Privacy Policy

1. INTRODUCTION

As part of its business activities, the publishing company Orixa Media is required to process information about you. For example, by filling out a registration form, making a purchase on our online services, signing up for an event we organize, participating in a contest, browsing our websites or our mobile and digital applications, or clicking on an advertisement link we present to you, you provide us with information that 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.

Important
We only use your personal data in cases provided for by the applicable 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 in using your data.

The legitimate interest is a set of business reasons that justifies 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.

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

The responsible party for the processing mentioned in this document is the publishing company Orixa Media, SAS with a capital of €19,000, registered in the Paris Trade and Companies Register under number 4943341133.

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

3.1. Data you provide us directly

During our various contacts with you, you may be required to provide us with information about yourself. This information is collected notably when registering for a form, creating an account on our sites and applications, placing an order for our online services, or accessing any other offer or service.

This data includes:

Last name, first name, title, date of birth;
Postal address, email address, phone number;
Encrypted username and password used to identify you on our sites or applications;
Choices regarding commercial prospecting;
Any other information you wish to share with us.

Data we collect during our business relationship

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

Information related to the history of your business relationship with the publishing company Orixa Media: registration for a form, orders for products and services, if applicable billing and payment;
Your participation in promotional offers, contests, or events;
Information regarding the purchases of products and services you have made with our partners.

3.3. Data we collect automatically

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

Data collected through cookies

A cookie is a text file placed during the consultation of a site, application, or online advertisement and stored in a specific area of your computer's hard drive or your 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 placement and storage on your device are done in compliance with applicable legislation and subject to the choices you have expressed and that 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 device and collect a certain amount of information related to the navigation performed from that device.

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

The cookies placed by the publishing company Orixa Media, subject to your choices, give us access to the following information:

Identifiers of the equipment you are using (IP address of your computer, Android identifier, Apple identifier, etc.);
Type of operating system used by your device (Microsoft Windows, Apple OS, Linux, Unix, BeOS, etc.);
Type and version of the browser software used by your device (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.);
Dates and times of connection to our services;
Address of the referring webpage;
Navigation data on our services, viewed content.

Data collected by standard Internet technologies

We may also use standard Internet technologies, such as scripts, pixels, and redirects. Scripts (sometimes called tags), written in JavaScript, are programs that run in your browser and perform various actions, such as sending information to our servers. Scripts can also create pixels. Pixels (sometimes called transparent GIFs, clear GIFs, or web bugs) are lines of code that allow displaying a graphic image (generally invisible) on a webpage or in an email. Redirects allow a webpage to be 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 enhance your experience on our sites and applications, including providing you with personalized content based on your interests. For example, when a user clicks on a share button for an article, a script creates a pixel that allows counting the share. Thus, we can 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 related to your use of our sites and applications;
Information related to the presence of cookies on your device, the time and date of consultation of a page, and a description of the page where the web tag is placed;
Information on whether or not the emails we send you are read, and on the clicks you make on the links contained in those 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 webpage that redirected you to our websites. These third-party service providers process the information they collect for auditing, research, and reporting information on our sites and applications and on the advertisements viewed on them. We do not share your identifying data with these third parties in the context of 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 (notably AT Internet, SmartAdServer, HockeyApp, Google Analytics...) to provide you with a service and advertisements tailored to the technical characteristics of your device and to measure the audience of our application.

Furthermore, if you accepted this feature when downloading our applications, we can identify the physical location of your device (geolocation), notably to inform you about content or offers that we believe match your expectations or interests or to improve your experience on our mobile applications.

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

3.4. Data we assume

We may establish, by correlating the data we have about you and general and anonymous statistical information, assumptions about the content and services that may meet your tastes or uses.

3.5 Data related to minors

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

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

3.6. Data related to a third party

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

3.7. Exclusion of any sensitive data

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

4. FOR WHAT PURPOSES DO WE USE YOUR DATA?

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

4.1. Operations necessary for the provision of products or services

Taking into account your subscription to a contract for our publications and executing this contract;
Taking into account your order for products or services and executing this order;
Managing subscriptions to our newsletters and/or email alerts;
Billing; collecting payments;
Managing deliveries and tracking orders;
Customer relations: providing a customer service accessible by mail, phone, email, for any questions or complaints;
Conducting satisfaction surveys;
Sending information about changes or developments in our services;
Managing unpaid bills and disputes;
Managing the exercise of your rights regarding your personal data, under the conditions provided in Article 9;
Verifying compliance with applicable legislation, our contracts, and general terms of use.

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

Postal standardization, updating, enriching, and de-duplicating your personal information in a dedicated database of the publishing company Orixa Media. Sending marketing, advertising, and promotional offers related to our products and services by postal mail, email, mobile notifications, on social networks, or any other medium; Personalized loyalty or commercial prospecting actions; Organizing contests or other promotional operations; Collecting customer feedback; Developing commercial statistics.

4.3. Operations related to commercial partnerships

Sharing, exchanging, or renting files with commercial partners in compliance with applicable regulations and security requirements; Sending marketing, advertising, and promotional messages related to the products and services of partners by postal mail, email, mobile notifications, on social networks, or any other medium; Organizing contests or other promotional or event operations with commercial partners.

4.4. Purposes associated with the placement of cookies on your browser

Functioning and optimization of navigation on our sites and applications

Adapting the presentation of our sites and applications to the display preferences of your device (language used, display resolution, operating system, etc.) during your visits, according to the hardware and software for viewing or reading that your device has;
Remembering information related to a form you filled out on our site (registration or access to your account) or to products, services, or information you selected on our site (subscribed service, content viewed, purchase made, etc.);
Automatic connection to the reserved or personal areas of our site, such as your account, using identifiers or data you previously provided to us;
Providing sharing tools on social networks;
Managing our platforms and performing internal technical operations in the context of problem resolution, data analysis, testing, research, studies, and surveys;
Implementing security measures;
Quality measures to ensure that the display of our content is suitable for your device.

Measuring attendance and audience

Establishing statistics and volumes of attendance and use of the various elements of our site (sections and content visited, paths) to improve the interest and ergonomics of our services; Counting the total number of advertisements displayed by us on our advertising spaces, ranking, and statistics; Analyzing audiences based on the results of advertising campaigns; Determining interests and behaviors; Improving customer/user knowledge for personalization purposes.

Personalizing advertisements on our sites and applications

Adapting advertising spaces to the display preferences of your device (identifying advertisements, establishing statistics and volumes of attendance and use of the various elements of our site: sections and content visited, paths) to improve the interest and ergonomics of our services; Adapting the advertisements displayed on your device during your navigation on our sites and applications to its technical characteristics (1), to your previous navigation choices (2), to your interests and uses (3), to the data you previously communicated to us (4), if applicable, to the geographical location data of your device (5); Recognizing you to display personalized advertisements on social networks; Measuring the effectiveness of our advertising campaigns and service proposals.

5. HOW LONG DO WE KEEP YOUR DATA?

Your personal data is kept for a duration that complies with legal provisions or is proportional to the purposes for which it was recorded. Some 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 the 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, or account management requirements, or if you have exercised a right of modification or deletion, we will securely delete them.

6. WHO MAY HAVE ACCESS TO THE DATA WE COLLECT?

Access to data within the publishing company Orixa Media

The following may have access to some of your data: Employees from the following departments: customer relations, administration, accounting and management control, IT, and marketing & sales. Access to your data is based on individual and limited access permissions. Staff who can access personal data are subject to a confidentiality obligation (through a nominal and personal confidentiality commitment).

6.2. Data transmission

The following may have access to some of your data:

Subcontractors

They provide services on our behalf, including:

Securing online payments and combating fraud;
Managing phone calls, sending postal or digital mail;
Personalizing content on websites and mobile applications;
Performing maintenance and technical development operations;
Collecting customer feedback;
Providing analytical solutions or audience measurement statistics.

Access to your data by our subcontractors is based on signed contracts that specify their obligations regarding data security and confidentiality.

Social media platforms

Using social media to interact with our sites and applications (notably the "share" buttons from Facebook, Twitter, Google+) may indeed 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 various social networks to be aware of the collections and processing they perform on your data.

Our commercial partners

They promote products or services for their own account or for 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 allow them to access some of your information, notably by connecting to their sites or applications, their privacy policies and cookie placements are applicable to 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 are legally obliged to do so or to guarantee the rights, property, and security of the publishing company Orixa Media.

7. ARE YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We keep your personal data within the European Union. However, it is possible 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 data protection legislation 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 that guarantee a sufficient level of protection of privacy and the fundamental rights of individuals.

8. HOW ARE YOUR DATA PROTECTED?

As the responsible party for processing, 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, including:

Appointing 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 our IT platforms;
Securing access, sharing, and transferring data;
High standards of data protection when selecting our subcontractors and partners.

9. WHAT ARE YOUR RIGHTS?

9.1. Your rights regarding access to your personal data

You have the right to access your personal data and request that it be rectified, completed, or updated. You can also request the deletion of your data or object to its processing, provided you justify a legitimate reason. You can request to exercise your right to data portability, which 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 also formulate directives regarding the retention, deletion, 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 additional information to respond to your request. We will strive to respond to your request within a reasonable time and, in any case, within the time limits set by law. In case of an unsatisfactory response, you can file a complaint with the National Commission for Information Technology and Civil Liberties (CNIL): https://www.cnil.fr/fr/plaintes.

9.2. Your rights regarding opposition to commercial solicitations

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

Commercial solicitations by electronic means (email and SMS):

We comply with the rules of Article L.34-5 of the Postal and Electronic Communications Code, which requires prior and express consent for sending commercial prospecting by electronic means (email, push notifications, or SMS).

Thus, on the forms you fill out when subscribing to one of our products or services, when creating an account on our sites or applications, or during 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 the partners of the publishing company Orixa Media.

Exception: your express and prior consent is not required 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.

In any case, you always have the option to oppose receiving these solicitations by taking the following actions: For email, by clicking on the unsubscribe link provided in each email.

Commercial solicitations on mobile applications

When you first open the mobile applications of the publishing company Orixa Media on your smartphone or tablet, you can give permission to receive mobile or "push" notifications. These notifications allow us to communicate editorial content (news alerts, content highlighted by the editorial team) and may occasionally be used for commercial offers. You can disable these notifications at any time in your smartphone settings.

Commercial solicitations by phone

We may contact you by phone to offer you products or services. If you do not wish to be solicited, you can register on the list opposing telemarketing accessible on the site www.bloctel.gouv.fr.

Solicitations by any other means

We invite you to contact our customer service to inform them that you do not wish to be subject to these solicitations.

9.3. Your rights regarding the acceptance and management of cookies

The recording of a cookie on your browsing device is subject to your will. You can modify your choices regarding the acceptance or refusal of cookies placed on your device at any time, either on your browser or online with various operators.

To manage cookies as closely as possible to your wishes, we invite you to configure your browser taking into account the purpose of the cookies.

How to exercise your choices?
→ Make your choices on your browser

You can configure your browser software either to propose the acceptance or refusal of cookies to you on a case-by-case basis, before a cookie is likely to be recorded, or to systematically accept or refuse the recording of cookies on your device. We alert you that any configuration on your browser software regarding the refusal of technical and functional cookies may impair your browsing comfort on our websites, or even prevent the use of certain services requiring the use of these same cookies.

If applicable, we decline any responsibility for the consequences related to the degraded functioning of our websites and services resulting from our inability to record or consult the cookies necessary for their functioning that you would have refused or deleted.

For managing cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies.