− PERSONAL DATA AND COOKIES –

1- INTRODUCTION

As part of its commercial activity, SCEA MICHEL BOUTIN is required to process information concerning you. For example, by browsing our website or our mobile and digital applications, by filling out a newsletter subscription form, or by clicking on an advertisement link that we present to you, you transmit information to us, some of which is capable of identifying you (“personal data”).

This Privacy Policy informs you of 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 current regulations:

• The performance of a contract we have entered into 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. Legitimate interest is a set of commercial or business reasons that justify the use of your data by SCEA Michel BOUTIN.

For any questions regarding this document, you may contact the data protection officer of SCEA Michel BOUTIN (click: email contact@domainesboutin.fr).

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

The data controller mentioned in this document is the company Michel BOUTIN SCEA, registered with the Pau Trade and Companies Register under number 320 167 984 00022, with its registered office located at 330 Route de la Chapelle de rousse, 64290 GAN.

The data protection officer for SCEA Michel BOUTIN is Mr. Michel BOUTIN.

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

3.1 Data you transmit directly to us

During our various interactions with you, you may be required to provide us with information concerning you. This information is collected, in particular, when you subscribe to a newsletter, create an account on our website and application, or access any other offer or service.

This data includes your email address and any other information you wish to bring to our attention.

3.2 Data we collect during our commercial relationship

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

• Your participation in promotional offers, contests, or events;
• Requests you have made to our community manager or incidents you have reported to us, for example, concerning the performance of our services;

3.3 Data we collect automatically

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

• Data collected via cookies

A cookie is a text file placed when you consult a website, application, or online advertisement and stored in a specific area of your computer’s hard drive 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 placement and storage on your device are carried out in compliance with applicable legislation and subject to the choices you have expressed, which you can modify at any time, under the conditions specified in Article 9 below.

A cookie does not identify you personally. It allows its issuer to recognize your device and collect a certain amount of information related to the browsing 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 browsing. You will find more information about cookies on the following websites:

www.cnil.fr

www.allaboutcookies.org

www.aboutcookies.org

www.youronlinechoices.eu

Cookies placed by SCEA Michel BOUTIN , subject to your choices, give us access to the following information, in particular:

– Identifiers of the equipment you use (IP address of your computer, Android ID, Apple ID, etc.),

– Type of operating system used by your device (Microsoft Windows, Apple OS, Linux, Unix, BeOS, etc.),

– Type and version of the browsing software used by your device (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),

– Dates and times of connection to our services,

– Referring internet page address (“referrer”),

– Browsing data on our services, content viewed.

• 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 are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs, or web bugs) are lines of code that allow a graphic image (usually invisible) to be displayed on a web page or in an email. Redirects allow a web page 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 improve your experience on our websites and applications, including providing 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 allows the share to be counted. This way, we are able to know the total number of shares for an article, and we can establish a ranking of the most shared articles.

These technologies give us access to the following information, in particular:

• Information related to your use of our websites and applications;
• Information related to the presence of cookies on your device, the time and date a page was viewed, and a description of the page where the web beacon 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 these emails.

Our websites and applications may also include third-party scripts, pixels, and redirects. 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 to report information on our websites and applications and on advertisements viewed on them. We do not share your identifying data with these third parties as part of their use of these technologies.

• Data provided by mobile devices

Certain mobile devices, depending on the features you have enabled (for example: “Push” or “Geolocation”) when downloading one of our applications, send information, including: your phone model, its operating system version, connectivity type, and the 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) to provide you with a service and advertisements adapted to the technical characteristics of your device and to measure the audience of our application.

Furthermore, if you have accepted this feature when downloading our applications, we are able to identify the physical location of your device (geolocation), particularly to inform you about content or offers that we believe 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.

3.4 Data we infer

By cross-referencing the data we have about you with general and anonymous statistical information, we may make inferences about content and services that are likely to match your tastes or usage patterns.

Example: If, according to statistical data, a majority of people aged 30 to 50, living in Pau and interested in website creation, are also passionate about social networks, and you are a 42-year-old business owner or merchant who regularly consults articles on our site related to our activity, we will infer that you are also interested in e-marketing, and we will be able to show you an advertisement for an affiliate service while you browse our site.

3.5 Data related 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 for some of our online services (e.g., newsletter), the age of 16 is accepted.

An internet user under the age of 18 at the time of publishing or creating an online account benefits from a specific right to the erasure of data concerning them. For any information, please contact the data protection officer of SCEA Michel BOUTIN (Click: email address contact@domainesboutin.fr).

3.6 Data related to a third party

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

3.7 Exclusion of all sensitive data

SCEA Michel BOUTIN does not collect any sensitive data concerning you. Sensitive data is considered to be: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, or sexual orientation. If such information were communicated to us in any way, it would 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 Article 3.

4.1 Operations necessary for the provision of products or services

• Management of subscriptions to our newsletters and/or email alerts;
• Customer relations: provision of a community manager accessible by email for any questions or complaints;
• Conducting satisfaction surveys;
• Sending information on the modification or evolution of our services;
• Management of the exercise of your rights over your personal data, under the conditions provided for in Article 9;
• Verification of 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 SCEA Michel BOUTIN

• Postal standardization, updating, enrichment, and deduplication of your personal information in a database dedicated to SCEA Michel BOUTIN ;
• Sending information about our company, its publications, and its activity;
• Sending marketing, advertising, and promotional offers related to our products and services via postal mail, inserts, email, mobile notifications, social networks, or any other medium;
• Personalized loyalty or commercial prospecting actions;
• Setting up contests or other promotional operations;
• Collection of customer reviews;
• Development of commercial statistics.

4.3 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 related to partners’ products and services via postal mail, inserts, emails, mobile notifications, social networks, or any other medium;
• Setting up contests or other promotional or event-based operations with commercial partners.

4.4 Purposes associated with placing cookies on your browser

• Operation and optimization of browsing on our websites and applications

• Adaptation of the presentation of our websites and applications to your device’s display preferences (language used, display resolution, operating system, etc.) during your visits, according to the hardware and viewing or reading software on your device;
• Memorization of information related to a form you have filled out on our site (registration or account access) or to products, services, or information you have chosen on our site (service subscribed to, content viewed, purchase made, etc.);
• Automatic connection to reserved or personal areas of our site, such as your account, using identifiers or data you have previously entrusted to us;
• Provision of social media sharing tools;
• Management of our platforms and execution of internal technical operations for problem resolution, data analysis, testing, research, analyses, studies, and surveys
• Implementation of security measures;
• Quality measures to ensure that the display of our content is adapted to your device.

• Traffic and audience measurement

• Establishment of statistics and volumes of traffic and usage of the various elements composing our site (sections and content visited, user journeys) to improve the interest and ergonomics of our services;
• Counting the total number of advertisements displayed by us in our advertising spaces, ranking, and statistics;
• Audience analysis based on advertising campaign results;
• Determination of interests and behaviors;
• Improvement of customer/user knowledge for personalization purposes.

• Personalization of advertisements on our websites and applications

• Adapt advertising spaces to your device’s display preferences (identification of advertisements, establishment of statistics and volumes of traffic and usage of the various elements composing our site: sections and content visited, user journeys) to improve the interest and ergonomics of our services;
• Adapt the advertisements displayed on your device when browsing our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your interests and usage (3), to the data you have previously provided to us (4), and, where applicable, to the geographical location data of your device (5);
• Recognize you to display personalized advertisements on social networks;
• Measure the effectiveness of our advertising campaigns and service offerings.

5- HOW LONG DO WE RETAIN YOUR DATA?

Your personal data is retained for a period compliant with legal provisions or proportionate to the purposes for which it was recorded. Certain retention periods align with the legitimate interest of SCEA Michel BOUTIN t as specified in the introduction.

Retention periods vary depending on whether we have an ongoing contractual relationship with you (you are an active client), whether we have had a contractual relationship with you in the past (you are an inactive client), or whether we have never had such a relationship with you (you are then a prospect). Data related to your browsing on our online services, collected by cookies you have authorized, have a specific retention period.

The table below outlines the main retention periods for your data.

In any event, we regularly review the information we hold. When its retention is no longer justified by legal, commercial, or client account management requirements, or if you have exercised a right to modification or erasure, we will securely delete it.

Data Categories	Purposes	Retention Periods
Data related to a prospect
All data	Creation and management of a prospect file	3 years from data collection or the last contact from the prospect
Data related to an active client
All data	Client account management	For the entire duration of the contractual relationship
Data related to an inactive client
Identification and contact data – Newsletter subscribers	Sending information on the evolution of our publications and our offers	Maximum 3 years from unsubscription or the last contact from the client
Data generated by cookies
Data related to your browsing on our online services	Operation and optimization of services Audience measurement. Content and advertisement personalization	Maximum 13 months
Inferred data
Data related to your inferred usage and interests	Sending information and offers inferred to match your interests and usage	Annual update

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

6-1 Access to data within SCEA Michel BOUTIN

Employees from the administrative, accounting and management control, IT, community management, and marketing & sales departments may have access to some of your data.

Access to your data is based on individual and limited access authorizations. Personnel 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 also have access to some of your data:

• Subcontractors

They provide services on our behalf, including:

• Management of telephone calls, sending postal or digital mail
• Personalization of website and mobile application content
• Execution of maintenance operations and technical developments
• Collection of client reviews
• Provision of analytical solutions or audience measurement statistics

Our subcontractors’ access to your data is based on signed contracts that specify their obligations regarding the protection of data security and confidentiality.

• Social media platforms

The use of social networks to interact with our sites and applications (notably the “share” buttons for Facebook, Twitter, Google+) may indeed lead to data exchanges between SCEA Michel BOUTIN and these social networks. For example, if you are logged into the Facebook social network and you view a page on the SCEA Michel BOUTIN website, Facebook may collect this information. Similarly, if you view an article on the SCEA Michel BOUTIN website and click the “tweet” button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social networks to be aware of the data collection and processing they perform on your data.

• Our business partners

They promote products or services on their own behalf or on behalf of advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our business partners and allow them access to some of your information, particularly by connecting to their sites or applications, their privacy policies and cookie deposits are applicable to you. We have no control over the collection or processing of your data implemented by our business 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, assets, and security of SCEA Michel BOUTIN.

7- IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We store your personal data in France. In all cases, we ensure that processing is carried out in accordance with this privacy policy and is governed by the European Commission’s standard contractual clauses, which guarantee a sufficient level of protection for privacy and fundamental rights of individuals.

8- HOW IS YOUR DATA PROTECTED?

As data controllers, 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:

• The appointment of a Data Protection Officer;
• The establishment of a unit dedicated to information system security;
• Raising awareness among our employees who access
  your personal data about confidentiality requirements;
• Securing access to our premises and IT platforms;
• The implementation of a general IT security policy for the company;
• Securing data access, sharing, and transfer;
• A high degree of data protection requirement 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 to request that it be rectified, completed, or updated. You may also request the erasure of your data or object to its processing, provided there is a legitimate reason.

You may request to exercise your right to data portability, meaning 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.

Finally, you may issue directives regarding the retention, erasure, and communication of your personal data after your death.

You can exercise your rights with the Data Protection Officer at SCEA Michel BOUTIN, 330 Route de la Chapelle de Rousse, 64290 GAN or by email: contact@domainesboutin.fr

Before responding to your request, we may verify your identity and/or ask you to provide further information to fulfill your request. We will endeavor to respond to your request within a reasonable timeframe and, in any event, within the deadlines set by law.

In case of an unsatisfactory response, you may lodge a complaint with the National Commission for Information Technology and Liberties (CNIL).

9.2 Your rights regarding objection to commercial solicitations

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

• Commercial solicitations by electronic means (e-mail):

We comply with the rules of Article L.34-5 of the French Post and Electronic Communications Code, which provides for the prior and express collection of your consent for sending commercial prospecting by electronic means (e-mail, push notifications, or SMS).

However, your express and prior consent is not mandatory when you are already a client of SCEA Michel BOUTIN and the purpose of our solicitation is to offer you products or services similar to those we already provide to you.

In all cases, you always have the option to object to receiving these solicitations by clicking on the unsubscribe link provided in each email.

• Commercial solicitations on mobile applications

Upon first opening SCEA Michel BOUTIN mobile applications on your smartphone or tablet, you may authorize the reception of mobile or “push” notifications. These notifications allow us to communicate editorial content (news alerts, content highlighted by the editorial team), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in your smartphone settings.

9.3 Your rights regarding cookie acceptance and management

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

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

How to exercise your choices?

1. Make your choices in your browser

You can configure your browser software either so that you are prompted to accept or refuse cookies on a case-by-case basis, before a cookie may be stored, or to systematically accept or refuse the storage of cookies on your device.

We alert you to the fact that any setting in your browser software concerning the refusal of technical and functional cookies may impair your browsing comfort on our websites, or even prevent the use of some of our services that require the use of these same cookies.

Where applicable, we disclaim all responsibility for the consequences related to the degraded functioning of our websites and services resulting from our inability to store or consult the cookies necessary for their operation that you may have refused or deleted.

For managing cookies and your choices, the configuration of each browser is different. It is described in your browser’s help menu, which will inform you how to modify your cookie preferences.

• Microsoft Internet Explorer

http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

• Microsoft Edge

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

• Apple Safari

http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

• Google Chrome

http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

• Mozilla Firefox

http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

• Opera
  http://help.opera.com/Windows/10.20/fr/cookies.html

• Flash Cookies from Adobe Flash Player

Adobe Flash Player is a computer application that enables the rapid development of dynamic content using the Flash computer language. Flash (and similar applications) stores the settings, preferences, and usage of this content using a technology similar to cookies. However, Adobe Flash Player manages this information and your choices through an interface different from that provided by your browser software.

Insofar as your device may display content developed with the Flash language, we invite you to access your Flash cookie management tools directly from the website https://www.adobe.com/fr.

• “Do not track”

You can also configure your browser to send a code indicating to websites that you do not wish to be tracked (“Do not track” option).

Microsoft Internet Explorer

http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11

Microsoft Edge

https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy

Apple Safari

http://support.apple.com/kb/PH11952

Google Chrome

https://support.google.com/chrome/answer/114836?

Mozilla Firefox

https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister

Opera

http://help.opera.com/Windows/12.10/fr/notrack.html

1. Make your choices online

For audience measurement cookies and analytical cookies

Analytical cookies allow us to obtain anonymous traffic statistics for our site to optimize it and detect potential malfunctions. They are placed on our sites and applications by Google Analytics, ATInternet (XiTi), Parse.ly, Weborama, ACPM.

If you do not wish for our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links where you will find additional information:

– Google Analytics Cookies

https://tools.google.com/dlpage/gaoptout

– ATInternet Cookies

https://www.atinternet.com/societe/protection-des-donnees/mettre-a-jour-mes-preferences/

– Parse.ly Cookies

https://www.parse.ly/privacy-policy/

– Weborama Cookie

https://weborama.com/fr/respect-de-la-vie-privee/

ACPM Cookie

(awaiting Médiamétrie link)

For “Social Network” cookies

We use Facebook, Twitter, Pinterest, Google+, and LinkedIn share buttons.

To manage your data on Facebook

https://www.facebook.com/help/cookies/

To manage your data on Twitter

https://support.twitter.com/articles/20170518-utilisation-des-cookies-et-des-technologies-similaires-par-twitter

To manage your data on Pinterest

https://policy.pinterest.com/fr/cookies

To manage your data on Google+

https://policies.google.com/privacy?hl=fr#infochoices

To manage your data on LinkedIn

https://www.linkedin.com/legal/cookie-policy

Disabling these cookies therefore prevents any interaction with social networks.

For advertising cookies

We use the Doubleclick and SmartAdserver platforms to manage advertising displays on our websites.

To manage Doubleclick cookies

https://www.google.com/settings/u/0/ads/authenticated

To manage SmartAdserver cookies

http://www.smartadserver.fr/privacy-policy

We also use the Ligatus platform to offer article reading based on popularity criteria and your interests, as well as sponsored articles.

To learn more about interest-based targeting

A propos de la publicité comportementale

To disable this targeting technology

https://www.ligatus.com/fr/privacy-policy

You also have the option to connect to the website http://youronlinechoices.com, offered by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France.

This European platform is shared by hundreds of online advertising professionals and provides a centralized interface allowing you to express your refusal or acceptance of cookies used by these companies to tailor advertisements displayed on your device based on your browsing information:

http://www.youronlinechoices.com/fr/controler-ses-cookies/.

Finally, some cookies are placed by third-party providers for personalized advertising purposes. You can also click on the following links to learn more about their practices and exercise your choices:

– Rubicon Cookies

http://www.rubiconproject.com/privacy/consumer-online-profile-and-opt-out/

– DoubleClick for Publisher Cookies

https://www.google.com/settings/u/0/ads/authenticated

– AppNexus Cookies

http://appnexus.com/en/company/platform-privacy-policy-fr

– Weborama Cookie

https://weborama.com/fr/respect-de-la-vie-privee/

– Index Exchange Cookie

http://www.indexexchange.com/privacy/