Online on January 12, 2021.
Following the PD Regulation, the Website’s publication director informs you of the following.
« Terms and Conditions of Use »
refers to the general terms and conditions of use accessible on the Website.
« Cookies »
« Personal Data »
means any data of a personal nature presenting nominative information relating to a person identified or identifiable in the person of the User (in particular, the surname, the first name, the title, the date of birth, the age, a postal and e-mail address).
« Newsletter »
means the letter sent to the User in the form of an electronic e-mail regularly sent to a list of Users who have subscribed to this option on the Website. The conditions of subscription to the Newsletter and its operation are defined in Article 5 of the Terms and Conditions of Use.
« PD Regulation »
means the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals concerning the processing of Personal Data and on the free movement of such data (hereinafter “GDPR”).
« Website »
« Sub-contractor »
means the natural or legal person, public authority, or any other body that processes Personal Data on behalf of the data controller.
« TALI »
means the company TALI SAS, a simplified joint stock company with a single shareholder, with a capital of €5,000, registered with the Versailles Trade and Companies Register under the number 848 557 195, domiciled at 3, rue Camille Claudel in Buchelay (78200), and its employees.
« Data Processing »
means any operation(s) or set of operations carried out or not using automated processes and applied to data or sets of Personal Data, and in particular, the collection, recording, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation, or reuse, as well as blocking, erasure or, destruction as defined by the PD Regulation.
« User »
means any person accessing the Website concerned by the use of Personal Data.
Purpose of the Policy
TALI assures Users of the security and confidentiality of their Personal Data and is committed to protecting it in accordance with the PD Regulation.
The Policy provides targeted and detailed information on Data Processing and defines TALI’s commitments as Data Processor, concerning the respect of the User’s Personal Data collected and processed when browsing the Website, subscribing to the Newsletter and/or any contact by the User with TALI.
Scope of the Policy
The Policy applies to Users of the Website and describes how TALI collects and uses Personal Data during their browsing and when they subscribe to the Newsletter. The User acknowledges and accepts that the Policy is an integral part of the Terms and Conditions of Use.
By subscribing to the Newsletter and by providing his/her email address, the User acknowledges and agrees that TALI may collect, process, store and/or use the Personal Data submitted.
The User has the right to withdraw his/her consent at any time in the manner set forth below in the Article 15.
Personal Data collected
When the User browses the Website and subscribes to the Newsletter, TALI collects various categories of Personal Data, namely:
Category of Personal Data
Personal Data collected
Identification and contact data
- first name,
- date and place of birth,
- mailing address,
- email address.
- IP address of the User’s computer,
- browser type and version,
- device used,
- language preferences,
- the website from which the User accesses the Website,
- the pages consulted on the Website by the User,
- date and time of navigation on the Website,
- name of the User’s internet provider.
date of subscription to the Newsletter.
TALI may also collect Personal Data by automated means, from technologies developed by third parties and in particular, Google Analytics, Social Network Plugs-Ins, such as LinkedIn, Facebook, Twitter, Instagram, either by marketing providers, public or administrative sources.
These may include, but are not limited to:
- Users’ comments on the Website, or third party sites,
- o information in the context of complaints or disputes provided by Users or third parties.
The User acknowledges and accepts that TALI may combine the information collected from these sources with other information in its possession. In this case, TALI will take all legal measures required to inform the User of the source and category of the Personal Data collected and processed, except when disclosure by TALI is expressly prohibited, in particular in the context of investigations conducted by the authorities for money laundering.
TALI may also collect Personal Data from third parties, such as a spouse, or friend of the person concerned, contacting TALI and providing him or her with his or her contact information to invite him or her to events or share information that may be of interest to him or her.
The third-party that transmits Personal Data about someone else must ensure that he or she has the right to disclose such Personal Data and that, without TALI taking other measures imposed by data protection legislation, TALI may collect, use and disclose such Personal Data for the purposes described in the Policy. For example, you must ensure that the person concerned is aware of the various subjects outlined in the Policy.
The individual must also give his or her consent to the Processing of Data as outlined in the Policy.
TALI may request the disclosure of additional Personal Data to securely identify the User or to satisfy a legal reason, including to ensure secure identification methods, proof of addresses, and funding, and to verify the actual existence of the User.
Finally, when the User contacts TALI to exercise his or her rights as a data subject, TALI collects certain Personal Data, depending on how the User addresses his or her request:
- name (first and last name),
- type of request (e.g. request for correction or deletion),
- contact information,
- e-mail address,
- country of residence,
- other information necessary to process the request (e.g., identification data), and
- the content of the request addressed.
Use of Personal Data
Personal Data is collected and processed based on the legal grounds provided by the PD Regulation, namely:
In the context of the execution of the Conditions (contractual purpose):
- subscription to the Newsletter or the TALI mailing list: the User’s prior consent has been given,
- identification and authentication of the User,
- communications with the User,
- technical and commercial assistance,
- litigation management,
- management and exercise of the rights and requests of Users relating to their Personal Data,
- hosting of Personal Data,
- optimization and management of the Website and other means of communication,
- declarations required by the competent authorities, and/or, to the administrations and carrying out any administrative formality.
For legitimate interests or, where appropriate, based on the User’s consent:
- fight against fraud and/or money laundering,
- enrichment and enhancement of customer and prospect bases,
- provision of localized and customized content according to state regulations,
- development and improvement of the services offered by TALI or third parties and commercial prospecting,
- carrying out statistical studies and analyses,
- measure the audience and access flows to the Website.
They are also collected and used by TALI to ensure compliance with its legal and regulatory obligations as defined by the legislation in force, after having informed the User.
TALI may collect and process Personal Data for commercial prospecting purposes by sending Electronic Newsletters for direct prospecting or from its partners. TALI will thus use Personal Data to send the User customized communications, advertising, or personalized marketing campaigns.
Each time an electronic communication for commercial prospecting purposes is sent, the User can choose not to receive any more in the future thanks to a link allowing him/her to unsubscribe from the mailing list. For this purpose, it is also possible, at any time, to send an e-mail to the following e-mail address: firstname.lastname@example.org.
The User receives information and data about TALI, either at his request (with his prior consent, when required by law) or when the law authorizes us to send this information directly to you. These communications may be international or local and may include information about TALI’s products and services, invitations to events, offers, surveys, etc. TALI’s communications are specifically designed to be of interest to the User.
Personal Data is updated with any new Personal Data sent to TALI.
Following the PD Regulations, TALI undertakes to:
- process the Personal Data only for the purpose(s) mentioned above,
- guarantee the confidentiality of the Personal Data processed in application of the General Conditions of Use,
- ensure that the persons authorized to process Personal Data undertake to respect its confidentiality or are subject to an appropriate legal obligation of confidentiality,
- take into account the principles of protection of Personal Data from the design stage (privacy by design) and protection of Personal Data by default (privacy by default).
If TALI needs to process Personal Data for a new purpose unrelated to the above, the User will be informed beforehand so that he/she can exercise his/her rights concerning such Data Processing.
The User has the right to object to the Data Processing, which may be used following the procedure described in Article 9.
Addresses of the Personal Data
Personal Data may be processed by any duly authorized person within TALI (members and staff), Sub-contractors, or providers.
It is established that the use of service providers is necessary for the development of TALI’s activity.
If the recipients process Personal Data outside the European Union, the transfers will be carried out in compliance with the PD Regulations.
Any disclosure to third parties will be made following the applicable PD Regulations after they have agreed to keep all information received confidential and have agreed that their staff members are bound by similar obligations.
Finally, TALI reserves the right to disclose processed Personal Data to third parties if such disclosures are permitted by applicable laws, including, but not limited to, the following list:
- if TALI is subject to a merger, disposal, acquisition, restructuring, or transfer,
- to protect and defend the rights and interests of TALI, the security or that of its subsidiaries, the rights of Users including the rights of the User concerned,
- to comply with any legal or judicial obligation,
- to meet the requirements of another applicable law, such as anti-money laundering legislation.
Conservation period of Personal Data
TALI undertakes to keep the Personal Data only for the time necessary to fulfill the purposes mentioned in Article 6 above or to meet its legal obligations.
The “necessary” criterion is determined as follows:
- according to the category of Personal Data and the relationship between TALI and the User,
- rules applicable to specific services offered by TALI,
- European and/or French laws.
The User authorizes TALI to keep certain Personal Data for a period time determined with regard to the limitation periods.
Personal Data used for commercial prospecting purposes may be kept for a maximum period of three (3) years from the User’s unsubscription to the Newsletter.
TALI is authorized by the User to keep the Personal Data for purely statistical purposes once they have been made anonymous.
The User has the following rights:
Right of access
Right to access the following information:
- purpose of the Data Processing,
- the categories of Personal Data concerned by the Data Processing,
- the recipients or categories of recipients to whom the Personal Data has been or will be communicated. This right is reinforced when the recipients are established in third countries,
- the intended retention period of the Personal Data or, where applicable, the criteria used to determine the retention period,
- source of the collected data,
- the existence of automated decision making, including profiling, and, at least in such cases, useful information regarding the underlying logic, as well as the importance and expected consequences of such Data Processing for the data subject.
Right to withdraw consent
When it has been given by the User: in particular when subscribing to the Newsletter.
Right of rectification
When Personal Data is false, inaccurate, or incomplete.
Droit à l’effacement (droit à l’oubli)
When Personal Data is no longer necessary for the purposes for which it was collected.
When the User has exercised his right to oppose or revoke the consent given to TALI and TALI has no legal reason to keep them. When Personal Data has been unlawfully processed or must be deleted to comply with a legal obligation arising from European Union law or the law of the Member State to which TALI is subject (French law).
Right of objection
Right to object at any time to a Data Processing for reasons related to one’s particular situation.
Right to Limitation of Treatment
Right to request the limitation of the Data Processing when one of the following applies:
- the accuracy of the Personal Data is contested by the data subject,
- the Processing of Personal Data is unlawful and the person concerned opposes their deletion and demands instead the limitation of their use,
- TALI no longer needs to process Personal Data, but it is still necessary for the establishment, exercise or defense of legal rights,
the User has objected to the Data Processing during the verification of whether the legitimate reasons pursued by TALI prevail over those of the person concerned.
Right to portability
The right to request communication of the Personal Data collected and processed in a structured, commonly used and machine-readable format, and to transfer them directly to another data controller when the Data Processing is based on consent, or on a contract concluded between the User and TALI, and carried out by automated processes.
Users who wish to unsubscribe from the Newsletter may revoke their consent at any time via the unsubscribe link inserted in each Electronic Newsletter they receive, either by sending a request to that effect to the contact address indicated at Article 15.
In the case of unsubscription, TALI regularly updates its databases and will take all reasonable measures to respond to the User’s request as quickly as possible.
The terms and conditions for exercising the User’s rights are indicated in Article 15.
Before being able to respond to the User exercising his rights, TALI may need to verify the identity of the User to guarantee the security of Personal Data and ensure that it is not disclosed to unauthorized persons.
TALI will provide a copy of the Personal Data requested, without prejudice to the rights and freedoms of others, including TALI, within one month after receipt of the request, it being specified that this period may be extended by two months in the event of strong demand and given the complexity of the User’s request. In the latter case, the User will be duly informed.
The User also has the possibility to contact the “Commission National Informatique et Libertés” (CNIL) at the following addresses:
- CNIL – Service des Plaintes – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07,
Personal Data security
TALI implements the appropriate technical and organizational measures to ensure a level of security appropriate to the risks, such as securing the passwords of TALI members and staff.
All TALI employees and its Subcontractors are required to respect the security and protection of Personal Data.
TALI shall not be held liable for any action or omission on the part of the User or a third party in connection with Personal Data before it is collected and processed by TALI, including but not limited to, any transfer of Personal Data by the User to TALI to a State with a lower level of data protection than that in force in the European Union, by any technological means whatsoever (including but not limited to WhatsApp, Skype, Instagram, Facebook, Dropbox, etc.).
TALI is in no way responsible for the security of Personal Data in transit over the Internet, unless TALI’s responsibility results explicitly from French regulations.
Notwithstanding the foregoing, TALI cannot guarantee that the transmission of Personal Data or the storage system is 100% secure. Sub-Contractors with access to Personal Data are specifically required to apply appropriate technical and organizational security measures to protect the Personal Data processed against any unauthorized or accidental disclosure, loss, or destruction and against any illicit form of Data Processing.
Links to third-party websites are indicated. TALI is in no way responsible for the content, general conditions, and privacy policies of these sites, and can in no way be considered as endorsing their content and contractual provisions. The User agrees to be aware of the general conditions and privacy policies of any third-party website.
Notification of Personal Data violations
In the event of a breach of Personal Data security leading, accidentally or unlawfully, to the destruction, loss, alteration, unauthorized disclosure of Personal Data transmitted, stored or otherwise processed, or unauthorized access to such Personal Data, TALI undertakes to notify the User of this breach as soon as possible after becoming aware of it and inform the User of the measures taken to:
- remedy the incident,
- mitigate the negative consequences for the User,
- avoid the occurrence of a similar future violation.
- the identification of the Data Controller and his/her contact information,
- all Data Processing carried out within the framework of the General Terms and Conditions and for the purposes described in Article 6,
- the technical and organizational security measures detailed in Article 10,
- storage periods.
TALI provides the User with the necessary documentation showing compliance with the PD Regulation.
For the strict needs of the execution of the Conditions and subject to inform the User in advance, TALI may transfer Personal Data provided that it implements the appropriate management tools in the application of article 46 of the GDPR, apart from:
- the European Union, or
- the European Economic Area, or
- countries recognized as having an adequate level of security by the European Commission, including companies based in the United States of America, certified “Privacy Shield”.
The User is informed that some Cookies are necessary for the proper functioning of the Website and others are used for analysis purposes to help TALI provide services, develop its offer and improve the User’s digital experience.
The User may exercise his rights at any time as reminded to Article 9.
For questions relating to the Electronic Newsletters, the User may unsubscribe at any time directly via the “unsubscribe” link inserted in all Newsletters sent to Users.
If the new stipulations do not suit the User, the User must cease using the Website’s services without delay and, if applicable, exercise his rights as outlined in Article 9.