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Privacy policy

Last updated on: 8 February 2021

 

PRIVACY POLICY

 

This privacy policy defines and explains how Trendlab SAS (“we” or “us”) uses and protects any information you may provide when using this website, available at: http://www.nellyrodi.com

(hereinafter the “Website”).

 

Please note that we may amend or supplement this privacy policy at any time, in particular to reflect any legislative, regulatory, case-law or technological developments. In such a case, the date of the new version will be clearly stated at the top of this policy. Amendments are binding on users from their publication online. Accordingly, users should consult this privacy and cookies policy regularly to keep abreast of any amendments.

 

 

  1. PERSONAL DATA

As a general rule, you do not need to provide any personal information to visit our Website. In any event, you are under no obligation whatsoever to provide personal information to us.

 

However, if you do not wish to provide personal information, some of the information or services you have requested may not be available. For example, in some cases, we may need to ask you to provide your full name, email address, telephone number, company name and position (hereinafter your “Personal Information”). By providing this information, you expressly authorise us to process it for the purposes stated in Section 2 below and for the purposes stated at the end of each form.

 

Pursuant to the General Data Protection Regulation adopted by the European Parliament on 14 April 2016 and the French Data Protection Act of 6 January 1978 as amended, you are informed of the following:

 

  • Identity of the data controller

The data controller is Trendlab SAS, whose registered office is located at 9 Rue Cadet, 75009 Paris, France. Telephone: +33 (0)1 42 93 04 06.

 

 

  • Purposes of the processing

We may process your Personal Information for the following purposes:

 

(a) to provide you with the information or services you have requested (including sending Newsletters, special offers and white papers); and/or

 

(b) to collect information to help us improve our Website, products and services (mainly through cookies).

 

  • Collection of information

We collect personal information about you and any other party whose details you may provide when you:

  • sign up to use our website, applications or services (including free trials); this may include your name, address, email address and telephone number. We may also ask you for additional information about your line of work and preferences;
  • place an order via our website, applications or services; this may include your name (including the name of the company you work for), address, contact details (including your telephone numbers and email address) and payment information;
  • complete online forms (including callback requests), take part in surveys, post messages in our discussion forums, download information such as white papers or other publications or engage in any other activities proposed in any other interactive areas of our website or our application or service;
  • interact with us on social media;
  • enter your contact details to sign up for or access any website, application or service provided by us or when you update your contact details; and
  • contact us offline, for example by telephone, fax, text message, email or post.

 

We may also collect information from your devices (including mobile telephones) and the applications used by you or your users to access and use our websites, applications or services (for example, we may collect the identification number and type of device used, location and connection data, such as statistics about the pages visited, traffic to and from the websites, the referring URL and your IP address, browsing history and weblog information). Your prior consent is required to collect this information.

We use cookies or other similar technology (as described in Chapter II below) for that purpose.

The personal information we receive from you may also be supplemented by information obtained from third parties, authorised to share it, for example information from data providers or public sources (for example, for customer due diligence procedures). However, we always comply with the applicable laws.

If you plan to provide personal information about third parties, you must always obtain their prior express consent and explain to them how we collect, use, disclose and retain personal information or ask them to read our privacy policy.

  • How do we use your information?

You authorise us to use your information to:

  • provide the information, services and/or applications you have requested and all the applications and services you have ordered;
  • compare information for the purpose of checking its accuracy and corroborating it with third parties;
  • manage and administer your use of the applications, products and services you have asked us to provide;
  • manage our relationship with you (for example, customer services and marketing campaigns);
  • monitor, measure, improve and protect our content, website, applications and services;
  • perform internal controls on our website, applications, systems and services to test and improve their security and performance. Where appropriate, we will anonymise any information used for testing purposes;
  • provide you with any information we are required to provide under our regulatory or statutory obligations;
  • detect, prevent, investigate or address any criminal, unlawful or banned activities or otherwise protect our legal rights (including liaising with regulators and law enforcement agencies for those purposes);
  • contact you to ask you to take part in our customer surveys (for example, feedback on your use of our applications, products and services);
  • deliver marketing messages (including popup banner ads) or targeted information that you may find useful, based on your use of our applications and services;
  • deliver content and services jointly with third parties having a separate relationship with you (for example, social media platforms).

We may retain your Personal Information after your NellyRodi account is closed, if the creation of an account is refused or if you decide not to go ahead with the creation of an account. This information will be retained and used for statutory, regulatory and fraud prevention purposes and for our legitimate business operations, for the period permitted by law.

 

  • Recipients

Trendlab SAS is the only recipient of your Personal Information. It will never be transferred to a third party, in an individual or aggregate form, notwithstanding the data processors we use (further information about them can be found in Section 7 below). Neither Trendlab SAS nor any of its data processors market the personal data of visitors or users of its Website.

 

  • Retention period

We retain your Personal Information for no longer than is necessary for the purpose of the collection, as stated in Section 2 above, and, in any event, for no longer than 24 months.

 

  • Data subject rights

You hold the rights listed below in relation to your Personal Information, which may be exercised by sending a written request to us at the postal address specified in Section 1 or by contacting the Data Protection Officer: Eric Fejan, dpo@nellyrodi.com.

 

o Right of access and right to obtain a copy of your data

You have the right to access your Personal Information.

 

However, due to our obligation to process personal data securely and confidentially, your request will only be processed if you provide proof of your identity, in particular a scan of a valid identity document (for requests submitted via our special electronic form) or a signed photocopy of a valid identity document (for requests submitted in writing).

 

We have the right, where appropriate, to decide not to comply with any requests that are manifestly abusive (excessive number of requests or repetitive or systematic requests).

To help you exercise your rights, in particular if you wish to exercise your right of access by sending a written request to the postal address specified in Section 1, the French Data Protection Authority (CNIL) has produced a template letter, which may be accessed by clicking here.

https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

 

o Right to rectify data

Under this statutory right, you may request the rectification, updating, blocking or erasure of any of your personal data that may be inaccurate, erroneous, incomplete or out of date.

 

You also have the right to give general and specific instructions on what should happen to your personal data after your death. Where appropriate, the heirs of a deceased may require the death of their relative to be taken into account and/or the necessary updates to be made.

To help you exercise your rights, in particular if you wish to exercise your right to rectification, on your own behalf or for a deceased relative, by sending a written request to the postal address specified in Section 1, the CNIL has produced a template letter, which may be accessed by clicking here.

https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

 

o Right to object

This right may only be exercised in one of the following two situations:

  1. The exercise of the right is based on legitimate grounds; or
  2. The exercise of the right is intended to prevent the collected data from being used for direct marketing purposes.

 

To help you exercise your rights, in particular if you wish to exercise your right to object by sending a written request to the postal address specified in Section 1, the CNIL has produced a template letter, which may be accessed by clicking here.

https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

 

  • Response times

We undertake to respond to your request exercising your right of access, right to rectification or right to object or any other additional request for information within a reasonable time and, in any event, within one month of receipt of your request.

 

  • Accredited providers and transfers to countries outside the European Union

We use accredited providers to facilitate the collection and processing of the data you provide. They may be located outside the European Union and they receive the data collected via the various forms on the Website.

Before they are used, we check that they have implemented appropriate safeguards and that they meet strict confidentiality, use and protection requirements for data. We specifically check that there is a legal basis for any transfer of data to a third country. In this respect, one of our providers is subject to Binding Corporate Rules approved by the CNIL in 2016.

 

  • Complaints to supervisory authorities

If you believe that we have breached our obligations with respect to your Personal Information, you may lodge a complaint with or submit a request to the appropriate authority. In France, the relevant authority is the CNIL and requests may be submitted electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

 

 

 

  1. COOKIES POLICY

When you visit our website for the first time, a banner will be displayed at the bottom of your screen informing you that your browsing data may be recorded in files called cookies. Our cookies policy explains the steps we take to monitor users browsing our website. In particular, it lists all the cookies we use on our website and explains why we use them (part I.) and also explains how you can set your cookie preferences (part II.).

 

  • General information about the cookies used on our website

Trendlab SAS, as the publisher of this website, may install a cookie on the hard drive of your device (computer, tablet or mobile telephone etc.) to provide you with a smooth, enhanced browsing experience on our website.

 

Cookies are small text files containing small amounts of information that we use to recognise your computer, tablet or mobile telephone to customise the services we propose.

 

The information collected through cookies cannot be used to identify you directly. It is used solely for our own needs, to help us improve the interactivity and performance of our website and propose targeted content. None of the information is disclosed to third parties without your prior consent or unless the disclosure is required by law or under an order issued by a court or any administrative or judicial authority with the power to require its disclosure.

Further information about the types of data collected by cookies can be found in the table set out below, listing the different types of cookies that may be used on our website along with their name, purpose and retention period.

 

  • Cookie lifetime

Your consent is valid for up to 13 months. However, your consent is not required for some types of cookies (technical cookies).

  • Cookie preferences

You can enable or disable cookies at any time.

 

When you visit our website for the first time, a banner will be displayed at the bottom of your screen containing a brief explanation of the cookies and similar technology used. You are warned that if you continue to browse our website (by loading a new page or clicking on any component of the website for example), you will be deemed to consent to cookies being installed on your device.

 

You are also deemed to have consented to the installation of cookies if you click on the “X” icon to the right of the banner displayed at the bottom of your screen.

 

For some types of cookies, your consent must be obtained to install and read cookies on your device.

 

  1. Cookies that do not require consent

Pursuant to the recommendations of the French Data Protection Authority (CNIL), some cookies may be used without obtaining your prior consent as they are strictly necessary for the operation of the website or are solely used to allow or facilitate electronic communications. These include session ID cookies, authentication cookies, session load balancer cookies and cookies customising your interface. All provisions of this policy apply to those cookies, as they are issued and managed by us.

 

  1. Cookies requiring your prior consent

Your prior consent is required for cookies issued by third parties classified as “persistent” cookies, as they remain on your device until they are deleted or expire.

As they are issued by third parties, it is their privacy policies that govern the use and installation of the cookies, which can be consulted by clicking on the relevant link below. These types of cookies include analytical cookies (namely Google Analytics), advertising cookies (which are not used by us) and social media sharing cookies (mainly from Facebook, YouTube, Twitter and LinkedIn).

 

Analytical cookies compile statistics about the number of visitors and the use of the various components of the website (such as the content/pages you have visited). This data is used to improve the ease of use of our website.

An analytical tool is used on this website:

 

o Google Analytics whose privacy policy is available in English here:

https://policies.google.com/privacy?hl=en-CA

 

We use Google Analytics for an aggregate, anonymous analysis of website traffic. In order to track the use of your session, Google installs a cookie (_ga) with a randomly generated ClientID in your browser. This ID is anonymised and does not contain any identifying information such as email addresses, telephone numbers or names etc. We also send Google your IP address. We use GA to track behaviour on websites in an aggregate format, such as the pages you viewed, the time spent etc. This information is important to us as it helps us to enhance the user experience and assess the effectiveness of the website. Should you wish to access the browser information we hold for you – or ask us to delete the Google Analytics data – please delete your _ga cookies, contact us via this form and/or install the Google Analytics Opt-Out browser add-on.

 

Social media sharing cookies are issued and managed by the publisher of the relevant social media platform. With your consent, these cookies make it easier for you to share some of the content published on our website, in particular using a sharing “button” for some social media platforms. Four types of social media sharing cookies are used on our website:

 

o Facebook, whose cookie policy can be viewed by clicking here: https://fr-fr.facebook.com/policies/cookies/

o LinkedIn, whose cookie policy can be found by clicking here: https://www.linkedin.com/legal/cookie-policy?_l=fr_FR

o Twitter, whose options for controlling or restricting the use of cookies and its cookie policy are explained here: https://support.twitter.com/articles/20170518#

o YouTube, for which an explanation of how to delete cookies from the Google Chrome browser can be found here: https://support.google.com/youtube/answer/32050?hl=fr and its full cookie policy here: https://www.google.fr/intl/fr/policies/technologies/cookies/.

 

  1. You can set your cookie preferences in different ways.

Most web browsers enable cookies as their default setting. You can change the standard settings in your browser to systematically disable all cookies or enable or disable some of them only depending on the issuer.

 

NB: Please note that if you disable cookies on your device, this may affect your user experience and you may be ineligible for some of the services or functionalities available on this website. We disclaim all liability for the consequences of any negative effect on your browsing experience as a result of your decision to disable, delete or block the cookies needed for the operation of the website. Those consequences may not be treated as any type of damage or loss and you will not be entitled to claim any compensation in that respect.

 

Your browser settings may also be modified to delete cookies that have already been installed on your device and to send notifications whenever new cookies are to be installed on your device. These settings do not prevent you from browsing our website but you will not be able to benefit from the advantages of the cookie.

 

You will find, below, an explanation of the different methods for setting your cookie preferences on your device.

 

  1. Web browser settings

Each web browser has its own cookie preference settings. To find out how to change your cookie preferences, please click on the relevant link below to the help section explaining how to access your browser’s cookie menu:

Chrome: https://support.google.com/chrome/answer/95647?hl=fr

Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies

Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

Safari: https://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR

 

To find out more about how you can manage your cookie preferences, please consult the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser