PREAMBLE

The company GROUPE PREMIUM (hereinafter “GROUPE PREMIUM”) is a Simplified Joint Stock Company (Société par Actions Simplifiée) with a share capital of €3,613,762.35, having its registered office at 87-89 avenue Kléber, 75016 Paris, and registered with the Nanterre Trade and Companies Register under number 429 317 118.

GROUPE PREMIUM is committed to complying with the legislation in force in France and Europe (Regulation 2016/679 of April 27, 2016), ensuring the protection, confidentiality, and security of personal data, as well as ensuring respect for privacy.

This Personal Data Protection Policy (hereinafter “the Policy”) describes how GROUPE PREMIUM collects and processes the personal data of individuals affected by the processing operations implemented by GROUPE PREMIUM.

The Policy also specifies the legal bases on which we rely to process personal data, the persons with whom we share it, and how it is stored.

Depending on the processing operation, GROUPE PREMIUM acts as either a data controller or a data processor:

• when GROUPE PREMIUM processes data as a data controller, it means that GROUPE PREMIUM determines the purposes and means of the processing,
• when GROUPE PREMIUM processes data as a data processor, it means that GROUPE PREMIUM processes the data based on instructions from a data controller.

GROUPE PREMIUM adheres to the following principles:

• your data is used only for explicit, legitimate, and specified purposes. It is processed lawfully and fairly,
• only data that is useful to us is collected,
• you are informed in a clear and transparent manner about the purpose for which your data is used, the optional or mandatory nature of your responses in the form(s), and your data protection rights.
  
  
  

ARTICLE 1 – DEFINITIONS

• “Personal Data”: any information relating to an identified or identifiable natural person, directly (e.g., by first or last name) or indirectly (e.g., by reference to an identifier such as an identification number, location data, an online identifier, or one or more specific elements unique to their physical, physiological, genetic, mental, economic, cultural, or social identity).
• “Processing”: any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Data Subject” / “you”: an identified or identifiable natural person whose personal data is processed.
• “Data Controller”: a natural or legal person who, alone or jointly with others, determines the purposes and means of the processing.
• “Data Processor”: a natural or legal person who processes personal data on behalf of the data controller.
• “Cookie”: trackers that allow access to information stored in a visitor’s terminal equipment.
• “Recipient”: a natural or legal person to whom personal data is disclosed, whether a third party or not.
• “Third Party”: an authorized natural or legal person, public authority, agency, or body other than the data subject, the data controller, the data processor, and persons who, under the direct authority of the data controller or data processor, are authorized to process personal data.
• “Personal Data Breach”: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
• “You” / “your” / “user”: refers to the data subject whose personal data is processed by GROUPE PREMIUM.
  
  
  

ARTICLE 2 – FOR WHAT PURPOSES IS YOUR DATA PROCESSED?

Your personal data is used for the following purposes:

• managing requests from a user of the GROUPE PREMIUM website,
• compiling statistics, particularly regarding audience measurement.

ARTICLE 3 – ON WHAT LEGAL BASIS IS THE DATA PROCESSED? HOW LONG IS MY DATA STORED?

ARTICLE 4 – WHO ARE THE RECIPIENTS OF YOUR DATA?

Only persons who need to know your data as part of their duties have access to it. These include:

• GROUPE PREMIUM employees,
• administrative and judicial authorities to satisfy legal and regulatory obligations,
• GROUPE PREMIUM data processors, if necessary.

ARTICLE 5 – DATA TRANSFER OUTSIDE THE EUROPEAN UNION

When the processing of your data involves a transfer outside the European Union, these transfers are carried out in exchange for appropriate guarantees regarding data confidentiality and security, in full compliance with applicable regulations. Transfers outside the European Union are based on standard contractual clauses, in accordance with the clause models validated by the European Commission.

ARTICLE 6 – WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL DATA?

Regarding your personal data, you have the rights of access, rectification, erasure, restriction, objection, and withdrawal of consent.

To learn more about your rights, you can visit the CNIL website (http://www.cnil.fr/en/understanding-your-rights).

When requesting to exercise your rights, proof of identity may be requested, particularly to maintain the security of the processing that is the subject of the request.

A response will be sent to you, depending on the complexity of your request, within the timeframes prescribed by Article 12.3 of the GDPR. For any complaint to the National Commission for Information Technology and Liberties (CNIL), you can write to the following address: CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris cedex 07.

ARTICLE 7 – HOW IS YOUR PERSONAL DATA PROTECTED?

GROUPE PREMIUM ensures that data is processed with full security and confidentiality, including when certain operations are carried out by data processors.

To this end, we implement appropriate technical and organizational measures to prevent the loss, misuse, alteration, and deletion of your personal data.

These measures are adapted according to the sensitivity level of the data processed and the level of risk presented by the processing or its implementation.

If a security breach concerning your data occurs, we will inform you within the timeframes and according to the procedures specified by the legal and regulatory provisions in force.

ARTICLE 8 – HOW DO I EXERCISE MY RIGHTS?

To exercise your rights, the GROUPE PREMIUM Legal Department is at your disposal at the email address juridique@groupepremium.com or at the postal address GROUPE PREMIUM – Direction Juridique, 87-89 avenue Kléber 75016 Paris.

In accordance with Article 12 of the GDPR, GROUPE PREMIUM has one month to respond to your request. This period may be extended by two months, taking into account the complexity and number of requests.