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Important Notice:

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This English version of the Privacy Policy is provided for convenience and information purposes only. It is a an unofficial English translation of the original French-language Privacy Policy ('Politique de confidentialité') published on afineconseil.com.

While every effort has been made to ensure the accuracy of this translation, in the event of any inconsistency, discrepancy or conflict between the original French version and this English version, the French version shall prevail and shall constitute the only legally binding version.

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ARTICLE 1: PREAMBLE

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This privacy policy applies to the website: afineconseil.com.

 

The purpose of this privacy policy is to inform users of the website about:

• How their personal data is collected and processed. Personal data is defined as any data that can identify a user. This includes, in particular, first and last name, age, postal address, email address, the user's location, or their IP address;

• What rights users have regarding this data;

• Who is responsible for the processing of the personal data collected and processed;

• To whom this data is transmitted;

• Where applicable, the website's policy regarding "cookies."

 

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ARTICLE 2: GENERAL PRINCIPLES REGARDING DATA COLLECTION AND PROCESSING

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In accordance with the provisions of Article 5 of European Regulation 2016/679 (GDPR), the collection and processing of website users' data comply with the following principles:

• Lawfulness, fairness, and transparency: data may only be collected and processed with the consent of the data subject. Whenever personal data is collected, the user will be informed that their data is being collected and for what reasons;

• Limited purposes: data collection and processing are carried out to meet one or more specific objectives set out in this Privacy Policy;

• Minimization of data collection and processing: only the data necessary to properly achieve the objectives pursued by the website is collected;

• Limited data retention period: data is retained for a limited period, of which the user is informed. Where this information cannot be communicated, the user is informed of the criteria used to determine the retention period;

• Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

 

In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only take place if they meet at least one of the following conditions:

• The user has expressly consented to the processing;

• The processing is necessary for the performance of a contract;

• The processing is required by a legal obligation;

• The processing is necessary to protect the vital interests of the data subject or of another natural person;

• The processing is necessary for the performance of a task carried out in the public interest or falling within the exercise of official authority;

• The collection and processing of personal data are necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.

 

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ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN CONNECTION WITH BROWSING THE WEBSITE

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A. DATA COLLECTED AND PROCESSED, AND METHOD OF COLLECTION

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In general, users may visit the afineconseil.com website without having to identify themselves or provide any personal information about themselves.

 

The personal data collected on the afineconseil.com website is as follows:

• Name and email address, when the user makes contact through the website

• Technical browsing data that may be collected via cookies related to the operation of the Wix.com platform (marketing, functional, and analytical), subject to the user's consent obtained via the cookie banner. These cookies are not used by Afine Conseil for advertising or marketing purposes, and the data is not transmitted to third parties for commercial prospecting purposes.

 

This data is collected when the user performs one of the following actions on the website:

• The user uses the contact form to send a message

• The user accepts, via the consent banner, the use of non-essential cookies

 

The data controller will retain the data collected under reasonable security conditions, for a period of:

• 1 year for data collected via the contact form

• The period strictly necessary for the purposes for which the data is stored, in accordance with the recommendations of the CNIL (French Data Protection Authority), for technical browsing data collected via non-essential cookies

 

The collection and processing of data meet the following purposes:

• Responding to requests sent via the contact form on the afineconseil.com website

• Audience measurement and technical improvement of the website's operation

 

The data processing carried out is based on the following legal grounds:

• User consent (contact form)

• User consent (non-essential cookies, obtained via the consent banner)

 

B. TRANSFER OF DATA TO THIRD PARTIES

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The personal data collected by the website is not transmitted to any third party and is processed only by the website's publisher.

 

C. DATA HOSTING

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The domain name afineconseil.com is registered and managed by OVH SAS, whose registered office is located at 2, rue Kellermann, 59100 ROUBAIX, France (reachable at +33 9 72 10 10 07).

 

The afineconseil.com website is developed and hosted on the Wix.com platform, whose European representative is Wix Online Platforms Limited, 1 Grant's Row, Dublin 2 D02HX96, Ireland (GDPR contact: dpo@wix.com).

 

The data collected via the website (via the contact form) is therefore hosted and processed by Wix.com, which implements appropriate contractual safeguards to ensure a level of data protection in compliance with the GDPR.

 

D. COOKIES 

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The afineconseil.com website, developed on the Wix.com platform, uses essential cookies necessary for its proper functioning (security, user login, system monitoring and debugging, measuring system effectiveness), as well as marketing, performance, and analytics cookies.

 

On their first visit, users are informed via a consent banner and may choose to accept or refuse the use of these non-essential cookies. Essential cookies, which are necessary for the website to function, are not subject to this choice.

 

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ARTICLE 4: DATA CONTROLLER

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A. THE DATA CONTROLLER

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The controller responsible for processing personal data is: Afine Conseil Sarl. The Data Controller may be contacted as follows:

• By phone at +33 6 07 71 64 58 or by email at contact@afineconseil.com

 

The data controller is responsible for determining the purposes and means used for processing personal data.

 

B. OBLIGATIONS OF THE DATA CONTROLELER

The data controller undertakes to protect the personal data collected, not to transmit it to third parties without informing the user, and to comply with the purposes for which this data was collected.

 

The website uses SSL/TLS encryption to ensure that information and data transfers passing through the website are secure.

 

An SSL ("Secure Socket Layer") certificate is designed to secure the data exchanged between the user and the website.

 

In addition, the data controller undertakes to notify the user in the event of rectification or deletion of data, unless doing so would involve disproportionate formalities, costs, or steps.

 

In the event that the integrity, confidentiality, or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means.

 

ARTICLE 5: USER RIGHTS

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In accordance with the regulations concerning the processing of personal data, users have the rights listed below.

 

In order for the data controller to act on their request, the user must provide their first and last name as well as their email address.

 

The data controller must respond to the user within a maximum period of 30 (thirty) days.

 

A. OVERVIEW OF USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING

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a. Right of access, rectification, and erasure

Users may access, update, modify, or request the deletion of data concerning them, by following the procedure below:

• The user must send an email to the data controller, specifying the purpose of their request and their contact email address.

 

b. Right to data portability

Users have the right to request the portability of their personal data held by the website to another website, in accordance with the following procedure:

• The user must submit a request for portability of their personal data to the data controller by sending an email via the contact form or to contact@afineconseil.com

 

c. Right to restriction of and objection to data processing

Users have the right to request the restriction of, or object to, the processing of their data by the website, and the website may not refuse such a request unless it can demonstrate compelling legitimate grounds that override the interests, rights, and freedoms of the user.

 

To request the restriction of processing of their data, or to object to the processing of their data, users must follow the procedure below:

• The user must submit a request for restriction of processing of their personal data by email to the data controller.

 

d. Right not to be subject to a decision based solely on automated processing

In accordance with the provisions of Regulation 2016/679, users have the right not to be subject to a decision based solely on automated processing if the decision produces legal effects concerning them, or similarly significantly affects them.

 

e. Right to determine what happens to personal data after death

Users are reminded that they may specify what should happen to their collected and processed data in the event of their death, in accordance with Law No. 2016-1321 of 7 October 2016.

 

f. Right to lodge a complaint with the competent supervisory authority

If the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or believes that one of the rights listed above has been infringed, the user is entitled to lodge a complaint with the CNIL (French Data Protection Authority, https://www.cnil.fr) or with any competent court.

 

B. PERSONAL DATA OF MINORS

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In accordance with the provisions of Article 8 of European Regulation 2016/679 and French data protection law ("loi Informatique et Libertés"), only minors aged 15 or older may consent to the processing of their personal data.

 

If the user is a minor under the age of 15, the consent of a legal representative will be required before any personal data may be collected and processed.

 

The website publisher reserves the right to verify, by any means, that the user is over 15 years of age, or that they have obtained the consent of a legal representative before browsing the website.

 

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ARTICLE 6: CONDITIONS FOR MODIFYING THE PRIVACY POLICY

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This privacy policy may be viewed at any time at the following address:

 

www.afineconseil.com

 

The website publisher reserves the right to modify it in order to ensure its compliance with applicable law.

 

Users are therefore invited to consult this privacy policy regularly in order to stay informed of the latest changes made to it.

 

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ARTICLE 7: USER ACCEPTANCE OF THE PRIVACY POLICY

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By browsing the website, users confirm that they have read and understood this privacy policy and accept its terms, particularly with regard to the collection and processing of their personal data.

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