In accordance with the provisions of Articles 6-III and 19 of Law No. 2004-575 of June, 21st, 2004 for the Trust in the digital economy, known as LCEN, it is brought to the attention of users and visitors of the site https://coment.in this data privacy policy. Access and use of the Site are subject to applicable laws and / or regulations. The connection, use, and access to this Site imply full and unreserved acceptance by the user of all the provisions of this privacy policy.

1. DEFINITIONS

Terms in which the first letter appears in upper case, plural or singular, shall have the following meanings:

• Website: means the address of the Platform accessible on the Internet at https://coment.in.
• Visitor: means any natural person who visits the Website, including Users.
• User: means any natural person with an account on the Platform.
• Main User: refers to the User who created the Team and has the Team Leader Profile.
• Personal Data or Data: information relating to a natural person, identified or who can be identified, directly or indirectly, by reference to a name, an identification number, or to one or more elements of its own.
• Person Concerned: natural person to whom the Personal Data is related.
• Processing: any transaction(s) or set of transactions concerning Personal Data, regardless of the process used, including the collection, registration, retention, adaptation or modification, extraction , consultation, use, communication by transmission, broadcast or any other form of making available the reconciliation or interconnection, as well as the locking, deletion or destruction or any operation designated as “Processing” by the regulation.
• Responsible for the treatment: means COMENT

2. DATA COLLECTION

COMENT respects the Visitors’ right to privacy and recognizes the importance of protecting their personal data. It commits itself to respect the new regulation resulting from the European regulation on the protection of the personal data. The Website does not require the personal data of Visitors for a simple consultation of the Site. COMENT collects personal data in three ways:

• The ones that the Visitor provides,
• Those COMENT obtains from third party sources;
• By the use that the Visitor makes of the services.

As such, the following data may be collected:

• Identification data: names, first names, postal address, telephone and email address, username, password …
• Bank details: bank details, SEPA mandate …
• Usage data of services including cookies: service requested, date and time of consultation, the name of the files consulted, the Internet browser and the operating system used, IP address of the device, the volume of data transferred, the mobile platform, the technical identifier(s), error reports and execution data …
• Tracking data: clicks …

The Website may use “cookies” techniques to process traffic statistics and information, facilitate navigation and improve the service for the comfort of Visitors: security, session, tracking cookies … Visitors are free to accept or refuse cookies on the Site by modifying the parameters of their internet browser. The Visitor may disable cookies. However, if cookies are disabled, the Visiter may not be able to use all the features of the Website.

3. USE OF PERSONAL DATA

The aforementioned Personal Data are used to:

• Allow the execution of the services offered by COMENT on the Website;
• Allow the linking of Users;
• Perform statistics, improve the use of services;
• Identify usage trends
• Promote new services, loyalty, prospecting
• Comply with applicable law and legal requirements;
• Guarantee the security of the network and prevent possible fraud.

 

4.POLICIES OF USE OF PERSONAL DATA

When COMENT collects or processes Visitors’ Personal Data in compliance with European data protection laws, COMENT does so with the following purposes:

• If necessary to provide the services, complete a transaction, execute a contract or at the request of a Visitor prior to the conclusion of a contract;
• If necessary to comply with applicable law or any other legal obligation;
• If necessary to ensure the performance of a task in the public interest;
• If necessary to prevent fraud, allow the Visitor to comply with its legal obligations;
• If necessary, with the agreement of the Visitor;
• If necessary for the operation of COMENT, to protect the security of its systems, Visitors and Users, to detect and prevent fraud, or to protect our legitimate interests, unless the interests or fundamental rights and freedoms of Visitors requiring protection of his personal data beyond the legitimate interests of COMENT.

When COMENT relies on the Visitor’s agreement to process his / her personal data, the Visitor has the right to withdraw this Agreement at any time.  

5. RECIPIENTS OF PERSONAL DATA

The data thus collected and processed in a fair and lawful manner for specified and legitimate purposes, without being further processed in a way incompatible with these purposes, are strictly intended for COMENT. The recipients of the personal data are the authorized staff of the services responsible for customer relations and prospecting, administrative services, logistical and IT services and their hierarchy, and any subcontractors and partners in respect of French regulations. COMENT also reserves the right to disclose Personal Data when the disclosure appears necessary to:

• comply with any applicable law, regulation, legal process or other legal obligation;
• detect, investigate and prevent security, fraud or technical problems;
• protect the rights, property or safety of COMENT;
• carry out a general transaction, such as a transfer of assets or an acquisition through a merger with another company.

Personal Data processed by COMENT as a Data Controller may only be processed by a subcontractor or a contractual partner of COMENT in accordance with its instructions. In this respect, COMENT ensures that its potential subcontractors and partners provide the guarantees necessary for the protection of the visitor’s personal data.  

6. DATA TRANSFER

Personal Data may be stored and processed in any country where COMENT, its suppliers, partners or subcontractors manage servers. In the event that Personal Data may be transferred outside the territory of the European Economic Area, COMENT shall take all necessary measures to ensure that the Personal Data benefit from the appropriate safeguards (and in particular through the Privacy Shield or Standard Contractual Clauses approved by the European Commission).

 

7. DURATION OF STORAGE OF PERSONAL DATA

Customer data is retained by COMENT during the retention period necessary for the management of the business relationship except those required to establish proof of a right or contract that may be archived in accordance with provisions of the Commercial Code relating to the shelf life of books and documents created during commercial activities and the Consumer Code relating to the retention of contracts concluded electronically, namely 10 years. The Data is kept by COMENT for commercial prospection for 3 years.  

8. DATA SECURITY

COMENT implements organizational, technical, software and physical security measures for the protection of Personal Data against unauthorized alteration, destruction and access. However, it should be noted that the Internet is not a completely secure environment and the Website can not guarantee the security of the transmission or storage of information on the Internet.  

9. LIABILITY

In the event of COMENT’s breach, its liability will, in any event, be limited to the only direct prejudice suffered by the Visitor. COMENT can not be held liable for any indirect damages suffered by the Visitor.  

10. RIGHT OF THE USER ON HIS DATA

The Visitor is invited to update the data concerning him which is inaccurate, incomplete or obsolete. In accordance with the regulations applicable to the protection of personal data, the Visitor has:

• access rights to his data,
• a right of rectification,
• a right to erase data,
• a right of limitation,
• a data portability right (a copy of his data),
• a right to oppose the treatment

The Visitor may also set guidelines regarding the fate of your personal data after his death. The data that COMENT needs for the purpose for which it was collected, necessary for the fulfillment of a legal obligation and / or the finding, exercise or defense of rights in court may, however, not be deleted. The Visitor may benefit from the exercise of his rights by writing to the following address: 14, rue Charles Brunellière, 44100 Nantes, FRANCE, or the following email address: hello@coment.in, subject as appropriate to the justification the identity of the person.