As part of making our Website available, we process your personal data in compliance with the General Data Protection Regulation 2016/679 of April 27, 2016 ("GDPR") and under the conditions set out below.
Personal data refers to any information relating to an identified or identifiable natural person. We collect and process personal data in connection with providing our Services or communicating about these Services exclusively, in strict compliance with the GDPR.
We only collect personal data that is adequate, relevant and limited to what is necessary for the purposes for which they are processed. Thus, you will never be asked to provide "sensitive" personal data, such as your racial or ethnic origin, political, philosophical or religious opinions.
By registering on the Website, you authorize us to process your personal data in accordance with the Charter. If you refuse the terms of this Charter, please refrain from using the Website and Services.
1. When do we collect your personal data and what data is collected?
We may collect and retain your personal data, in particular when you:
- browse the Website
- create an account
- pay online
- contact us
We use your personal data to enable the implementation and management of the Website's Services and to respond to your specific requests. We also use your personal data for the purpose of operating and improving our Services, our Website and our approach. This information is used solely by us and allows us to better adapt our Services to your expectations.
If you have chosen to receive emails and messages from us when creating your Account, you will then receive electronic and alphanumeric messages about our products and promotions. We will then use the personal data you provided during registration. You can unsubscribe from these mailings at any time.
1.1 Browsing the Website
Connection data. Each time you connect to our Website, we collect personal data such as your IP address and your computer's MAC address, the date and time of connection, as well as information about the browser you use.
1.2 Account creation
Access to some of our Services requires prior creation of an Account. In accordance with the General Terms and Conditions, you will be asked to provide certain personal data when creating your Account, including your first and last name, mailing address, email address and phone number.
Some of the available Services are paid. For this purpose, you agree that we may use external service providers who may collect personal data in order to enable the proper functioning of credit card payment services or any other means of payment and, where applicable, product or service delivery.
To pay for your purchase, you must provide your billing information as well as your payment information, including your credit card number, expiration date, security code and cardholder name for credit card payments.
You may also be asked to provide your telecom operator's name, your mobile phone model and a valid mobile number in order to provide the purchase instructions directly through your mobile phone.
We retain the details of your payments, as well as the details of purchases you make. Transaction details are retained either in our systems or with the external provider. This retention is carried out for internal purposes, including accounting, compliance and legal purposes, in accordance with paragraph 5 of this Charter.
1.4 Newsletter subscription
When creating your Account, you can give your prior consent to receive our newsletters concerning news, new products, services and promotions, as part of the Services.
You can also directly consent to receiving our newsletters by entering your email address in the areas provided for this purpose on the Website.
In any event, you have the right to withdraw your consent to receive such newsletters at any time and without charge under the conditions set out in paragraph 6 of the Charter.
In order to follow up on requests you may make to our Customer Service and confirm information about you, we may use your name, first name, email address and telephone number.
2. How do we protect your personal data?
We have implemented technical and organizational security measures to ensure the security, integrity and confidentiality of all your personal data, to prevent it from being distorted, damaged or accessed by unauthorized third parties. We provide an appropriate level of security, taking into account the state of knowledge, implementation costs and the nature, scope, context and purposes of processing, as well as risks and their likelihood.
However, it should be noted that no security measure is infallible, so we are unable to guarantee absolute security for your personal data.
In addition, it is your responsibility to ensure the confidentiality of the password allowing you to access your Account. Do not share this information with anyone. If you share your computer, remember to log out before leaving a Service.
3. When do we share your personal data?
3.1 Sharing your personal data with third party companies
When browsing the Website, your personal data may be transmitted to external service providers. These third parties provide a service on our behalf and in our name in order to enable the proper functioning of credit card payments and other Services.
Personal data may be transferred to countries outside the European Union (such as the United States) for statistical analysis and email sending purposes.
In accordance with the GDPR, all transfers of personal data to a country located outside the European Union and/or not offering an adequate level of protection as deemed sufficient by the European Commission have been the subject of cross-border flow agreements in accordance with the standard contractual clauses enacted by the European Commission.
Other transfers of personal data to the United States are governed by the EU-US PRIVACY SHIELD: click here for more information.
We will never share your personal data with third party companies for marketing and/or commercial purposes without having obtained your prior consent.
3.2 Sharing with authorities
We may be required to disclose your personal data to administrative or judicial authorities when disclosure is necessary to identify, apprehend or prosecute any individual likely to harm our rights, any other user or a third party. Finally, we may be legally required to disclose your personal data and cannot refuse in this case.
4. How long do we keep your personal data?
We will only keep your personal data for the duration of your registration on the Website in order to ensure your identification when connecting to your Account and to provide the Services.
Thus, if you unsubscribe from the Website, your personal data will be deleted and only retained in archived form for the purpose of establishing evidence of a right or contract.
In any event, we will keep your personal data for a period not exceeding that necessary for the purposes for which they are processed in accordance with the uses set out in this Charter and in compliance with laws and regulations.
5. Cookies : How do we use them?
5.1 What is a cookie?
A cookie is a text file that may be deposited on a terminal when consulting an online service with browsing software. A cookie file allows its issuer, during its validity period, to recognize the terminal concerned each time that terminal accesses digital content containing cookies from the same issuer.
In any event, cookies deposited on your browsing terminal with your consent are destroyed 13 months after being deposited on your terminal.
5.2 What are the cookies issued on our Site used for?
The cookies we issue allow us to:
- establish statistics and volumes of traffic and use of the various components of our Website (sections and content visited, routes), allowing us to improve the relevance and ergonomics of the Website and, where applicable, our products and services;
- adapt the presentation of our Website to your terminal's display preferences (language used, display resolution, operating system used, etc.) during your visits to our Website, according to the hardware and software used to view or read on your terminal;
- remember information about a form you completed on our Website (registration or account access) or about products, services or information you selected on our Website (subscribed service, shopping cart content, etc.);
- allow you to access reserved and personal areas of our Website, such as your Account, thanks to identifiers or data that you may have previously entrusted to us and to implement security measures, for example when you are asked to log in again to content or a service after a certain period of time.
When browsing the Website, social network cookies can be generated in particular through the sharing buttons that collect personal data.
When you first visit the Website, a cookies banner will appear on the homepage. A clickable link provides more information about the purpose and operation of cookies and redirects to this Charter. Continuing browsing on another page of the site or selecting an element of the Website (including: image, text, link, etc.) signifies your acceptance of the deposit of the cookies referred to on your computer.
5.3 How can you control the cookies used?
You can configure your browser software at any time so that cookies are saved on your terminal or, on the contrary, rejected (either systematically or according to their issuer). You can also configure your browser software so that acceptance or refusal of cookies is proposed to you occasionally, before a cookie can be saved on your terminal.
5.4 How do you configure your browser?
For cookie management and your choices, each browser's configuration is different. It is described in your browser's help menu, which will allow you to know how to modify your cookie preferences. You will find information below regarding the main browsers.
Internet Explorer / Edge
- In Internet Explorer, click the Tools button, then Internet Options.
- Under the General tab, under Browsing History, click Settings.
- Click the View Files button.
- Go to the browser's Tools tab then select Options.
- In the window that appears, choose Privacy and click Show Cookies.
- Access Settings via the browser menu (Safari > Preferences).
- Click on Privacy.
- Access Settings via the button on the right of the URL bar or via the browser menu (Chrome > Preferences).
- Select Advanced Settings.
- Click on Content Settings then Cookies.
For more information about cookies, you can consult the CNIL website.
6. What are your rights?
You alone have provided us with the data in our possession, through the Website. You have rights over your personal data. In accordance with the regulations on the protection of personal data, in particular articles 15 to 22 of the GDPR, and after proving your identity, you have the right to request access to, rectification or erasure of personal data concerning you.
In addition, within the limits set by law, you also have the right to object to processing, to limit it, to decide on the post-mortem fate of your data, to withdraw your consent at any time and the right to data portability of the personal data provided.
You can contact our Services to exercise your rights at the following email address: [email protected] or at the following postal address: Anphos, 39 rue de l'Abbé Grégoire, 75006 Paris, enclosing a copy of an identity document with your request.
In addition, you can unsubscribe from our newsletter at any time by clicking on the unsubscribe link at the bottom of each email. You can also unsubscribe by sending a message to the following address: [email protected].
7. Can we modify the Charter?
We reserve the right to modify the Charter at any time. You are therefore advised to consult it regularly. In the event of a change, we will publish these changes on this page and in places we deem appropriate depending on the purpose and importance of the changes made.
Your use of the Website after any change means that you accept these changes. If you do not accept certain substantial changes made to this Charter, you must stop using the Website.
8. Data Protection Officer and contact
For any questions regarding your personal data or if you wish to delete your Account, please contact us at the following postal address: Anphos, 39 rue de l'Abbé Grégoire, 75006 Paris (indicating "Privacy - Data Protection"), or by email at [email protected].
9. The National Commission for Data Protection and Liberties ("CNIL")
We remind you that you can contact the CNIL directly on the CNIL website or by mail at the following address: National Commission for Data Protection and Liberties (CNIL), 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX 07.