TheGreenBow website is published by Sistech S.A., a limited company operating under the trade name ‘TheGreenBow’, identification number 420 414 336 Paris Trade and Companies Register, registered office 28 Rue de Caumartin, 75009 Paris, France, represented by Mr Roger Simon in his capacity as Chairman and publication manager; firstname.lastname@example.org
1. Legal framework
1.1 TheGreenBow undertakes to collect, process and protect your personal data in compliance with the legislation that applies in France, in particular EU GDPR Regulation 2016/679 of 27 April 2016, amended by the corrigendum of 23 May 2018, the (French) Computers and Data Protection Law 78-17 of 6 January 1978 amended by Order 2018-1125 of 12 December 2018 and Directive 2002/58 of 12 July 2002, amended by Directive 2009/136 of 25 November 2009.
1.2 In the following provisions, the terms ‘controller’, ‘processor’, ‘processing’, ‘data breach’ and ‘data of a personal nature’ (or, for simplification purposes, ‘personal data’) have the meanings defined in Art. 4 of the GDPR.
2. Tracking cookies
2.1 In accordance with decision 2019-093 of 4 July 2019 of the French National Computers and Data Protection Commission (CNIL), validated by State Council ruling 434684 of 19 June 2020, TheGreenBow informs you that it uses tracking cookies, which are installed in the device that you use to consult TheGreenBow website, that are ‘strictly necessary for the provision of an online communication service at the express request of the user’ or ‘the exclusive purpose of which is to enable or facilitate communication by electronic means’, the legal basis of which is Art. 6.1(b) of the GDPR.
2.2 You will be reminded of this information in a banner that will be displayed throughout your browsing of TheGreenBow website until you click ‘I understand’.
3. Contact form
3.1 If you want to contact us, please use the online contact form on TheGreenBow website.
3.2 Your responses are required if you wish to be contacted by TheGreenBow.
3.3 TheGreenBow keeps your contact data for a period of two years, in accordance with CNIL decision SAN2020-003 of 28 July 2020, that starts from the last ‘event that demonstrates [your] interest … in the message received, such as a click on a hypertext link contained in an email’.
3.4 After that period, your contact data will be deleted from TheGreenBow’s database.
4. TheGreenBow personal data protection policy
4.1 TheGreenBow is responsible for processing the personal contact data that TheGreenBow collects directly (Art. 13 of the GDPR) from the TheGreenBow website for the following purposes only:
(i) processing necessary for the performance of a contract or pre-contractual measures (Art. 6.1(b) of the GDPR);
(iii) processing necessary for the purposes of TheGreenBow’s legitimate interests (Art. 6.1(f) of the GDPR) of prospecting for its other products or services, with a free and immediate unsubscribe http link (right to be forgotten in Art. 17 of the GDPR and right to object to direct marketing in Art. 21.2 of the GDPR) contained in each electronic mailing.
4.2 You have a right of access to (Art. 15 of the GDPR) and rectification of (Art. 16 of the GDPR) such personal data processed by TheGreenBow. TheGreenBow undertakes to reply by email to your requests within thirty (30) days of receipt by TheGreenBow. If you do not receive a reply, you are entitled to refer the matter to the Commission Nationale de l’Informatique et des Libertés (CNIL) [French Data Protection Authority] in order to contest such failure to reply.
4.3 Your data is exclusively hosted within the European Union by the host identified in the ‘About us’ article of the General Conditions of Use on TheGreenBow website.
4.4 TheGreenBow undertakes to include this processing of your personal data in its ‘register of processing activities’ (Art. 30 of the GDPR).
4.5 Any subcontracting by TheGreenBow of the technical management of its database containing your personal data will be subject to a written contract with a professional subcontractor. TheGreenBow undertakes that its subcontractor will strictly comply with these provisions and guarantees the security and confidentiality of the personal data that TheGreenBow may entrust to it.
4.6 Any other type of processing by TheGreenBow of your personal data (eg, sending, with or without pecuniary consideration, to third parties for direct or indirect marketing purposes, including profiling) will be carried out by TheGreenBow only with your prior individual informed consent (Art. 6.1(a) of the GDPR).
4.7 Each electronic mailing from TheGreenBow to the electronic contact details that you have provided will include a clear and concise reminder of the existence of your rights under the GDPR, including the right to object to canvassing and profiling (Art. 21 of the GDPR).
4.8 Without delay and at the latest within seventy-two (72) hours after becoming aware of it (Art. 33 of the GDPR), TheGreenBow undertakes to inform the CNIL of any proven breach of your personal data.
4.9 If you have any questions about the protection of your personal data, you can write to us at email@example.com.