document, you can contact our data protection officer.

2.6. Data relating to a third party

Before offering a third party a subscription or any other product or service we market, you must ensure that the person concerned agrees that their personal data, including their postal details, be communicated to us.

2.7. Exclusion of any sensitive data

The publishing company Orixa Media does not collect any sensitive data concerning you. Sensitive data includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health data or sexual orientation. If such information were somehow communicated to the publishing company Orixa Media, it would be deleted.

3. FOR WHAT PURPOSES DO WE USE YOUR DATA?

This article indicates the main purposes for which we use the data mentioned in the article above.

3.1. Operations necessary for the provision of products or services

Taking into account your subscription to a subscription contract to our publications and execution of this contract;
Taking into account your order for products or services and execution of this order;
Management of subscriptions to our newsletters and/or email alerts;
Billing; collection of payments;
Management of deliveries and order tracking;
Customer relations: provision of a Customer Service accessible by mail, telephone, email, for any question or complaint;
Conducting satisfaction surveys;
Sending information on the modification or evolution of our services;
Management of unpaid bills and disputes;
Management of the exercise of your rights on your personal data, under the conditions provided for in article 9;
Verification of compliance with applicable legislation, our contracts and general conditions of use.

3.2. Marketing and commercial prospecting operations relating to publications, products and services of the publishing company Orixa Media

Postal standardization, updating, enrichment and de-duplication of your personal information in a dedicated database of the publishing company Orixa Media. Sending marketing, advertising and promotional offers relating to our products and services by postal mail, canvassing, email, mobile notifications, on social networks or any other medium; Personalized loyalty or commercial prospecting actions; Setting up contests or other promotional operations; Collection of customer opinions; Development of commercial statistics.

3.3. Operations related to commercial partnerships

Sharing, exchanging or renting files with commercial partners in compliance with current regulations and security requirements; Sending marketing, advertising and promotional messages relating to partner products and services by postal mail, canvassing, emails, mobile notifications, on social networks or any other medium; Setting up contests or other promotional or event operations with commercial partners.

3.4. Purposes associated with depositing cookies on your browser

Operation and optimization of navigation on our sites and applications

Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, according to the materials and visualization or reading software that your terminal includes;
Memorization of information relating to a form you have filled out on our site (registration or access to your account) or to products, services or information you have chosen on our site (service subscribed, content consulted, purchase made, etc.);
Automatic connection to reserved or personal areas of our site, such as your account, thanks to identifiers or data you have previously entrusted to us;
Provision of sharing tools on social networks;
Management of our platforms and carrying out internal technical operations as part of problem solving, data analysis, testing, research, analysis and surveys;
Implementation of security measures;
Quality measures to ensure that the display of our content is adapted to your device.

Measurement of traffic and audience

Establishment of statistics and volumes of traffic and use of the various elements making up our site (sections and content visited, paths) in order to improve the interest and ergonomics of our services;
Counting the total number of advertisements displayed by us on our advertising spaces, classification and statistics;
Analysis of audiences based on the results of advertising campaigns;
Determination of centers of interest and behaviors;
Improvement of customer/user knowledge for personalization purposes.

Personalization of advertisements present on our sites and applications

Adapt advertising spaces to the display preferences of your terminal (identification of advertisements, establishment of statistics and volumes of traffic and use of the various elements making up our site: sections and content visited, paths) in order to improve the interest and ergonomics of our services;
Adapt the advertisements displayed on your terminal when browsing our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your interests and uses (3), to the data you have previously communicated to us (4), where applicable, to the geographical location data of your terminal (5);
Recognize you to display personalized advertisements on social networks;
Measure the effectiveness of our advertising campaigns and service proposals.

4. HOW LONG DO WE KEEP YOUR DATA?

Your personal data is kept for a period in accordance with legal provisions or proportional to the purposes for which it was recorded. Certain retention periods respond to the legitimate interest of the publishing company Orixa Media as specified in the introduction. Retention periods vary depending on whether we have an ongoing contractual relationship (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we have never had such a relationship with you (you are then a prospect). Data related to your navigation on our online services collected by cookies you have authorized have a specific retention period. In any case, we regularly review the information we hold. When their retention is no longer justified by legal, commercial requirements or related to the management of your customer account, or if you have exercised a right of modification or erasure, we will delete them securely.

5. WHO IS LIKELY TO HAVE ACCESS TO THE DATA WE COLLECT?

5.1. Access to data within the publishing company Orixa Media

The following are likely to have access to some of your data: Employees of the services: customer relations, administrative, accounting and management control, IT and marketing & commercial. Access to your data is based on individual and limited access authorizations. Personnel who can access personal data are subject to a confidentiality obligation (by a nominal and personal confidentiality commitment).

5.2. Data transmission

The following are likely to have access to some of your data:

Subcontractors

Securing online payments and fighting fraud
Managing telephone calls, sending postal or digital mail
Personalizing content on sites and mobile applications
Carrying out maintenance operations and technical developments
Collecting customer opinions
Providing analytical solutions or audience measurement statistics

Our subcontractors' access to your data is based on signed contracts mentioning the obligations incumbent on them regarding the protection of data security and confidentiality.

Social network platforms

The use of social networks to interact with our sites and applications (including Facebook, Twitter, Google + "share" buttons) is indeed likely to lead to data exchanges between the publishing company Orixa Media and these social networks. We therefore invite you to consult the personal data management policies of the different social networks to learn about the collections and processing they carry out on your data.

Our commercial partners

They promote products or services on their own behalf or on behalf of advertising advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our commercial partners and let them access some of your information, particularly by connecting to their sites or applications, their privacy policies and their cookie deposits are enforceable against you. We have no control over the collection or processing of your data implemented by our commercial partners on their own platform.

Police authorities, judicial or administrative authorities

When we have a legal obligation to do so or to guarantee the rights, property and security of the publishing company Orixa Media.

6. IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We keep your personal data in the European Union. However, it is possible marginally that the data we collect when you use our platforms or in the context of our services may be transferred to subcontractors or commercial partners located in other countries, some of which may have legislation on the protection of personal data that is less protective than that in force in the country where you reside. 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 framed by the standard contractual clauses of the European Commission which guarantee a sufficient level of protection of privacy and fundamental rights of persons.

7. HOW IS YOUR DATA PROTECTED?

As data controller, we implement appropriate technical and organizational measures in accordance with applicable legal provisions, to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorized access, and in particular:

The appointment of a data protection officer;
Securing information systems;
Raising awareness of confidentiality requirements among our employees who have access to your personal data;
Securing access to our premises and IT platforms;
Securing access, sharing and transfer of data;
High level of requirements regarding data protection when selecting our subcontractors and partners.

8. WHAT ARE YOUR RIGHTS?

8.1. Your rights regarding access to your personal data

You have the right to access your personal data and to request that it be rectified, completed or updated. You can also request the erasure of your data or object to their processing, provided you justify a legitimate reason. You can request to exercise your right to data portability, that is, the right to receive the personal data you have provided to us in a structured, commonly used format and the right to transmit this data to another data controller. You can finally formulate directives relating to the conservation, erasure and communication of your personal data after your death.

You can exercise your rights with the data protection officer of the publishing company Orixa Media at the following email address: dpo@orixa-media.com.

Before responding to your request, we may verify your identity and/or ask you to provide us with more information to respond to your request. We will endeavor to respond to your request within a reasonable time and, in any case, within the deadlines set by law. In case of unsatisfactory response, you can file a complaint with the National Commission for Information Technology and Civil Liberties (CNIL): https://www.cnil.fr/fr/plaintes

8.2. Your rights regarding opposition to commercial solicitations

We are likely to use your contact details in the context of commercial solicitations, in compliance with applicable law and the clauses of this privacy policy. You can at any time object to these solicitations, according to methods that depend on the communication channel we use to address them to you.

Commercial solicitations by electronic means (email and SMS):

We respect the rules of article L.34-5 of the postal and electronic communications code which provides for the prior and express collection of your consent for sending commercial prospecting by electronic means (email, push notifications or SMS).

Thus, on the forms you fill out when you subscribe to one of our products or services, when you create an account on our sites or applications, or on the occasion of any other contact with us, you are expressly asked for your consent: to receive offers from the publishing company Orixa Media to receive offers from partners of the publishing company Orixa Media

Exception: your express and prior consent is not mandatory when you are already a customer/registered on one of the sites of the publishing company Orixa Media and the purpose of our solicitation is to offer you products or services similar to those we already provide you.