– PERSONAL DATA AND COOKIES –

1- INTRODUCTION

Within the framework of its commercial activity, the EARL Domaine Capdevielle is brought to treat information concerning you. For example, by browsing our website or our mobile and digital applications, by filling out a form to subscribe to a newsletter, by clicking on an advertising link that we present to you, you send us information, some of which is likely to identify you (“personal data”).

This Privacy Policy tells you how we collect and process your Personal Data. We invite you to read it carefully.

Important

We use your personal data only in the cases provided for by the regulations in force:

– 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 commercial or business reasons that justifies the use of your data by the EARL Domaine Capdevielle.

For any question relating to this document, you can contact the data protection officer of the Domaine Capdevielle (click: mail contact@domaine-capdevielle.com ).

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

The person in charge of the processing mentioned in this document is the EARL Domaine Capdevielle, registered in the register of commerce and companies of Pau under the number 391 755 022 00012, whose head office is located at Quartier Coos – 64360 Monein.
The Data Protection Officer is Mr Didier Capdevielle.

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

3.1 The data you send us directly

In the course of the various contacts we have with you, you may be asked to provide us with information that concerns you. This information is collected in particular when subscribing to a newsletter, creating an account on our site and application or to access any other offer or service.

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

3.2 The data we collect in the course of our business relationship

The data we collect in the course of our business relationship with you includes the following:
– Your participation in promotional offers, contests or events;
– Requests that you have made to our community manager or incidents that you have reported to us, for example concerning the performance of our services;

3.3 Data that we collect automatically

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

● Data collected via cookies

A cookie is a text file that is placed when you visit a website, application or advertisement online 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 sender of a cookie can decide whether to read or modify the information contained therein.

A cookie has a limited period of validity. It is deposited and stored on your terminal in compliance with applicable legislation and subject to the choices you have expressed and which you may modify at any time, under the conditions specified in Article 9 below.

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

Cookies have several functions, such as enabling you to navigate efficiently on a site or application, to remember your choices, the goods and services you wish to purchase, and to offer you relevant advertising content according to your centres of interest expressed during your navigation. You will find more information about cookies on the following sites:
www.cnil.fr
www.allaboutcookies.org
www.aboutcookies.org
www.youronlinechoices.eu

The cookies deposited by the EARL Domaine Capdevielle subject to your choices give us access in particular to the following information:

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– 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 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 Internet page of origin (“referrer”),
– Navigation 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 display a graphic image (usually invisible) on a Web page or in an e-mail. Redirects are used to make a web page available at 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 content that is customized to your interests. For example, when a user clicks on a share button on an article, a script creates a pixel to count the share. In this way, we are able to see the total number of times an item has been shared, and we can rank the most shared items.

These technologies give us access to the following information in particular:
– Information about your use of our sites and applications;
– Information relating to the presence of cookies on your terminal, the time and date of a page visit, and a description of the page where the web beacon is placed;
– Information on whether or not you read the e-mails we send you, and the clicks you make on the links contained in those e-mails.

Our sites and applications may also include scripts, pixels, and third party 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 the purposes of auditing, research, and to report information about our sites and applications and the advertisements viewed on them. We do not share your personally identifiable information with these third parties in connection with their use of these technologies.

● Data Provided by Mobile Devices

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

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

In addition, if you have accepted this feature 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 believe are relevant to your expectations or interests or to improve your experience on our mobile applications. In accordance with applicable law, location-based features may be disabled at any time in the system settings of your device.

3.4 The data we assume

By combining the data we have about you with general anonymous statistical information, we may be able to make assumptions about the content and services that are relevant to your tastes or uses.

Example: If, according to statistical data, a majority of people aged between 30 and 50 years old, living in Pau and interested in creating websites, also have a passion for social networks, and you are a company manager or a 42-year-old merchant who regularly consult the website, we may be able to establish, by comparing the data we have about you with general and anonymous statistical information, suppositions about the content and services that are likely to meet your tastes or uses.

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Example: If, according to statistical data, a majority of people aged between 30 and 50 years old, living in Pau and interested in website creation, are also passionate about social networks, and you are a company manager, or a 42 year old shopkeeper who regularly consult articles on our site related to our activity, we will assume that you are also interested in e-marketing and we will be able to show you during the navigation on our site an advertisement for an affiliate service.

3.5 Data relating to minors

In principle, our products and services are intended for adults who are capable of entering into contractual obligations.

Users who are minors must obtain the consent of their legal guardian prior to the communication of personal data concerning them.

For registration on our sites and for some 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 has a specific right to the deletion of data concerning him/her. For any information, please contact the data protection officer of the EARL Domaine Capdevielle (Click: email address contact@domaine-capdevielle.com).

3.6 Data relating to a third party

Before offering a third party a service or any other product that we market, you must ensure that the person concerned agrees that his or her personal data, in particular his or her postal details, may be communicated to us.

3.7 Exclusion of sensitive data

XXXXXXXXXXXXXdoes not collect any sensitive data about you. The following are considered sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sexual orientation. If such information is in any way disclosed to us, it will be deleted.

4- FOR WHAT PURPOSES DO WE USE YOUR DATA?

This article tells you the main purposes for which we use the data mentioned in article 3.

4.1 Operations necessary for the supply of products or services

– Management of subscriptions to our newsletters and/or email alerts ;
– Customer relations: a community manager is available by e-mail for any questions or complaints;
– Realization of satisfaction surveys;
– Sending information on the modification or evolution of our services;
– Management of the exercise of your rights on your personal data, under the conditions set out in Article 9;
– Verification of compliance with applicable legislation, our contracts and general terms of use.

4.2 Marketing and commercial prospecting operations relating to the publications, products and services of the EARL Domaine Capdevielle
– Upgrading to postal standards, updating, enriching and deduplicating your personal information in a dedicated database;
– Sending information about our company, its publications and its activity;
– Sending marketing, advertising and promotional offers relating to our products and services by postal mail, e-mail, mobile notifications, on social networks or any other medium;
– Actions of loyalty or personalized commercial prospecting;
– Implementation of contests or other promotional operations;
– Collection of customer opinions;
– Elaboration of commercial statistics.

4.3 Operations related to commercial partnerships

– Sharing, exchanging or renting files with business partners in compliance with the regulations in force and the security requirements ;
– Sending of marketing, advertising and promotional messages relating to the products and services of partners by postal mail, e-mail, mobile notifications, on social networks or any other medium;
– Setting up contests or other promotional or event-related operations with commercial partners.

4.4 Purposes associated with placing cookies on your browser

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● Operation and optimization of navigation on our sites and applications

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

● Traffic and audience measurement

o Establishment of statistics and volumes of frequentation and use of the various elements composing our site (sections and contents visited, paths) in order to improve the interest and ergonomics of our services;
o Counting of the total number of advertisements displayed by us on our advertising spaces, classification and statistics;
o Audience analysis based on the results of advertising campaigns;
o Determination of interests and behaviors;
o Improving customer/user knowledge for personalization purposes.
● Personalization of ads on our sites and applications

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

5- HOW LONG DO WE KEEP YOUR DATA?

Your personal data is kept for a period of time in accordance with legal provisions or proportional to the purposes for which it was recorded. Certain periods of conservation respond to the legitimate interest of EARL Domaine Capdevielle as specified in the introduction.

The retention periods vary according to whether we have an ongoing contractual relationship (you are an active customer), that we have had a contractual relationship with you in the past (you are an inactive customer) or that we have never had such a relationship with you (you are a prospect). The data related to your navigation on our online services collected by the cookies that you have authorized have a specific retention period.

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

In any event, we regularly review the information we hold. When their retention is no longer justified by legal, commercial or customer account management requirements, or if you have made use of a right of modification or deletion, we will securely delete them.
Categories of data Purposes Retention periods
Prospect data
All data Creation and management of a prospect file 3 years from the date of data collection or the last contact from the prospect.
Data on an active customer
Data set Customer account management Throughout the entire contractual relationship
Inactive client data
Identification and contact data – Newsletter subscriptions Sending information on the evolution of our publications and our offers 3 years maximum from the unsubscription or last contact from the customer
Data generated by cookies
Data related to your navigation on our services
online Operation and optimization

Attendance measures.
Personalization of content and advertising 13 months maximum
Assumed data
Data relating to your supposed uses and interests Sending of information and offers supposed to correspond to your interests and uses Annual Update


6- WHO IS LIKELY TO HAVE ACCESS TO THE DATA
THAT WE COLLECT?

6-1 Access to data within the EARL Domaine Capdevielle

Are likely to have access to some of your data:
– Employees of the administrative and accounting departments
and management control, IT, community management and marketing & sales.
Access to your data is based on individual and limited access authorisations. The personnel who can access personal data are subject to an obligation of confidentiality (by a nominal and personal commitment to confidentiality).

6-2 Transmission of data


Are also likely to have access to some of your data:

– Subcontractors
They provide services on our behalf, such as:
– Management of telephone calls, sending of postal or digital mail
– Personalization of mobile site and application content
– Carrying out maintenance operations and technical developments
– Collection of customer opinions
– Provision of analytical solutions or audience measurement statistics
Our subcontractors have access to your data on the basis of signed contracts that specify their obligations to protect data security and confidentiality.

– Social networking platforms
The use of social networks to interact with our sites and applications (notably the “share” buttons on Facebook, Twitter, Google+) is indeed likely to result in data exchanges between the EARL Domaine Capdevielle and these social networks. For example, if you are connected to the social network Facebook and you visit a page on the site Nathalie Goujon, Facebook is likely to collect this information. Similarly, if you view an article on the Domaine Capdevielle EARL website and click on the “tweet” button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social networks in order to be aware of the collections and processing they carry out 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 commercial partners and you let them access some of your information, in particular by connecting you to their sites or applications, their confidentiality policies and their cookie deposits are opposable to you. We have no control over the collection or processing of your data by our business partners on their own platform.

– Police authorities, judicial or administrative authorities
When we are legally obliged to do so or in order to guarantee the rights, property and safety of the Le Monde Group.

7- IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

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

8- HOW ARE YOUR DATA PROTECTED?

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

– The appointment of a Data Protection Officer;
– The establishment of a unit dedicated to the security of information systems;
– Raising awareness of confidentiality requirements among our employees who have access to information.
to your personal data;
– Securing access to our premises and computer platforms;
– The implementation of a general computer security policy of the company;
– Securing access, sharing and transfer of data;
– The high level of data protection requirements when selecting our subcontractors and partners.

9- WHAT ARE YOUR RIGHTS?

9.1 Your rights in terms of access to your personal data

You have the right to access your personal data and request that they be corrected, completed or updated. You may also request the deletion of your data or object to their processing, provided that you can prove a legitimate reason.

You may request to exercise your right to the portability of your data, i.e. the right to receive the personal data you have provided us with in a structured, commonly used format and the right to pass this data on to another data controller.

Finally, you can formulate guidelines for the storage, deletion and communication of your personal data after your death.

You can exercise your rights by contacting the personal data protection officer at Domaine Capdevielle Chemin Coos 64360 MONEIN or by e-mail: contact@domaine-capdevielle.com.
Before responding to your request, we may verify your identity and/or ask you to provide us with further information to respond to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the time limits set by law.

In the event of an unsatisfactory response, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).

9.2 Your rights to object to commercial solicitations

We may use your contact information for marketing solicitations in accordance with applicable law and the terms of this Privacy Policy. You may object to these solicitations at any time, in a manner that depends 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 the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS).


However, your express and prior consent is not obligatory when you are already a customer of the EARL Domaine Capdevielle and that the object of our solicitation is to offer you products or services similar to those that we already provide you.

In any case, you always have the possibility of opposing to the reception of these solicitations by clicking on the link of unsubscription envisaged in each e-mail.

– Commercial solicitations on mobile applications

The first time you open the EARL Domaine Capdevielle mobile applications on your smartphone or tablet, you can give permission to receive mobile or “push” notifications. These notifications allow us to communicate editorial content to you (info alert, content highlighted by the editorial staff), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in the settings of your smartphone.

9.3 Your rights to accept and manage cookies

You can save a cookie on your browser device if you wish to do so. You can at any time modify your choices regarding the acceptance or refusal of cookies placed on your terminal, either on your browser or online with different operators.
In order 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 do you exercise your choices?

a. Make your choices on your browser

You can set your browser software either to offer you the possibility of accepting or rejecting cookies from time to time, before a cookie is likely to be saved, or to systematically accept or reject the saving of cookies in your device.
We would like to alert you to the fact that any setting on your browser software concerning the refusal of technical and functional cookies will be likely to alter your browsing comfort on our websites, or even prevent the use of some of our services requiring the use of these same cookies.
Where applicable, we decline all responsibility for the consequences related to the degraded functioning of our websites and our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and that you would have refused or deleted.
The configuration of each browser is different for the management of cookies and your choices. It is described in the help menu of your browser, which will enable you to find out how to change your cookie preferences.
– Microsoft Internet

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

– Adobe Flash Player Flash Cookies
Adobe Flash Player is a computer application that allows the rapid development of dynamic content using the Flash computer language. Flash (and similar applications) stores the parameters, preferences and use of these contents thanks to 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.

To the extent that your device is likely to view content developed using Flash, we invite you to access your Flash cookie management tools directly from the http://www.adobe.com/fr website.

– Do not track
You can also set your browser to send a code to websites that tell them that you do not want 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

b. Make your choices online

For audience measurement and analytical cookies

Analytical cookies enable us to obtain anonymous statistics on the use of our site in order to optimise it and detect possible malfunctions. They are deposited on our sites and applications by the companies Google Analytics and Facebook.
If you do not want our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links for further information:
– Google Analytics cookies
https://tools.google.com/dlpage/gaoptout

For “Social Networks” 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 the 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 articles based on popularity criteria and your interests as well as sponsored articles.
To learn more about interest targeting
http://www.youronlinechoices.com/fr/a-propos-de-la-publicite-comportementale/
To disable this targeting technology
https://www.ligatus.com/fr/privacy-policy

You also have the possibility of connecting to the sitehttp://youronlinechoices.com, proposed by digital advertising professionals grouped within the European association EDAA (European Digital AdvertisingAlliance) and managed in France by the Interactive Advertising Bureau France.

This European platform is shared by hundreds of Internet advertising professionals and provides a centralized interface allowing you to express your refusal or acceptance of the cookies used by these companies to adapt to your browsing information the advertisements likely to be displayed on your device:
http://www.youronlinechoices.com/fr/controler-ses-cookies/ .

Finally, certain cookies are deposited by third-party service providers for the purposes of personalised advertising. You can also click on the following links to learn more about their practices and exercise your choices:
http://www.youronlinechoices.com/fr/controler-ses-cookies/ .

Finally, some cookies are deposited by third party service providers for the purpose of personalised advertising. 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
– Cookie weborama
https://weborama.com/fr/respect-de-la-vie-privee/
– Cookie Index Exchange
http://www.indexexchange.com/privacy/