Legal information

GDPR policy

Last updated: 04/18/2022

Preamble

1Clusif attaches the greatest importance to the protection of the personal data and privacy of its clients as well as of any person who accesses its websites and applications (hereinafter “Sites”).

All operations on your personal data are carried out in compliance with the regulations in force and, in particular, with the amended law n°78-17 “Informatique et Libertés” of January 6, 1978 and Regulation n°2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

This personal data protection policy (hereinafter “Policy”) describes how 1Clusif (hereinafter “1Clusif” or “we”) processes the personal data of policyholders and their beneficiaries, clients and their representatives, any natural or legal person entering into a commercial or non-commercial relationship with 1Clusif, and any other internet user who accesses the Sites (hereinafter “the User” or “you”).

Article 1. Definitions

The terms and expressions beginning with a capital letter, whether used in the singular or plural, shall have the meaning given to them below:

“personal data”: any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to them.

“processing of personal data”: any operation or set of operations carried out or not using automated processes and applied to data, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, erasure or destruction, etc.

“data controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, collects and processes personal data.

“recipient”: the natural or legal person authorized to receive communication of data recorded in a file or a processing operation by reason of their functions.

“services”: the services provided by 1Clusif, in particular through the Sites.

Article 2. Scope

1Clusif carries out an e-commerce activity, within the meaning of law n° 2004-575 of June 21, 2004 on confidence in the digital economy.

The purpose of this Policy is to inform Users of how their personal data is collected and processed by 1Clusif.

Article 3. Identity of the data controller

Personal data is collected by 1Clusif, an association under the French law of 1901, registered with the prefecture/sub-prefecture of 13 – Marseille Prefecture under number W133036148, having its registered office at 6 rue Jean-Baptiste Reboul – Le Palladium Bât B 13010 MARSEILLE, represented by Jérôme SAVAJOLS duly authorized.

Article 4. Purposes and legal bases for the processing of personal data

In the context of operating the Sites and/or providing the Services, 1Clusif may collect and carry out processing of Users’ personal data, the purposes and legal bases of which are described below.

The original layout presents this information in a two-column table; since automatic content extraction does not allow the exact row-by-row correspondence to be reconstructed, the purposes and legal bases are reproduced below in their original order, without an asserted link between a specific purpose and a specific basis.

Processing purposes

  • Managing their membership in the association.
  • Subscribing to communications and newsletters.
  • Participating in events related to the association’s purpose.
  • Managing access to the Sites and their use.
  • Compiling statistics and traffic measurements for the Sites.
  • Processing applications submitted through the recruitment form.

Legal bases

  • Performance of pre-contractual or contractual measures.
  • Express and specific consent of Users (*).

(*) This consent may be withdrawn at any time by the User.

When data is collected, the User will be informed, by means of an asterisk, whether certain data must be provided or is optional. The mandatory information we request is necessary for providing the expected service. If you do not provide it to us, 1Clusif may be unable to process the request or form in question.

Article 5. Nature of the data processed

1Clusif may collect the following data:

  • civil status data: surname, first names, address, telephone number (landline or mobile), postal and email address, date and place of birth, gender;
  • connection data, in particular when using our online services (IP addresses, logs, device identifiers, login credentials);
  • contact data relating to newsletter subscriptions: surname, first name, address, telephone number (landline or mobile), fax number;
  • location and geolocation data of persons in connection with insured risks or the services offered;

If you provide us with third parties’ contact details, please ensure that you communicate this Policy to those third parties before any communication of their data to 1Clusif.

Article 6. Collection of processed data

Data is collected:

  • either directly from you as part of a contact form, membership application or subscription to one of our Services;
  • or from 1Clusif staff

Article 7. Data recipients

Strictly within the scope of the stated purposes and as needed, the recipients of the collected data are:

  • the various departments and entities of 1Clusif in the course of carrying out their duties;
  • 1Clusif’s subcontractors and service providers

Where 1Clusif entrusts data processing activities to subcontractors, the latter will in particular be chosen for providing sufficient guarantees as to the implementation of appropriate technical and organizational measures, in particular in terms of reliability and security measures.

Article 8. Data transferred to authorities and/or public bodies

In accordance with the regulations in force, data may be transmitted to the competent authorities upon request, in particular to public bodies, exclusively in order to comply with legal obligations, to legal officers, to ministerial officers and to bodies responsible for debt collection.

Article 9. Data transferred abroad

In the event of a transfer of personal data for the purposes described above between countries that are members or non-members of the European Economic Area, and when this proves essential for providing its Services or for complying with its legal obligations, 1Clusif undertakes to use third parties located in a State considered by the European Commission to ensure an adequate level of protection.

Where the third party is not located in a State considered by the European Commission to ensure an adequate level of protection, 1Clusif then contractually sets out compliance with data protection and information security provisions with the recipients concerned and takes all measures necessary to ensure strict observance of the guarantees by third parties.

Article 10. Retention periods

1Clusif will retain the User’s personal data in a secure environment for the period necessary to achieve the purposes for which it was collected, or for the minimum retention period provided for by applicable legislation, particularly in civil and commercial matters.

Some personal data may be retained by 1Clusif for longer periods exclusively for archiving or statistical purposes.

Data processed in the context of prospecting operations with the User’s agreement may not be retained for more than 3 years after the last contact from the User or in the context of their objection.

Article 11. Social networks

If the User has an account on social network sites and accesses the Sites without having first registered for the Service, 1Clusif may receive information from said social networks in order to facilitate the creation of an account on the Sites.

When the User uses a Service via a social network site, the User authorizes 1Clusif to collect, store and use all information they have provided to the social network site, such as their username, first and last name, profile picture and data relating to their use of that Service.

Article 12. Protection of minors’ personal data

1Clusif’s Sites are not intended for minors under fifteen (15) years of age.

If you are under fifteen (15) years of age, we ask you not to provide personal data via 1Clusif’s Sites.

Article 13. Cookies

The User is informed, on their first visit to the Sites, by means of a banner appearing on the access page to the Sites, that cookies or other technologies are used when connecting to the Sites and using the Services, subject to the choice expressed by the User; this choice may be changed at any time.

A cookie allows its issuer, during its period of validity, to recognize the terminal concerned (computer, tablet, smartphone, etc.) each time that terminal accesses digital content containing cookies from the same issuer. A cookie records information relating to the User’s computer browsing on our Sites (pages viewed, date and time of consultation, etc.) which we may read on subsequent visits.

These cookies facilitate navigation and improve the usability of the Site. The User may object to the recording of cookies by configuring their browser settings, as indicated below. Access to certain services and sections of the Sites may, in this case, be impaired or even impossible.

Several types of cookies may be used by the Site:

  • cookies strictly necessary for browsing the site and ensuring its proper functioning;
  • cookies used to compile traffic statistics;
  • advertising cookies used to provide offers related to the User’s interests.

a) Site browsing cookies

Browsing cookies improve the performance of the Services in order to provide the User with a better use of the Site. These cookies do not require the User’s prior information and agreement to be placed on the User’s device.

More specifically, these browsing cookies allow, among other things:

  • adapting the presentation of the Site to the display preferences of the device (language used, display resolution, operating system used, etc.) during Users’ visits to the Site, depending on the hardware and viewing or reading software the device includes;
  • accessing a restricted area requiring a username and password;
  • remembering information relating to a form the User has filled out on the Site or information the User has chosen on the Site;
  • offering the User access to their account or any other restricted area using their credentials;
  • implementing security measures, for example when the User is asked to log in again to content or a Service after a certain period of time has elapsed.

b) Audience measurement cookies

Audience measurement cookies help compile statistics and traffic and usage volumes for the various elements making up the Site (sections and content visited, browsing paths), enabling 1Clusif to improve the relevance and usability of the Services.

c) Advertising cookies

Advertising cookies make it possible to determine in real time which advertisement to display based on the User’s recent browsing on the Site, in order to limit the number of times the User has seen an advertisement and to help measure the effectiveness of an advertising campaign.

Advertising content may contain cookies issued by third parties: either the advertiser behind the advertising content concerned, or a company other than the advertiser (communications consulting agency, audience measurement company, targeted advertising provider, etc.) or advertising network, which has associated a cookie with an advertiser’s advertising content.

d) Google Analytics and Privacy

This Site uses a web analytics service provided by Google Inc (“Google”).

Google Analytics uses “cookies,” text files stored on the User’s computer, which enable analysis of the Site’s use.

The information generated by cookies concerning the use of this Site is transmitted to and stored on a Google server in the United States. Google uses this information to evaluate the use of the Site, compile reports on Site activity for its operators, and provide other services related to the use of the Site and the Internet. Google may also transmit this information to third parties where required by law or where such data is processed by third parties on Google’s behalf. Under no circumstances will the User’s IP address be associated with other Google data. The User can disable cookies by changing their browser settings; in which case they will not be able to use all the functions of this website. The User can, at any time, cancel the collection and storage of data by Google Analytics for the period following the time of cancellation, by downloading a browser add-on to disable Google Analytics and installing it for their browser. The opt-out add-on can be found at http://tools.google.com/dlpage/gaoptout?hl=en.

The User can configure their browsing software so that cookies are saved on the device or, conversely, rejected, either systematically or according to their issuer. The User can also configure their browsing software so that they are offered the choice of accepting or refusing cookies on a case-by-case basis, before a cookie is likely to be saved on their device.

For managing cookies and User choices, the configuration of each browser is different. It is described in the browser’s help menu, which will explain how to change cookie preferences:

e) Retention period

The retention period for cookies varies depending on the type of cookie. We mostly use cookies that self-destruct at the end of the connection. These are known as session or browsing cookies. A log file also allows us to keep a history of all access to our web pages and the downloading of the various files available on our sites, for a period of 6 months. Finally, information concerning the User’s consent regarding cookies is kept for a maximum period of 13 months. Cookies are used for internal purposes only and are not accessible to third parties.

Article 14. Rights of individuals

In accordance with the amended law n°78-17 of January 6, 1978 and Regulation (EU) 2016/679 on the protection of personal data, the User has the following rights over their data: right of access, right of rectification, right to erasure (right to be forgotten), right to object, right to restriction of processing, right to portability.

The User may also set guidelines relating to the retention, erasure and communication of their personal data after their death.

For reasons relating to their particular situation, the User may object to the processing of data concerning them.

To exercise your rights, please send your registered letter with acknowledgment of receipt to the following address: 1Clusif 6 rue Jean-Baptiste Reboul – Le Palladium Bât B 13010 MARSEILLE. We recommend that you enclose proof of identity.

Subject to a breach of the above provisions, the User has the right to lodge a complaint with the CNIL www.cnil.fr.

Article 15. Security measures

Given the evolution of technologies, implementation costs, the nature of the data to be protected, and the risks involved, 1Clusif implements all appropriate technical and organizational measures to guarantee the confidentiality of the personal data collected and processed and a level of security appropriate to the risk.

Article 16. Changes to the privacy policy

In the event of a change to this Policy by 1Clusif, or if required by law, it will be published on the Sites and will take effect as soon as it is published. We therefore invite you to refer to it on each visit in order to review its latest version, permanently available on our websites.

It was last updated on 04/18/2022.

For any information on the protection of personal data, you can also visit the website of the Commission Nationale de l’Informatique et des Libertés (CNIL) www.cnil.fr.