Preamble
This privacy policy informs you about how E-PANGO uses and protects the information you provide to us, if any, when you use this site accessible from the following URL : www.e-pango.com (hereinafter the “Site”).
Please note that this privacy policy is subject to change or supplement at any time by E-PANGO, in particular in order to comply with any legal or technological development. In such a case, the date of its update will be clearly identified at the top of this policy. These modifications commit you as soon as they are put online. It is suitable by therefore that you regularly consult this privacy policy in order to take note of these possible modifications.
Article 1. Parties
This confidentiality policy is applicable between the publisher of the Site, hereinafter “E-PANGO”, And any person connecting to the Site, hereinafter “the Internet user”.
Article 2. Definitions
“Site content”: elements of any kind published on the Site, whether or not protected by intellectual property law, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software.
“Internet user”: any person connecting to the Site.
“Site”: website accessible at the URL www.e-pango.com, as well as the sub-sites, mirror sites, portals and related URL variations.
Article 3. Scope
This confidentiality policy is applicable to all Internet users. The simple connectionand / or browsing the Site will imply your full acceptance of thisprivacy policy. In addition, clicking on “I accept” in the information banner relating to cookies displayed on the Site constitutes your confirmation of this acceptance, while allowing you to customize which cookies will or will not beapplied. By the same token, you acknowledge that you have fully understood them and accept them without restriction.
The Internet user recognizes the value of proof of the automatic registration systems of E-PANGO and, except for him to provide proof to the contrary, he renounces to contest them in the event of litigation.
The acceptance of this confidentiality policy supposes on the part of Internet users they have the necessary legal capacity or are at least 16 years old, or failing that they have the authorization of a tutor or curator if they are incapable, of their legal representative if they are under 16, or if they hold a mandate if they act on behalf of a legal person.
Article 4. Personal data
In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016 and the national legislation in force, E-PANGO provides you the following information:
4.1 Identity of the controller
The responsible for the collection and the data processed on the Site is E-PANGO, 26 rue Vignon, 75009 PARIS, SIREN n°: 817 840 762, intra-community VAT n°: FR30817840762, contact: Philippe Girard, email address: contact@e-pango.com, phone: +33.1.42.33.34.07.
4.2 Identity of the Data Protection Officer
The identity of the Data Protection Officer is Pierre Renaux, email address: dpo@e-pango.com
4.3 Data collection by E-PANGO
4.3.1 Data collected
4.3.1.1 Data collected during navigation
When browsing the Site, the Internet user consents to E-PANGO collecting information relating to: its use of the Site; the content he views and clicks on; to his location; to his connection data (timetables, pages viewed, IP address, etc.) and to the pagesweb visited before or after using the Site.
4.3.1.2 Data collected when using the contact form
The use of the contact form by the Internet user supposes the collection by E-PANGO of following personal data: last name, first name, telephone number, fax number, name of the company, postal address, e-mail address, any information voluntarily transmitted by the Internet user (free field).
Internet users who do not wish to provide the information required for the use of the contact form will not be able to send a message to E-PANGO directly from the Site.
4.3.1.3 Data collected during registration and use of the customer area
The registration and use of the customer area supposes the collection by E-PANGO of following personal data: company name, last name, first name, e-mail address, sector of activity, profession and professional status, telephone number, fax number, banks contact details, bills, electricity delivery points and consumption, profile of consumption.
4.3.2 Purposes of the collection of personal data
The data collected during navigation is subject to automated processing with the purpose of:
- develop, operate, improve, provide and manage the Site;
- contextualize and improve the Internet user's experience;
- enforce the conditions relating to the use of the Site.
The data collected when using the contact form is processed automated with the aim of:
- provide a detailed response to the Internet user;
- develop, operate, improve, provide and manage the Site;
- send information and contact the Internet user, including by e-mail, telephone and push notification;
- enforce the conditions relating to the use of the Site.
4.3.3 Legal basis for processing
The data collected during navigation have as a legal basis the legitimate interest of E-PANGO, namely carrying out an analysis of behavior on the Site and obtaining security and improved functioning of the Site. Some of this data, such as that from the implementation of certain cookies, may have as a legal basis the consent of people.
Data collected when using the contact form has the legal basis of consent of the persons concerned.
4.3.4 Data recipients
The data collected can only be viewed by E-PANGO, and is never returned freely viewable by a third natural person.
4.3.5 Retention period of personal data
Personal data collected during browsing is kept for a reasonable period of time necessary for the proper administration of the Site and for a maximum of 13 months.
The personal data collected when using the contact form are kept for a reasonable period of time necessary for the proper management of the request for the Internet user, and for a maximum of 12 months.
4.3.6 Security and confidentiality of personal data
Personal data is kept in secure conditions, according to the means state of the art, in compliance with the provisions of the General Regulations for data protection and applicable national legislation.
4.3.7 Minimization of personal data
E-PANGO can also collect and process any data transmitted voluntarily by a Internet user, in particular via the free field of the contact form.
E-PANGO guides Internet users as much as possible when providing data to unnecessary or superfluous personal character.
E-PANGO undertakes to keep and process only the data strictly necessary for its activities, and will delete any data received that is not useful as soon as possible.
4.4 Respect for rights
You have the following rights regarding your personal data, which you can exercise by writing to our postal address or by filling out our contact form online.
4.4.1 Right to information, access and communication of data
You have the possibility to access the personal data which concern you.
Due to the obligation of security and confidentiality in the processing of personal data which is incumbent on E-PANGO, your request will only be processed if you provide proof of your identity, in particular by producing a scan of your valid identity card (if requested by email) or a signed photocopy of your valid identity card (in the event of a written request), both accompanied by the mention “I certify on my honor that the copy of this identity document corresponds to the original. Made in …on… ”, followed by your signature.
To help you in your process, you will find here a model letter developed by the Cnil.
4.4.2 Right to rectification, deletion and right to be forgotten
You have the possibility of requesting rectification, updating, locking or even the erasure of your personal data which may prove to be inaccurate, if necessary, incorrect, incomplete or obsolete.
You can also define general and specific directives relating to the fate of personal data after your death. If applicable, the heirs of a person deceased may require taking into consideration the death of their loved one and / or proceeding to the necessary updates.
To help you in your process, you will find here a model letter developed by the Cnil.
4.4.3 Right to object to data processing
You have the possibility to object to the processing of your personal data.
To do so, you should send an email to the following address: contact@e-pango.com.
In this email, you will need to specify the data you wish to be deleted as well as thereasons justifying this request, except in the case of commercial prospecting.
4.4.4 Right to data portability
You have the right to receive the personal data you have provided to us in a transferable, open and readable format.
4.4.5 Right to restriction of processing
You have the right to request that the processing of your personal data by E-PANGO is limited. Thus, your data can only be kept and no longer used by E-PANGO.
4.4.6 Response times
E-PANGO undertakes to respond to your request for access, rectification or opposition or any other request for additional information within a reasonable period of time which cannot exceed 1 month from receipt of your request.
4.4.7 Complaint to the competent authority
If you consider that E-PANGO is not respecting its obligations with regard to your personal information, you can address a complaint or a request to the competent authority. In France, the competent authority is the CNIL to which you can send a question here.
4.5 Transfer of collected data
4.5.1 Transfer to partners
E-PANGO informs you that we use authorized service providers to facilitate the collection and processing of the data you have communicated to us. These providers may be located outside the European Union and have data communication collected on the Site.
E-PANGO has previously ensured the implementation by its providers of adequate guarantees and compliance with strict conditions in terms of confidentiality, use and data protection, for example via the US PrivacyShield.
The Internet user consents to the data collected being sent by E-PANGO to his partners and to be processed by these partners as part of third-party services,to know:
4.5.2 Transfer on requisition or court order
The Internet user also consents to E-PANGO communicating the data collected to any person, upon request from a state authority or by judicial decision.
4.5.3 Transfer as part of a merger or acquisition
If E-PANGO is involved in a merger, sale of assets, financing transaction, liquidation or bankruptcy or in an acquisition of all or part of its activity by another company, the Internet user agrees that the data collected are transmitted by E-PANGO to this company and that this company carries out the processing of personal data referred to in this confidentiality policy instead of E-PANGO.
Article 5. Policy relating to tracers / cookies
When you first connect to the E-pango website , you are warned by a banner at the bottom of your screen that information relating to your browsing may be saved in files called “cookies”. Our cookie policy allows you to better understand the provisions we implement in terms of navigation on our website. It informs you in particular about all the cookies on our website, their purpose, and gives you the procedure to follow to configure them.
5.1 Use of trackers / cookies
E-pango , as the publisher of this website, may install a cookie and other tracer on the hard drive of your terminal (computer, tablet, mobile, etc.) in order to guarantee you browsing. fluid and optimal on our website, and in order to know your browsing and web behavior data.
“Cookies” (or connection witnesses) are small text files of limited size which allow us to recognize your computer, tablet or mobile in order to personalize the services we offer you.
To better inform you about the information that cookies identify, you will find a table below listing the different types of cookies that may be used on the E-pango site , their name, their purpose and their retention period.
5.2 Purposes of tracers
With the help of the information contained in the tracers and cookies used , E-pango can analyze the frequentation and the use made of the Site and, if necessary, facilitate and improve navigation, carry out prospecting operations, develop business statistics or display targeted advertisements.
5.3 Tracers used
5.4 Setup your preferences about cookies
When you first log on the website of E-Pango, a banner exhibiting a brief information about the deposit of cookies and similar technologies appears at the bottom of your screen. This banner allows you to configure the cookies that will be applied to you when you browse the Site. You are able to give your agreement to deposit of cookies by clicking on the icon “I agree” to the right of each cookie in the banner at the bottom of your screen.
5.4.1 Cookies exempt from consent
Conformly to recommendations of the Commission nationale Informatique et Libertes (CNIL), some cookies are exempted of prior collecting your consent if they are strictly necessary for the operation of the website or have for the sole purpose of enabling or facilitating communication by electronic means. These include cookies of 'session ID' or 'authentication', load balancing and session cookies to customize your interface. These cookies are fully subject to the present policy.
5.4.2 Cookies requiring the prior collection of your consent
This requirement concerns cookies issued by third parties and which are qualified as “persistent” insofar as they remain on your terminal until their deletion or their expiration date.
As such cookies are issued by third parties, their use and storage are subject to their own privacy policies. This cookie family includes audience measurement cookies, advertising cookies and social network sharing cookies.
Audience measurement cookies establish statistics concerning the visits and use of various elements of the website (such as the content / pages you have visited). These data help to improve the ergonomics of the E-PANGO website.
You can freely accept or refuse the deposit of this type of cookies. They will be deactivated by default during your navigation.
5.4.3 Current status of your consent
Here is the current state of your consent to the deposit of cookies:
choice not made.
You can accept or refuse the deposit of cookies via the displayed banner.
5.5 Maximum shelf life of tracers
The plotters are intended to be stored on the Internet user's computer station for a period of up to 6 months. These data are kept in secure conditions, using current technical means, in compliance with the provisions of the General Data Protection Regulations and the national legislation in force .
5.6 Opposition to the use of tracers
5.6.1 Faculty of opposition to the use of tracers
You can accept or refuse the deposit of cookies at any time, via the Site's cookies banner or via the “Confidentiality Policy” section.
The Internet user can delete or deactivate the use of tracers whenever he wishes by modifying the settings of his browser. It is possible to consult the Site without tracers. However, certain additional functions of the Site may not work if the Internet user has deactivated the use of plotters, such as the autocompletion of forms or navigation indicators.
5.6.2 Settings
Each Internet browser offers its own cookie management settings. The Internet user can configure his browser software so that cookies are rejected, either systematically or according to their issuer. The Internet user can also configure his browser software so that his acceptance or refusal of cookies is offered to him from time to time, before a cookie is likely to be saved on his terminal.
For the management of cookies and the Internet user's choices, the configuration of each browser is different. It is described in the browser's help menu, which will allow you to know how to modify your preferences in terms of cookies:
- For Internet Explorer ;
- For Safari;
- For Chrome;
- For Firefox;
- For Opera.
For more information on the tools for controlling cookies, you can consult here the dedicated page on the CNIL website.
Article 6. Intellectual property
6.1 Legal protection of Site Content
The Contents of the Site are liable to be protected by copyright and database law. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, carried out illegally and without the consent of E-PANGO or its successors or assigns constitutes a violation of Books I and III of the Intellectual Property Code and will be likely to give rise to legal proceedings for infringement
6.2 Contractual protection of Site Content
The Internet user undertakes contractually with regard to E-Pango not to use, reproduce or represent, in any way whatsoever, the Content of the Site, whether or not they are protected by an intellectual property right, for a purpose other than that of their reading by a robot or a browser. This prohibition does not apply to indexing robots whose sole purpose is to scan the content of the Site for indexing purposes.
Article 7. Final stipulations
7.1 Modifications
This Privacy Policy may be modified at any time by E-PANGO. The conditions applicable to the Internet user are those in force at the time of his connection to the Site, any new connection to the Site implying acceptance, if applicable, of the new conditions.
7.2 Completeness
The nullity of one of the clauses of this contract will not entail the nullity of the other clauses of the contract or of the contract as a whole, which will retain their full effect and scope. In such a case, the parties must, as far as possible, replace the canceled stipulation by a valid stipulation corresponding to the spirit and the object of the present.
7.3 Non-waiver
The absence of exercise by E-PANGO of the rights which are recognized to it by the present can in no case be interpreted as a waiver of the assertion of said rights.
7.4 Languages
This privacy policy is initially written in French. It is offered here in English, thanks to the use of automatic translation tools. Some translations could therefore be inaccurate. E-PANGO cannot be held responsible for these inaccuracies. The applicable text is the French text.
7.5 Unfair terms
The provisions of this confidentiality policy apply subject to compliance with the mandatory provisions of the Consumer Code concerning unfair terms in contracts concluded between a professional and a consumer.
Article 8. Disputes
8.1 Applicable law
This Privacy Policy is subject to the application of French law and European regulations, in particular the European Data Protection Regulation.
8.2 Disputes
Pursuant to Ordinance No. 2015-1033 of August 20, 2015, all disputes that may arise in the context of the execution of this confidentiality policy and for which the solution could not be found beforehand amicably between the parts must be submitted to Medicys.
8.3 Arbitration
Any dispute relating to or in connection with this contract will be settled by arbitration in accordance with the FastArbitrator regulations of the Digital Arbitration and Mediation Institute.
E-PANGO