We, the Sperian Protection group and Sperian Protection Europe (the words “we” or “our” must hereinafter be understood to refer to the said group), are aware of your natural concern with regard to privacy and the protection of your personal information, and thank you for placing your confidence in us.
This Policy describes the types of personal data concerning you that we collect on this Internet site (the “Site”) available at the www.sperian.com/eu Internet address (or at any other address substituted for it). It explains the way in which we may use this information and with whom we may possibly share it, subject to the respect of the applicable legislation, and explains your rights vis-à-vis such use. Our Policy also describes the measures we take in order to ensure that your personal data (as defined below) is secure, and explain how you can access such data and rectify it or ask questions concerning our Data Protection Policy. We hope that this Policy will help you feel that you can use of the Site Sperian Protection Europe in complete confidence.
We recommend reading this Policy before communicating your personal data to us. In accessing the Site and/or using our online services, you are signifying your consent to our collecting and processing your personal data under the conditions and in accordance with the modalities set forth below. If you do not agree to nor accept the terms of this Policy, we will be constrained to ask you not to make any further use of the Site.
To whom or what is the Policy for the protection of privacy and personal data applicable?
This Policy is applicable any Internet User visiting the Site and to the website of Sperian Protection Europe, available at the www.sperian.com/eu address (or at any other address that may be substituted for it).
What constitutes personal data?
Any information relating to a private individual who is or can be identified, directly or indirectly, by means of that information constitutes personal data.
Who is responsible for processing your personal data?
The data controller responsible for processing the data is Sperian Protection Europe, a société par actions simplifiée, with a capital of 17 750 000 euros, listed in the Bobigny Trade and Companies Register under the number 348 982 307, the registered office of which is at 33, rue des Vanesses - 93420 Villepinte - France (hereinafter referred to as “Sperian Protection Europe”).
How and why do we collect your personal data on the Sperian Protection Europe Site?
We collect your personal data on the www.sperian.com/eu site for reasons that we indicate to you before actually collecting your Data. Sperian Protection Europe collects your personal data in the cases and for the end purposes listed below. This list is exhaustive:
- Personal information: Sperian Protection Europe collects information which enables you to be directly or indirectly identified, such as your civil status, surname, first names, personal or professional address, fixed-line telephone number and fax number, e-mail address, name of your employer. You may of course refuse to provide us with this personal information, but in that case we shall be unable to offer you the services proposed on the Site.
This data is collected when you create your personal “My Sperian” account on the Site in order to be able to make use of the downloading services offered by the Site, and the “My favourites” and “Depreciation test” services.
This information is necessary to enable you to be authorized to legally make downloads from the Site and to enable (i) Sperian Protection Europe to provide you with the information you require concerning your Sperian products and/or (iv) enable Sperian Protection Europe to provide you with the “My favourites” service to create a tool for classifying the product sheets available on the Site.
We may have occasion to use your personal data in order to send you messages by letter, e-mail, fax, SMS and/or telephone concerning Sperian products that might be of interest to you. You may at any time unsubscribe to this service, at no cost (apart from the cost of sending your unsubscribe request) by following the instructions given in these messages or by contacting our data protection officer, whose contact details are given at the end of this Policy.
- Cookies: A cookie is generally speaking known as an alphanumerical identifier that we transfer to your hard disk via your browser when you visit the Site. This enables a system to recognize you when you next visit the site in order to be able, for example, to improve a service. The cookies are also used to compile information about the areas of the Site which are most frequently visited. This information about visits may be used to enhance the content of a site and make it easier to use. Please note that we only use session cookies. Session cookies are a cookie that do not remain on your hard disk after your browser is closed; which means that no information concerning you can be stored once your browser is closed. The cookies are only installed in your computer temporarily, and memorize personal information concerning you for the period of the session. This information is erased when you log off from the Site. The sole purpose of these session cookies is to facilitate your use of the Site.
- Connection data: The Site collects connection data susceptible of identifying you, such as the type of browser used, the operating system used and other connection data and files that the Site collects automatically, such as the identity of your Internet service provider, the name of the site from which you accessed our Site, your geographical area, the pages you visited on the Site, the time spent on each page, etc.. This data is used to manage the Site and analyze visits to the Site and frequentation of it in order to optimize the presentation and navigation on it and with a view to ensuring maximum ease of use for those who visit it and draw up commercial statistics concerning the profile of users of the Site.
Must you communicate personal data in order to be able to use the Sperian Protection site?
We do not ask you to communicate personal data in order to access or use the Site or consult the greater part of it. You can of course always refuse to provide personal data. However in that case we shall not be able to provide you with the “My favourites” and “Depreciation tests” services offered on the Site; moreover you will not be authorized to make downloads from our Site.
If you decide to communicate personal data to us but prefer not to receive commercial messages from us in future, you can at any time unsubscribe to this service, at no cost (apart from the cost of sending your unsubscribe request) by following the instructions given in the messages or by contacting our data protection officer, whose contact details are given at the end of this Policy.
Is this site intended for use by minors?
Our Site is not intended for minors but for persons aged at least 18. It must be exclusively used by such persons.
We do not knowingly collect or process any personal information concerning minors. Should we find that we have been collecting personal data concerning minors via the Site, we shall take the appropriate steps to delete this personal data from our servers.
With whom will we share your personal data?
We are the only holders of information collected on the Site. We shall not under any circumstances sell, lease or divulge your personal data to any third party without your express consent, subject to the provisions set forth below.
We may have occasion to reveal your personal data to our subsidiaries or to affiliates belonging to the Sperian Protection group in the context of our joint policy concerning the protection of privacy and personal data, for the purpose of enabling them to help us provide you with our services, including our marketing services.
In the context of providing services on the Site, we may have occasion to call on the skills of third party companies to help us provide you with these services. These companies include service providers supplying marketing services, web hosting firms, and suppliers of Internet services, who help us, maintain and manage our activities on the Site. These suppliers, service providers and marketing partners may only use your personal data to provide services to Sperian Protection Europe in the context of the end purposes for which Sperian Protection Europe collected the data in question. They may not use this information for any other purpose and may not under any circumstances divulge it.
We may also have occasion to transfer our database, including personal data concerning you, to a third party company in the event of a sale, merger, or transfer of all or part of the assets or stock of Sperian Protection Europe or of the Site, or in the context of reorganization or other analogous operations, even when the operation in question is only at the project stage. If a transfer of this type takes place, we shall make all reasonable efforts to try to ensure that the third party company concerned uses and/or divulges personal data concerning you in accordance with the terms of this Policy.
We may also divulge your personal data in response to a request made by the administrative or legal authorities, or in order to comply with our legal and regulatory obligations, protect and uphold our rights and interests, and/or prevent any misuse, unlawful use or unauthorized use of the Site.
Lastly, with your prior consent, we may communicate your personal data to our commercial partners to enable them to send you sales communications by e-mail, SMS, letter or telephone.
Will we transfer your personal data outside the European Union?
Sperian Protection Europe may have occasion to transfer your personal data to subsidiaries and/or companies affiliated to the Sperian Protection group, the list of which is available via the following hyperlink: www.sperian.com/Europe/Contacts.aspx ; certain of these are situated in countries that are not members of the European Union and do not afford personal data with a level of protection that is adequate as understood by French and EU legislation. In that event Sperian Protection Europe will ensure that any exchange of your personal data is secure, either by setting in place a data transfer agreement drawn up in compliance with the standard clauses stipulated by the European Commission or by any other means that is appropriate by virtue of the legislation applicable.
By using the Site and the services on the Site, you expressly agree to have your personal data transferred outside the European Union to the above-mentioned Sperian Protection group companies.
How will we protect your personal data?
We attach great importance to ensuring that your information is processed securely and on a confidential basis, and we take adequate administrative, technical, physical security, contractual and organizational measures to avoid the loss, revelation, wrongful use, alteration or deletion of personal data concerning you.
We set in place secure data systems that are in compliance with standards that are widely accepted throughout the industry, including encryption of the data storage systems.
Only employees who have to access your information in order to carry out a task or specific function for the purposes provided for in this document are authorized to access the said information. In addition, all the employees of Sperian Protection Europe are bound by confidentiality obligations.
Hyperlinks to other sites
The Site contains links to other Internet sites belonging to third parties that are not members of the Sperian Protection group and which operate independently of this Site and our group, and over which we have no control. We place hyperlinks to these sites at your disposal solely for your convenience and by way of information. This Policy applies only to our Site and does not cover information collected and/or processed on these third party sites. These sites may contain their own Policy for the protection of personal data, in which case we strongly recommend that you consult it attentively before using the sites in question. We are not responsible or liable for the practices with regard to the collection, use or divulging of personal data followed by these sites.
How long will your personal data be kept for?
We undertake to keep your personal data for the period strictly necessary for the processing envisaged and at all events within the limits imposed by the law. Your data will be kept for up to two years after the date of your last visit to the Site in order to enable us to manage our commercial relationship with you. In the absence of visits on your part, you will be warned by e-mail that your account has not been activated for several months. If you make no new visit, we shall unfortunately be forced to de-activate your account in order to guarantee optimum use of the Site for other Internet users. We trust you will understand why we implement this policy.
What are your rights concerning personal data collected on this Site?
We are conscious of how important it is for any information concerning you or your company to be wholly accurate. In accordance with the law of January 6 1978, modified, on Data Protection, and with the European Data Protection Directive n°95/46, you are entitled to access or rectify personal data concerning you or object, if there are legitimate reasons, to our processing of your personal data.
Accordingly, in the light of the nature of any information that you wish to update or clarify, and the circumstances in which it was collected, you may ask Sperian Protection Europe to communicate your personal data to you, and request it to correct, delete or add to your personal data and send you a copy of the amendments recorded. You also have the right to forbid Sperian Protection Europe to use your personal data for processing purposes or for commercial ends, and prohibit it from divulging your personal data to third parties. You may exercise these rights at any time by writing to us at the address given at the end of this Policy.
How can you contact us and/or ask questions concerning this Policy?
If you wish to contact us or ask questions concerning this Policy or use of your personal data, please write to the data protection officer at the following address:
Sperian Protection Europe Direction des Systèmes Informatiques Responsable des Données personnelles ZI Paris Nord II 33, rue des Vanesses BP 55288 95958 Roissy CDG cedex France