01 - Collection of Your Personal Data Main Purposes

We may collect personal data about you, especially when: (1) you create a member account, (2) download downloadable content, (3) authenticate yourself, (4) participate in a game/contest, (5) send an email, (6) respond to a satisfaction survey or study, (7) enroll in a training course and manage training courses, (8) send a CV, (9) place an order or send a request for service. (name, first name, email, postal address, and, where applicable, telephone number).

Your personal data is recorded in a computerized file by GRAND FROID for the following purposes:

  • Statistical studies: we compile and analyze your data to define your profile and better adapt our services to your expectations. These statistical studies are strictly confidential;
  • Customer relationship management: if you send us a message, the data is kept and used to respond to your request and follow up on it;
  • Service provision: sending newsletters.

They are kept for 3 years and are intended exclusively for GRAND FROID.

In accordance with current regulatory and legislative provisions, you have the right to access, rectify, and delete the data concerning you. You can exercise this right at any time by sending a letter, accompanied by a photocopy of proof of identity, to the following address:

GRAND FROID - 1 Avenue Aristide Briand - BP 38 - 93161 NOISY LE GRAND - France

 

02 - USER RIGHTS

GRAND FROID respects your right to privacy: it is important that you have control over your personal data. You have the following rights:

Your RightsWhat This Means
The right to be informedYou have the right to obtain clear, transparent, understandable, and easily accessible information on how we use your personal data and your rights.
The right of access

You have the right to access the personal data we hold about you (subject to certain restrictions).

We may require payment of reasonable fees taking into account the administrative costs incurred to provide the information. Manifestly unfounded, excessive, or repetitive requests may not receive a response.

To exercise your right of access, please contact us at the contact details provided at the end of this document under "CONTACT."

The right to rectification

You have the right to demand that your personal data be rectified if it is inaccurate or out of date and/or completed if it is incomplete.

To exercise your right to rectification, please contact us at the contact details below. If you have an account, it may be easier to update your own data via the "My Account" function.

The right to erasure/right to be forgotten

In certain cases, you have the right to obtain the erasure or deletion of your personal data. This is not an absolute right, as we may be required to retain your personal data for legal or legitimate reasons.

If you wish us to erase your data, please contact us at the contact details provided at the end of this document under "CONTACT."

The right to object to direct marketingYou can unsubscribe or object to receiving our commercial prospecting messages at any time. Simply click on the "unsubscribe" link in any email or communication we send you. You can also contact us at the contact details provided at the end of this document under "CONTACT."
The right to lodge a complaint with the CNIL

You have the right to file a complaint with the data protection authority (CNIL) to challenge GRAND FROID's practices regarding personal data protection and privacy.

We invite you to contact us at the contact details below before filing a complaint with the competent data protection authority.

The right to restrict processing

You have the right to request the restriction of processing of your data.

This right means that the processing of your data is limited, so we can keep the data but not use or process it. This right applies in specific circumstances set out in the General Data Protection Regulation, namely:

  • The accuracy of the personal data is contested by the data subject (that is, you), for a period enabling the controller to verify the accuracy of the personal data;
  • The processing is unlawful, and the data subject (that is, you) opposes the erasure of the personal data and requests the restriction of their use instead;
  • The data controller (that is, GRAND FROID) no longer needs the personal data for the purposes of the processing, but they are required by the data subject (that is, you) for the establishment, exercise, or defense of legal claims;
  • The data subject (that is, you) has objected to processing based on legitimate interests pursued by the data controller (that is, GRAND FROID) pending verification as to whether the legitimate grounds of the data controller override those of the data subject.

If you wish to obtain a restriction of processing, please contact us at the contact details provided at the end of this document under "CONTACT."

The right to disable Cookies

You have the right to disable Cookies.

Internet browser settings are generally set by default to accept cookies, but you can easily change this by modifying your browser settings. Many cookies are used to improve the usability and functionality of websites/applications, so disabling cookies may prevent you from using certain parts of this site.

If you want to restrict or block all cookies placed by our websites/applications (which may prevent you from using certain parts of the site) or by other websites/applications, you can do so by going to your browser settings. Your browser's Help function will provide you with instructions.

For more information, you can visit the following link: https://www.aboutcookies.org/

 

03 - OUR COMMITMENT TO PERSONAL DATA PROTECTION

  1. We respect your privacy and your choices.
  2. We ensure that personal data protection and security are at the core of everything we do.
  3. We send commercial communications only if you have requested them. You can change your mind at any time.
  4. We prohibit the communication or sale of your data.
  5. We are committed to securing and protecting your personal data. This means we only collaborate with trusted partners.
  6. We are committed to being open and transparent about how we use your data.
  7. We refrain from using your personal data in ways that we have not made known to you.
  8. We respect your rights and strive to fulfill your requests to the best of our ability, while respecting our own legal and operational responsibilities.

When you provide us with personal data or when we collect personal data about you, we commit to using it in accordance with this Policy. If you have any questions or concerns about your personal data, please contact us at the following address rgpd@grandfroid.fr.

 

04 - DATA CONTROLLER: DPO

The data controller for the personal data referred to herein is the company GRAND FROID, a simplified joint-stock company with a capital of €25,000, registered with the Paris Trade and Companies Register under number 49889973100042, with its registered office located at 1 Avenue Aristide Briand - BP 38 - 93161 NOISY LE GRAND - France.

GRAND FROID has appointed a Data Protection Officer who can be contacted at the following address: rgpd@grandfroid.fr

 

05 - CONTACT

If you have any questions or comments about how we process and use your personal data, or if you wish to exercise any of the rights mentioned above, please contact us at the following email address support@grandfroid.fr or write to us at the following address:

GRAND FROID - RGPD Service

ZA PARIEST 03 allée du 1er mai 77183 Croissy Beaubourg

SPECIAL PROVISIONS FOR FRANCE We remind you that in accordance with the provisions of Article 40-1 of Law 78-17 of January 6, 1978, you have the right to formulate general (with a trusted digital third party certified by the CNIL) or specific (with the data controller) directives concerning the storage, erasure, and communication of your personal data after your death.

Note: To respond to your request, we may require proof of identity.

 

06 - PERSONAL DATA SECURITY

GRAND FROID is committed to the security of your data and devotes significant human and technical resources to ensure its protection.

Our processes, internal organization methods, guarantees required from our subcontractors, as well as technical protection rules, are designed to ensure that your personal data is protected.

In the event of a breach of your personal data, GRAND FROID undertakes to inform you as soon as possible and to take all necessary measures to limit the risks associated with such breach.

For example:

  • Only authorized personnel, in accordance with the main purposes (01), may access your data.
  • Technical and organizational security measures are put in place, including updates through patches, antivirus, anti-spam, vulnerability management, perimeter security by Firewall, intrusion detection and prevention systems, as well as user account management and authorizations.
  • The use of a subcontractor and the transfer of this data to the subcontractor responsible for storing it on behalf of GRAND FROID are strictly limited to managing and routing subscriptions, to the exclusion of any other commercial use. When they act on our behalf, subcontractors must commit to guaranteeing the security of the data entrusted to GRAND FROID.
  • GRAND FROID does not use any subcontractor located outside the European Union, in a geographical area where the rules guaranteeing the security of personal data are less strict than those in force in France. Consequently, your data does not, on the part of GRAND FROID, undergo any transfer outside the EU.
  • GRAND FROID does not sell your data.

 

07 - PERSONAL DATA BREACH

In terms of the GDPR, a personal data breach is a security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to transmitted, stored, or otherwise processed personal data.

As the data controller, GRAND FROID is committed to ensuring the security of the processing of personal data to prevent any such breach.

However, in the event of a breach of personal data, GRAND FROID will comply with the obligation to notify the breach to the CNIL (https://notifications.cnil.fr/notifications/index) as soon as possible and if possible within 72 hours of becoming aware of the breach, unless the breach in question is not likely to result in a risk to the rights and freedoms of data subjects.

Beyond 72 hours, the notification that GRAND FROID will provide to the CNIL will specify the reasons for the delay.

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