Klee Commerce attaches great importance to and is committed to respecting the privacy of users (hereinafter referred to as ‘You’) of its Internet site (hereinafter referred to as the “Site”) and to the security of your personal data (hereinafter referred to as ‘Data’).

In this respect, Klee Commerce (RCS Nanterre n°752 270 173, Centre des Affaires La Boursidière, BP 159, 92350 Le Plessis Robinson Cedex – hereinafter ‘Klee’ or ‘We’) undertakes to respect and comply with the regulations on the protection of personal data, namely Law no. 78-17 of 6 January 1978 known as ‘Informatique et Libertés’ as amended and European Data Protection Regulation no. 2016/69 (“RGPD”) which came into force on 25 May 2018 (hereinafter the ‘Regulations’).

This policy applies to any person concerned by the processing of their Data by Klee and enables you to understand how and why your Data is processed.

If you have any questions about this document or the processing of your Data, you can contact our Data Protection Officer at the following address: dpo@kleegroup.com

1) What is the legal basis for the processing carried out?

Depending on the case, the legal basis for the processing of Data that We carry out may be one of those provided for by the Regulations, and in particular :

• your consent;
• compliance with a legal obligation;
• Klee’s legitimate interests;
• performance of a contract.

2) What Data do we collect, for what purposes and for how long?

Within the meaning of the Regulations, ‘personal data’ means any information relating to an identified or identifiable natural person such as, in particular, surname, first name, fixed or mobile telephone number, job title, organisation, e-mail or postal address, data relating to connection to and use of the Site, IP address, computer equipment used, an online identifier, etc. We may have access to your Data or use it to contact you.

We may have access to your Data or process your Data when you browse our Site.

You will find a summary below:

Identity (surname, first name), job title, contact details (email, telephone), IP address (if cookies are accepted)

• Purpose: Completion of contact forms
• Retention period: 5 years

Completion of the CRM database

• Purpose: Completion of the CRM database
• Retention period: 5 years

Production of audience and usage statistics for online services offered by Klee

• Purpose: Production of audience and usage statistics for online services
• Retention period: 5 years

Management of subscriptions, electronic mailings and production of statistics relating to the service

• Purpose: Management of subscriptions, electronic mailings and preparation of statistics
• Retention period: Until unsubscription by the person concerned

Receipt of comments and notices sent to the editorial staff and webmaster

• Purpose: Receipt of comments and notices
• Retention period: Until the person concerned unsubscribes

Management of action taken on comments received

• Purpose: Management of action taken on comments received
• Retention period: 5 years from processing of the request

Preparation of activity and audience statistics

• Purpose: Production of activity and audience statistics
• Retention period: 5 years

Log data

• Purpose: To investigate whether the site is experiencing technical or functional problems
• Retention period: 1 day

Data relating to browsing on websites (time stamps, users’ IP addresses, technical data relating to the equipment and browser used by users, cookies)

• Purpose: Production of audience and usage statistics for online services offered by Klee
• Retention period: 14 months from receipt of the data (period reset each time the Internet user concerned performs a new event)

Identity data and data relating to the management of user contacts (time-stamping and subject of the request, follow-up, action taken, statistics)

• Purpose: Management of user contacts, receipt of requests to download content and make live contact, management of action taken
• Retention period: 5 years from the time the request is processed

Identity data + Data relating to the management of technical problems reported by users (time-stamping and purpose of requests, follow-up, action taken, statistics)

• Purpose: Management of technical problems
• Retention period: 5 years from the time the request is processed

We comply with the Regulations and in particular with the legal retention periods for your Data. However, we may retain certain Data beyond the above-mentioned periods in order to fulfil our legal or regulatory obligations.

3) Who receives the Data We collect?

The persons likely to have access to your Data are:

– Klee employees responsible for publishing content, technical administration of websites, processing requests received via contact forms, etc.

– Employees responsible for supervising the security of Klee Group’s information systems

– Employees contributing to publications

– Our authorised service providers as subcontractors within the meaning of the Regulations.

4) Your rights regarding the Data we collect

You have a right of access, information, opposition, rectification, deferment, deletion and limitation of your Data.

For more information, please consult the website of the Commission Nationale de l’Informatique et des Libertés (CNIL): https://www.cnil.fr/fr/mes-demarches/les-droits-pour-maitriser-vos-donnees-personnelles

You also have the right to lodge a complaint with the CNIL, in particular on its website www.cnil.fr.

5) Modification of the privacy policy

We reserve the right, at any time, to modify/complete/update the present confidentiality policy, particularly with regard to changes in Regulations, the processing that We carry out and the Data that We collect.