Privacy policy Familycorp International

Last update: 26/11/2019

Table of content

Article 1 - Acceptance and modifications of the Privacy Policy

Article 2 - What information is collected and how is it collected?

Article 3 - Why and how we use your Personal Data?

Article 4 - When we disclose your information

Article 5. Place of storage of Personal Data

Article 6. How do we protect your information?

Article 7. Other important information

Article 8 - Your choices and rights

Article 9 - Cookies

Article 10 - Applicable law and disputes

Specific definitions within the T&Cs are also applicable to this Privacy Policy.

The confidentiality of your Personal Data is of paramount importance to us. We have therefore implemented strict rules and procedures to protect them.

You are fully aware that the Personal Data submitted and collected will be processed automatically.

Article 1 - Acceptance and modifications of the Privacy Policy

This Privacy Policy regulates the collection, processing and disclosure of your Personal Data by us in connection with the provision of the Platform and Services. It also details how to exercise your rights as a person concerned by Personal Data. 

You must read the entire Privacy Policy and accept it without reservation.

This acceptance will be expressed by checking the box corresponding to the acceptance sentence of the Privacy Policy when registering for the Platform, for example, with the mention "I acknowledge having read and accepted the Privacy Policy".

We reserve the right to change the Privacy Policy at any time by posting a new version on the Platform, notifying you by email or by notifying you when you next connect to the Platform.

If you do not accept the amended Privacy Policy, you may exercise your right of refusal by deleting your User Account. Before this deletion of the User Account, you have the possibility to recover your data.

The applicable Privacy Policy is the last one accepted.

Article 2 - What information is collected and how is it collected?

2.1. We may collect "Personal Data" (information that identifies you or relates to you as an identifiable person, in accordance with applicable regulations) about you, such as:

- Name ;

- First name ;

- E-mail address;

- Password;

- Mailing address (address, postal code, city, country);

- Languages (mother tongue, other spoken languages);

- Number of your children (if declared), age group of your children;

- Interests, environment (in the form of pictograms);

- IP address or device ID.

2.2. We may collect information about you when you interact with us on the Platform or within the Services, such as when you:

- You register for the Platform and Services;

- You fill in your Profile;

- You use the Platform and Services in general;

- Contact us for a question or request;

- Share a story or experience;

- Enjoy, follow or otherwise connect or publish content on one of our social networking pages.

2.3 We may also collect the following information about you: 

- Cookies: see "Cookies" article.

- Mobile Devices: When you use or access the Platform or our Services from a mobile device, we may collect information such as your unique device ID and location.

- Other non-directly identifiable information: In addition to the Personal Data or other information you choose to provide to us within the Platform or Services, we and our third-party service providers may use various technologies, already designed or developed in the future, that automatically collect certain website usage information each time you visit or interact with the Platform and Services. This information may include the type of browser, operating system, page served, time, source of request, page previously viewed and other similar information. We may use this usage information for a variety of purposes, including to strengthen or improve the Platform and Services. In addition, we may also collect your IP address or other unique identifier of the particular device you use to access the Internet, if applicable (collectively, referred to below as "Device ID"). A Device ID is a number that is automatically assigned to your device; we can identify your device by its Device ID. When analyzed, usage information helps us determine how our Platform and Services are used, such as the types of visitors who access them, the most popular type of content, the type of content you may find more relevant and the type of visitors who are interested in certain types of content and advertising. We may associate your Device ID or website usage information with the Personal Data you provide, but we will treat the combined information as Personal Data.

If we combine anonymized or aggregated data with Personal Data, we will treat the combined information as Personal Data in accordance with this Privacy Policy.

2.4. This Personal Data may be collected as follows:

- When filling in a form within the Services or the Platform (creation and edition of a User Account, message exchanges, publication of a Profile);

- When registering for the Platform and Services;

- When you subscribe to our newsletter;

- When you contact us, for any reason whatsoever;

- When you navigate within the Platform and Services.

Article 3 - Why and how we use your Personal Data?

3.1 We use your Personal Data to provide the Services and the Platform, to perform our contractual obligations to you under the T&Cs.

Personal Data is thus used to:

• Provide the Platform and Services;
• Answer your questions and satisfy your requests, especially with regard to support;
• Send you administrative information, for example, information about the Platform, the Services or an event in which you are participating.

3.2. We may use your Personal Data for the purpose of our legitimate business interests, including, but not limited to:

- Personalize your experience within Services by presenting you with tailor-made products and offers.

- Perform data analysis, audits, surveillance and fraud prevention, internal quality assurance, develop new products, strengthen, improve or modify the Platform and Services, identify usage trends, audit the use and functionality of the Platform and Services, enforce our terms of use, contribute to the protection of the Platform and Services, determine the effectiveness of our promotional campaigns and operate and develop our business activities.

3.3. Subject to your prior consent, we may send you newsletters or marketing communications that we believe may be of interest to you, for our own products and services, and on behalf of our partners, by post, e-mail, telephone or text message.

You have the right to refuse to give your consent and to withdraw it at any time, by using the unsubscribe function in the email you receive from us, or by contacting us at the email address provided here in.

3.4. We may use your Personal Data, if necessary or appropriate for legal reasons, including, but not limited to:

- Under the applicable law;

- To comply with a legal procedure;

- To respond to requests from public authorities, including outside your country of residence.

3.5. We also use non-personal information in a variety of ways, including to analyze site traffic, understand customer needs and trends, conduct targeted promotional activities and improve our services. We may use your non-personal information on its own or aggregate it with information we have obtained from other sources. We may share your non-personal information with our affiliates and third parties to achieve these and other purposes, but this aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this does not imply the disclosure of your personally identifiable information.

Article 4 - When we disclose your information

Personal Data will never be disclosed to a third party without your prior consent. By way of derogation from this, we inform you that personal data may be disclosed to the third parties specified in this Article.

These subcontractors have undertaken to us to comply with their legal and regulatory obligations with respect to Personal Data.

4.1. Subcontractors and service providers

We may disclose your Personal Data to subcontractors and service providers that we employ in the course of our business, such as: website hosts, customer service, e-mail distribution, legal advisors, accountants or others.

We currently use OVH, for our web hosting.

We can modify this list of service providers at any time. We will notify you of this in the Privacy Policy or in writing.

4.2 Merger or acquisition

We may disclose your Personal Data to a third party who acquires part of our business, whether such acquisition is the result of a merger, consolidation, divestiture, spin-off restructuring or purchase of all or a substantial part of our assets.

4.3. Disclosure authorized by law

We may disclose your Personal Data to law enforcement authorities, the State, public bodies or civil servants, regulatory bodies and/or any other person or entity with legal authority or justification for receiving your information, if required or permitted by law or legal process, to respond to claims, or to protect our rights, interests, confidentiality, property or safety, yours or those of others.

Article 5. Place of storage of Personal Data

The Personal Data collected is stored within the European Union by a service provider that applies industry standards in terms of IT security.

No data will be transferred outside the European Union.

Article 6. How do we protect your information?

6.1. We will take reasonable steps to protect the Personal Data you provide to us from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We have put in place appropriate physical, electronic and managerial procedures to protect and secure your information against loss, misuse, unauthorized access or disclosure, alteration or destruction.

We ensure that Personal Data is stored under conditions that comply with industry standards. In particular, we undertake to comply with the regulations applicable to the security of Personal Data.

The Platform and Services are secured by an SSL certificate and communications are encrypted. However, no security system is 100% secure, so we cannot guarantee the security of all the information you provide to us through the Platform and Services.

We ensure that our employees and service providers who process Personal Data are subject to an appropriate obligation of confidentiality.

In the event of a breach of Personal Data, we will notify you as soon as possible.

We will store Personal Data for the duration of the validity of the User Account.

If the Account has not been active for thirty-six (36) months, or if the User Account is deleted for any reason whatsoever, the Personal Data will be deleted automatically, with the exception of those strictly necessary to maintain our commercial accounting and to comply with our legal obligations.

Article 7. Other important information

7.1. Information provided on behalf of someone else

If you provide us with information about someone else, you guarantee that the person concerned has authorized you to do so, for the purposes detailed in the Privacy Policy.

7.2. Links to websites:

The Services may contain links to other websites that are not maintained by us. We have no control over how these websites may collect your information or any responsibility for the practices, policies and security measures implemented on these websites.

You should read the privacy policies of these other websites before submitting your information through them.

7.3.  Social networking sites:

When using social networking sites, we will make our best efforts to keep you informed of the collection, use and disclosure (including data security) policies and practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other application developer, application provider, social networking platform provider, operating system provider, mobile service provider or device manufacturer.

However, we shall only be liable in accordance with the applicable regulations, to the exclusion of any other liability.

7.4. Telephone calls:

We are committed to providing excellent customer service. We may from time to time monitor or record telephone conversations you have with our staff for training purposes and to improve the quality of our service. You will be informed in advance.

Article 8 - Your choices and rights

In accordance with the French Data Protection Act and the RGPD, you have the following rights for all Personal Data we collect;

• Right of access,
• Right of rectification and modification,
• Right to limit processing,
• Right of opposition,
• Portability rights.

In particular, you may at any time withdraw a consent you have given us to process your Personal Data.

It is possible to exercise these rights by contacting us by email at contact@familycorp.com or by post at: 35 ter avenue Pierre Grenier, 92 100, Boulogne-Billancourt, France.

We may ask you to confirm your identity and provide more details about your request.

In accordance with our legal obligations, we will respond to you within a maximum of one (1) month from receipt of the request.

Article 9 - Cookies

We may use the following cookies within the Platform and Services:

- Internal cookies that have the following functions:

o Establish attendance statistics (number of visits, page views, abandonment in the ordering process) in order to monitor and improve the quality of the Platform and Services. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

o Adapt the presentation of the Platform and Services to the display preferences of the user terminal. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

o Store information entered in forms, manage and secure access to reserved and personal spaces such as the User Account. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

o Provide content, including advertising, related to your interests and customize the offers that are addressed. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

o Send offers by email upon registration by you. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

- Third-party cookies have the following functions:

o Google Analytics (https://marketingplatform.google.com/about/), the purpose of these cookies is to allow us to collect traffic statistics. It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

o Social network cookies. These cookies are intended to link the Platform, Services and social networks (sharing, log-in). It is possible to exclude their installation, as they are not mandatory for the proper functioning of the Platform and Services.

It is possible to prevent the installation of cookies in the following way:

- By refusing them on the banner for this purpose.

- By deleting them via the appropriate browser option.

o Google Chrome: Tool Menu / Settings / Show advanced settings / Content Settings / Allow local data storage.

o Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

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

o Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

Only technical cookies cannot be rejected, as they are necessary for the proper functioning of the Platform and Services.

You have the ability to accept some cookies and refuse others, to accept all of them, or to refuse all of them, it being understood that this may disrupt the operation of the Platform and Services in the case of functional cookies.

These cookies are installed for a maximum duration of thirteen (13) months.

Article 10 - Applicable law and disputes

The law applicable to this agreement is French law.

The Privacy Policy is written in French, and the French version will prevail even in the event of translation into another language.

You may submit to the CNIL any dispute relating to the execution or interpretation of the Privacy Policy, which has not been resolved amicably between the Parties.

It may also be submitted to the competent court of our registered office, including in matters of summary proceedings, a warranty claims or a plurality of defendants, and regardless of your country of origin.