Privacy Policy of 25/05/2018

This Privacy Policy sets out and informs you of how Optimun (hereinafter "Site Publisher") uses and protects the information you transmit to us when you use this site accessible from the following URL. : https://www.optimum.tm.fr (hereinafter the "Site"). This privacy policy supplements the legal notices that users can consult by clicking on the "Legal mentions" section.  

This privacy policy may be amended or supplemented at any time by the Site Editor, in particular to comply with any legislative, regulatory, jurisprudential or technological developments. In such a case, the date of its update will be clearly identified at the beginning of this policy. These modifications engage the User as soon as they are posted online. It is therefore appropriate that the User consults regularly this policy of confidentiality and use of cookies to learn about any changes.

Access to the Site implies the full and unreserved acceptance by the User of this Privacy Policy and Cookie Policy.

The User acknowledges having read the information below and authorizes the Publisher of the site to collect and process, as specified in the Privacy Policy, the personal data that he communicates on the Site in the part of his contact request. 

The Privacy Policy is valid for all pages hosted on the Site and for registrations on this Site. It is not valid for pages hosted by third parties to which the Site Publisher may refer and whose privacy policies may differ. The publisher of the site can not therefore be held responsible for any data processed on these sites or by them.

Article 1: General Principles of Data Collection and Processing

In accordance with the provisions of Article 5 of the European Regulation 2016/679 (hereinafter the "RGPD ") and Article 6 and 36 of the Data Protection Act of 6 January 1978 amended by the law of 6 August 2004 on to computer science (hereinafter the " Computer Science and Freedoms "), the collection and processing of site users' data complies with the following principles:     

Legal, fair and transparent data: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data are collected, the user will be informed that his / her data are being collected, and for what reasons his / her data is collected;
Purposeful, Explicit and Legitimate Purposes: The collection and processing of data is performed to fulfill one or more of the purposes set out in this Privacy Policy;
Adequate, relevant and limited data: only the data necessary for the proper execution of the objectives pursued by the site are collected;
Conservation of data reduced in time: the data are kept for a limited time, of which the user is informed.
Exact and if necessary updated data: the data collected and processed will be kept up to date. All reasonable measures will be implemented to ensure that inaccurate data are erased and rectified as soon as possible. 
Integrity and confidentiality of data collected and processed: the data controller is committed to ensuring the appropriate security of personal data, including protection against unauthorized or unlawful processing and against loss, destruction or damage accidental origin, using appropriate technical or organizational measures.
In order to be lawful, and in accordance with the requirements of article 6 of the RGPD, the collection and processing of personal data can only take place if they comply with at least one of the conditions listed below:

The user has expressly consented to the treatment;
The processing is necessary for the performance of a contract to which the person concerned is party;
The treatment meets a legal obligation incumbent on the controller;
The treatment is due to a need to safeguard the vital interests of the data subject or of another natural person;
The treatment is explained by a necessity related to the performance of a mission of public interest or which falls within the exercise of the public authority of which the controller is invested;
The processing is necessary for the legitimate and private interests pursued by the controller or by a third party, unless the interests and fundamental rights of the data subject prevail over the interests of the controller.
Article 2: personal data collected:

In general, you can visit the Publisher Site without disclosing any personal information about you. You are in no way obliged to transmit this information to the Site Editor.

However, in case of refusal, you may not be able to benefit from certain information or services that you have requested.

Article 2.1 : Contact form 

The Editor of the site may be required in certain cases to ask you to provide: civility, surname, first name, email address, telephone number, postal address, country (hereinafter your "Personal Information").

Article 2.2 : Server log file 

When the User accesses the Site, the servers consulted automatically record certain data, such as:

the type of domain with which the User connects to the Internet;
the IP address assigned to the User (when connected);
the date and time of access to the Site and other traffic data;
the consultation time of the pages ; 
location data or other data relating to the communication;
the pages consulted;
the type of browser used;
the platform and / or operating system used;
This information is only kept for statistical purposes and to improve the Site.

Article 3: Purposes of treatment and shelf life

The Publisher of the site may process your Personal Information:

Prospect data : 

The data is used to respond to your requests, make commercial proposals and for the constitution and management of a file of prospects for a period of 3 years from the collection or last contact from the prospect. 
The data is used to provide you with the information you have requested by subscribing to the newsletter and is retained for a period of 3 years after your unsubscription.
Data about an active client : 

The data is used to perform the contract, manage the business relationship, track billing and manage unpaid invoices and are retained for the duration of the contractual relationship.
Data about an idle client : 

The customer account data, orders, invoices and information on payments are kept according to the legal, civil and tax prescription period.
Data generated by cookies : 

The data related to your navigation on the website are used to optimize the operation of our website and measure attendance and are kept for a maximum of 13 months.
Data generated by the server log files : 

These data related to the navigation on the website are used to detect malfunctions, computer attacks and fraudulent attempts and are kept for up to 13 months.
Article 4: Transmission of data to third parties

Article 4.1: Sharing of your personal data with third-party companies

Only the Publisher of the site is recipient of your Personal Information. These are never transmitted to a third party, notwithstanding the subcontractors to whom the Site Editor uses, accountant, registrar, web host, data host, e-mailing company, software publisher Management. Neither the Publisher of the site nor any of its subcontractors, proceed to the marketing of the personal data of the visitors and Users of its Site.

Article 4.2. Sharing with the authorities

We may disclose your personal data to the administrative or judicial authorities when their disclosure is necessary for the identification, prosecution or prosecution of any individual who may prejudice our rights, any other user or a third.

Article 5 : Security 

The Publisher has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that the servers hosting the personal data processed prevent, as far as possible:

unauthorized access or modification to these data;
improper use or disclosure of such data;
unlawful destruction or accidental loss of such data.
Organizational and technical measures : 

Editor's employees who have access to this data are subject to a strict confidentiality obligation. However, the Publisher can not be held responsible for any misuse of this data by a third party despite the security measures adopted.
The site has a SSL certificate ("Secure Socket Layer" Certificate) to ensure that the information and the transfer of data passing through the site are secure. An SSL certificate aims to secure the data exchanged between the user and the site.
The web server on which the data is collected and hosted is secured in accordance with accepted and constantly revised IT standards.   
Terminals that process data have up-to-date antivirus, complex password access, firewall.
Users undertake not to commit acts that may be contrary to this Privacy Policy, or, in general, to the law.

Article 6: hosting of data

The Site is hosted by:

Company EFEDUS, Sarl with capital of 30 000 €, whose registered office is 2791 Chemin Saint Bernard in VALLAURIS (06220) FRANCE, registered with the Register of Commerce and Companies of ANTIBES under number B 484 476 783, VAT number FR15484476783 , can be reached on its website http://www.efedus.fr and by phone at 04 93 32 76 84 

Article 7: Data controller

The person responsible for the processing of personal data is: Maxime VALENDUC

He can be contacted by phone at 05 53 69 22 00 Monday to Friday from 8:00 to 12:00 and from 14:00 to 17:30 or by email via the contact form of the site.

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

Article 8: Obligation of the data controller

The data controller undertakes to protect the collected personal data, not to transmit it to third parties without the user having been informed and to respect the purposes for which the data was collected. It is required to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk involved.

In addition, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this entails disproportionate formalities, costs and procedures.

In the event of a breach of the user's personal data that may entail a high risk for the rights of the user, the controller commits himself to communicate this violation to the User as soon as possible and this in accordance with the provisions of article 34 of the RGPD. 

Article 9: Rights of the user

In accordance with the regulations on the processing of personal data, the user has the rights listed below.

In order for the data controller to comply with his request, the user must provide him with: first name, last name, e-mail address, along with a copy of his identity card or passport.

The data controller is responsible for responding to the user within a maximum of 30 (thirty) days.

Article 9.1: Right of access, rectification and right to erasure

The user can take note, update, modify or request the deletion of the data concerning him, by sending an email to the person in charge of the treatment of the personal data, by specifying the object of his request by using the form of contact of the Site. 

If he has one, the user has the right to request the removal of his personal space by sending an email to the controller of personal data, specifying the email address of his personal space.

Article 9.2: Right to portability of data

The user has the right to request the portability of his personal data, held by the site, to another site by making a request for portability of his personal data to the data controller, by sending an email to the address provided above.

Article 9.3: Right to Limitation and Opposition of Data Processing

The user has the right to request the limitation or oppose the processing of his data when one of the elements referred to in article 18 of the RGPD applies.

In order to request the limitation of the processing of his data or to object to the processing of his data, the user must make a request for limitation to the processing of his personal data with the data controller, by sending an email to the data controller. address provided above.

Article 9.4: Right not to be the subject of a decision based exclusively on an automated process

In accordance with the provisions of Article 22 of Regulation 2016/679, the user has the right not to be the subject of a decision based exclusively on an automated process if the decision has legal effects concerning him, or the significantly affects in a similar way.

Article 9.5: Right to determine the fate of data after death

The user is reminded that he can organize what should be the future of his data collected and processed if he dies, in accordance with the provisions of article 40 of the law Informatique et Libertés.

Article 9.6: Right to seise the competent supervisory authority

If you consider that the controller does not comply with its obligations regarding your Personal Information, you may address a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can address a request electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet or by post : 

National Commission for Computing and Freedoms 
Complaints Service 
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07

Article 10: personal data of minors

In accordance with the provisions of Article 8 of the RGPD and the Data Protection Act, only minors aged 15 or over can consent to the processing of their personal data alone.

When the child is under 15, it is necessary that the consent be given jointly by the minor and the parent (s).

If the user is a minor under the age of 15, the consent of a legal representative will be required so that personal data can be collected and processed.

The publisher of the site reserves the right to verify by any means that the user is older than 15 years, or that he has obtained the consent of a legal representative before browsing the site.

Article 11: cookie policy

During your first connection to the Publisher's website, you are warned by a banner that information relating to your browsing may be stored in files called "cookies". Our cookie policy allows you to better understand the provisions that we implement in terms of navigation on our website. It informs you in particular about all cookies on our website, their purpose and gives you the procedure to set them.

Article 11.1 : General information on cookies on the Publisher's website 

The publisher of this website, may proceed to the implementation of a cookie on the hard drive of your device (computer, tablet, mobile etc.) to ensure smooth and optimal navigation on our website.

"Cookies" (or cookies) are small text files of limited size that allow us to recognize your computer, tablet or mobile to customize the services we offer.

The information collected through cookies does not in any way identify you by name. They are used exclusively for our own needs in order to improve the interactivity and the performance of our website and to send you contents adapted to your centers of interests. None of this information is the subject of a communication to third parties except when the Publisher has obtained your prior consent or when the disclosure of such information is required by law, by order of a court or any authority administrative or judicial authority to know.

To better inform you about the information that cookies identify, you will find below the list of different types of cookies that may be used on the Publisher's website, their name, purpose and their retention period.

Article 11.2 : Setting your preferences on cookies 

You can accept or refuse the deposit of cookies at any time.

When you first log on to the Publisher's website, a banner briefly outlining information about cookies and similar technologies is displayed. This banner warns you that by continuing your navigation on the Publisher's website (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your terminal. You are also deemed to have consented to the deposit of cookies by clicking on the "X" icon to the right of the banner.

For any query or additional request for information on this policy cookies, thank you kindly contact us through our form.

Depending on the type of cookie involved, collecting your consent to deposit and read cookies on your device may be imperative.

Cookies exempt from consent

In accordance with the recommendations of the Commission Nationale Informatique et Libertés (CNIL), some cookies are exempt from the prior collection of your consent to the extent that they are strictly necessary for the operation of the website or have the sole purpose of enabling or facilitating electronic communication. These include session ID, authentication, load balancing session cookies as well as customizing cookies for your interface. These cookies are fully subject to this policy insofar as they are issued and managed by the Site Editor.

List of cookies requiring the prior collection of your consent

This requirement applies to third-party cookies that are described as "persistent" as long as they remain in your device until they are deleted or expired.

Because such cookies are issued by third parties, their use and deposit are subject to their own privacy policies, which you will find below. This cookie family includes audience measurement cookies (Google Analitycs), advertising cookies (which the Publisher does not use), social network sharing cookies (including Facebook, YouTube, Twitter, Google + , LinkedIn, Viadeo) as well as cookies for external content (including badges and various Facebook and Twitter buttons, GoogleMap maps, Youtube or Dailymotion videos).

Audience measurement cookies provide statistics on the use and use of various elements of the website (such as the content / pages you visited). These data help to improve the ergonomics of the Publisher's website. An audience measurement tool is used on this website:

Google Analitycs whose privacy policy is available from the following link: https://piwik.org/privacy-policy/
Social network sharing cookies are issued and managed by the publisher of the social network concerned. Subject to your consent, these cookies allow you to easily share some of the content published on the Publisher's website, including via a "button" application sharing according to the social network concerned. Four types of social sharing cookies are present on the Publisher's website:

Facebook, which you can view the cookie policy by clicking on the following link: https://fr-fr.facebook.com/policies/cookies/
Google Plus, which you can view the cookie policy by clicking on the following link: https://policies.google.com/privacy?hl=en
LinkedIn, whose cookie policy you will find by clicking on the following link: https://www.linkedin.com/legal/cookie-policy?_l=en_US
Twitter, which you will find the options dedicated to the control or the restriction of the use of the cookies as well as the policy of use of the cookies: https://support.twitter.com/articles/20170518#
Viadéo, whose cookie policy you can consult by clicking on the following link : https://www.viadeo.com/en/policy-cookies 
YouTube, which you can find help to delete cookies from the Google Chrome browser by clicking on the following link: https://support.google.com/youtube/answer/32050?hl=en but also the full policy for cookies from the following link: https://www.google.com/intl/en/policies/technologies/cookies/
You have various tools for setting cookies

Most Internet browsers are configured by default so that cookies are allowed to be posted. Your browser offers you the opportunity to modify these standard settings so that all cookies are rejected systematically or that only part of the cookies is accepted or refused according to their issuer.

ATTENTION: We draw your attention to the fact that the refusal of the deposit of cookies on your terminal is nevertheless likely to alter your user experience as well as your access to certain services or functionalities of this website. If necessary, the Site Editor declines all responsibility for the consequences of the degradation of your browsing conditions that occur because of your choice to refuse, delete or block cookies necessary for the operation of the site. These consequences can not constitute damage and you can not claim any compensation for this fact.

Your browser also allows you to delete existing cookies on your device or to notify you when new cookies may be placed on your device. These settings do not affect your navigation but you lose all the benefit of the cookie.

Please find below the many tools available to you so that you can set the cookies on your device.

The cookie management tool provided by the website:

The deactivation of cookies can be done at any time during your navigation. You can manage your cookies via a banner available at the bottom right of the page viewed ("Service Management" button) and list all active cookies. To deactivate a cookie, simply click on the cross next to the proposed service. If all cookies are disabled, the banner dedicated to collecting the user's consent will reappear when the page is refreshed.

The setting of your Internet browser

Each Internet browser has its own cookie management settings. To find out how to change your cookie preferences, please find below the links to the help you need to access your browser's menu provided for this purpose:

Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en/kb/activate-deactivate-cookies
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Opera: http://help.opera.com/Windows/10.20/en/cookies.html
Safari: https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US
Edge : https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy 
For more information on the tools of control of cookies, you can consult the Internet site of the CNIL: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser