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Privacy policy

What is the purpose of our Privacy Policy?

Moderato SAS, which manages the website www.le-moderato.com, attaches great importance to the protection and confidentiality of your personal data, which we consider to be a guarantee of reliability and trust.

In this respect, our Privacy Policy is a clear demonstration of our desire to ensure that Moderato SAS complies with the rules applicable to the protection of personal data and, more specifically, those of the General Data Protection Regulation (« GDPR »).

In particular, our Privacy Policy aims to inform you about how and why we process your personal data in connection with the services we provide to you.

Who is our Privacy Policy intended for?

Our Privacy Policy applies to you, regardless of where you live, as long as you are at least 15 years old, whether you are a customer, a candidate for a position within Moderato SAS, or a visitor to the website www.le-moderato.com.

If you are under the legal age detailed above, you are not authorised to use our services without the prior and explicit consent of one of your parents or the holder of parental authority, which must be sent to us by email to dpo@le-moderato.com.

If you believe that we are holding personal data about your children without your consent, please contact us at the dedicated address detailed above.

Why do we process your personal data and on what basis?

We process your personal data mainly for the following reasons:

  • browse our website, benefit from our services and so that we can respond to your requests (e.g. requests for information, complaints, etc.) on the basis of our general terms of use and our legitimate interest in providing you with the best possible service.
  • manage our customer service on the basis of the performance of the contract and our legitimate interest in responding as effectively as possible to your requests and complaints.
  • to be kept informed of our latest offers and events by email on the basis of our legitimate interest in retaining our customers and prospecting potential new customers if you are a professional; on the basis of our legitimate interest in retaining our customers and on the basis of your consent if you are an individual who is not yet a customer of our services.
  • to be kept informed of our latest offers and events by SMS on the basis of our legitimate interest in retaining our customers and on the basis of your consent, if you are not yet a customer of our services.
  • to keep you informed of our latest offers and events by telephone, on the basis of our legitimate interest in building customer loyalty and prospecting potential new business customers.
  • manage invoicing and any outstanding payments, on the basis of our legitimate interest in obtaining consideration for the provision of our service and on the basis of our general terms and conditions.
  • follow us and comment on our publications on social networks on the basis of our legitimate interest in having a dedicated page on social networks.
  • receive our newsletter informing you of all the latest news about our services on the basis of our legitimate interest in retaining our customers and on the basis of your consent if you are not yet a customer of our services.
  • apply for a position with Moderato SAS on the basis of discussions we have with you during the recruitment process and our legitimate interest in recruiting and selecting candidates.
  • operate the videos on our site on the basis of our legitimate interest in offering you content in video format.
  • send satisfaction surveys based on our legitimate interest in improving our services.
  • to enable you to take part in our competitions, on the basis of our legitimate interest in organising them and the execution of the associated competition rules.

How did we obtain your personal data?

Your data is collected directly from you when you are a customer of our services or a "simple" visitor to our website www.le-moderato.com and we undertake to process your data only for the purposes described above.

However, we may also obtain your personal data indirectly from partners if you have given your prior consent.

For professionals only, your personal data may also be processed indirectly in the context of trade fairs or social networks (e.g. LinkedIn).

On the other hand, when you voluntarily publish content on the pages that we publish on social networks, you acknowledge that you are entirely responsible for any personal information that you may transmit, whatever the nature and origin of the information provided.

What personal data do we process and for how long?

We have summarised the categories of personal data and their respective retention periods below:

  • For private individuals, personal identification data (e.g. surname, first name) and contact details (e.g. email address) are kept for the entire duration of the service, plus the statutory limitation periods, which are generally 5 years.
  • For professionals, personal identification data (e.g. surname, first name, position, company, department, etc.) and contact details (e.g. e-mail address and business telephone number, etc.) are kept for the entire duration of the service, plus the statutory limitation periods, which are generally 5 years.
  • For private individuals, data of an economic and financial nature (e.g. bank account number, verification code, etc.) kept for the time required to complete the transaction and manage invoicing and payments, plus the statutory limitation periods, which are generally 5 to 10 years.
  • For professionals, when there is confusion between the name of your organisation and your personal name (e.g. self-employed entrepreneurs, very small businesses, etc.), economic and financial data (e.g. bank account number, verification code, etc.) retained for the time required for the transaction and for managing invoicing and payments, plus the statutory limitation periods, which are generally 5 to 10 years.
  • Telephone number for our commercial prospecting campaigns by SMS and telephone kept for a maximum of 3 years from the last contact we had with you.
  • Email address, kept for a maximum of 3 years from the last contact we had with you as part of our email prospecting campaigns, and kept until the end of your subscription to receive our newsletter.
  • The information on your CV and covering letter will be kept for the duration of the recruitment process and for 2 years from the date of your application.
  • Statistical data relating to the viewing of our videos, which is anonymised and stored indefinitely.
  • Connection data (e.g. logs, IP address, etc.) retained for 1 year.
  • Cookies are generally kept for a maximum of 13 months. For more details on how we use your cookies, you can consult our cookies policy, which can be accessed at any time on our website.

Once the applicable retention periods have expired, the deletion of your personal data is irreversible and we will no longer be able to communicate it to you. At the most, we may only keep anonymous data for statistical purposes.

Please also note that in the event of a dispute, we are obliged to keep all your personal data for as long as the case is being processed, even after the retention periods described above have expired.

What rights do you have to control the use of your personal data?

The applicable data protection regulations give you specific rights which you can exercise, at any time and free of charge, to control the use we make of your data.

  • The right to access and copy your personal data, provided that this request does not conflict with business secrecy, confidentiality or the confidentiality of correspondence.
  • The right to rectify any personal data that is incorrect, obsolete or incomplete.
  • The right to object to the processing of your personal data for commercial prospecting purposes.
  • For consumers only, the right to register free of charge on the Bloctel telephone anti-spam list at www.bloctel.gouv.fr.
  • The right to request the deletion ("right to be forgotten") of your personal data that is not essential for the proper functioning of our services.
  • The right to limit your personal data, which allows you to photograph the use of your data in the event of a dispute over the legitimacy of processing.
  • The right to data portability, which allows you to recover part of your personal data so that it can be easily stored or transmitted from one information system to another.
  • The right to give instructions on what should happen to your data in the event of your death, either through you or through a trusted third party or beneficiary.

For a request to be taken into account, it must be sent directly by you to dpo@le-moderato.com. Any request that is not made in this way cannot be processed.

Requests cannot come from anyone other than you. We may therefore ask you to provide proof of identity if there is any doubt about the identity of the person making the request.

We will respond to your request as quickly as possible, subject to a maximum of three months from receipt if the request is technically complex or if we receive many requests at the same time.

Please note that we can always refuse to respond to any excessive or unfounded request, particularly if it is repetitive.

Who can access your personal data?

Your personal data is processed by our teams and by our technical service providers for the sole purpose of operating our service.

We would like to point out that we check all our technical service providers before recruiting them to ensure that they scrupulously comply with the applicable rules on the protection of personal data.

WE GUARANTEE THAT WE WILL NEVER TRANSFER OR SELL YOUR DATA TO THIRD PARTIES OR COMMERCIAL PARTNERS.

Can your personal data be transferred outside the European Union?

The personal data processed by our website is hosted on servers located outside the European Union. In order to protect your personal data, we scrupulously ensure that our host implements the appropriate guarantees required to ensure the confidentiality and protection of your data.

We may also use technical tools located outside the European Union. If this is the case, we guarantee that they comply strictly with the applicable rules on transfers in order to guarantee confidentiality and adequate protection of your personal data.

How do we protect your personal data?

We implement all the technical and organisational means required to guarantee the security of your personal data on a day-to-day basis and, in particular, to combat any risk of destruction, loss, alteration or disclosure.

Do we use cookies when you browse our website?

Please note that we use cookies when you browse our website. For more information, please consult our Cookies Policy.

Who can you contact to obtain more information about the use of your personal data?

To guarantee the protection and integrity of your data, we have officially appointed an independent Data Protection Officer ("DPO") to our supervisory authority.

You can contact our DPO free of charge at any time at dpo@le-moderato.com to obtain more information or details on how we process your data.

How can you contact the CNIL?

You may at any time contact the "Commission nationale de l'informatique et des libertés" or "CNIL" at the following address: CNIL Complaints Department, 3 place de Fontenoy - TSA 80751, 75334 Paris Cedex 07 or by telephone on 01.53.73.22.22.

Can the Privacy Policy be modified?

We may amend our Privacy Policy at any time to adapt it to new legal requirements and to new processing operations that we may implement in the future.

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