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Privacy Policy

PERSONAL DATA PROTECTION

Latest version July 10, 2023

In accordance with the regulations in force in France and the European Union and with regard to the General Data Protection Regulation (GDPR) EU 2016/679 of April 26, 2016, which came into effect on May 25, 2018,

THEMIS TRANSACTIONS undertakes to implement the necessary measures to protect, secure and maintain the confidentiality of the personal data of the users of its website. Through this privacy policy, THEMIS TRANSACTIONS informs them of its practices regarding the collection and use of personal data.

Définitions

The Editor: THEMIS TRANSACTIONS SAS, owner of the website www.themis-transactions.com and responsible for processing the personal data collected from users.

The Site: www.themis-transactions.com, comprising all the web pages offered by the Editor.
The User: The individual using the Site.
Personal Data: All the User’s personal data.

By browsing the Site, the User acknowledges having read and accepted without reservation the privacy policy and the General Terms of Use.
En naviguant sur le Site, l’Utilisateur reconnait avoir pris connaissance et accepter sans réserve la politique de confidentialité ainsi que les Conditions Générales d’Utilisation.

1. Collection of Personal Data

Free browsing
The Site can be browsed without the User having to communicate any Personal Data.
The Editor does not record any data for simply browsing the Site.

Collection practices
The practices requiring the collection of Personal Data are as follows :

  • Responding to the User’s requests for information via the Site’s contact forms,
  • Sending informational or commercial emails to the User.

Nature of Personal Data collected

Identity data

When using the Site, the User may be required to provide Personal Data that may be collected by the Editor such as :

  • Civil status data: Last name, First name
  • Postal address and country of residence
  • Contact information: Phone, Email
  • Name of the company owned by the User.

Technical data :

When using the Site, the Editor may collect and store, through cookies (see §4), certain technical data from the User’s device such as :

  • Internet Protocol (IP) address
  • Internet Service Provider
  • URL links through which the User accessed the Site.

2. Retention period for Personal Data

In accordance with the recommendations of the French Data Protection Authority (CNIL), Personal Data will be kept for the time necessary to fulfill the User’s request. The maximum retention period for Personal Data is three years from the date it was collected by the Site. After this period, it will be deleted subject to legal obligations regarding the retention, archiving or anonymization of certain data.

3. Disclosure of Personal Data

No disclosure to third parties
The Personal Data of the Site’s Users is not subject to any communication, publication, transfer, exchange, assignment or sale to third parties. However, the User is informed that it may be disclosed pursuant to a law, regulation or a decision of a regulatory or judicial authority.
Transmission in the event of a merger/acquisition

Only the assumption of the absorption of the Editor and its rights would allow the transmission of the User’s Personal Data to the absorbing company which would in turn be bound by the same obligations regarding the processing inherent to the collection and use of Personal Data.

As part of this operation, the User concerned will be sent prior notice regarding the transmission of the collected Personal Data.

4. Cookies

Cookie retention period
In accordance with CNIL recommendations, the maximum cookie retention period is 13 months after they were first stored in the User’s device, just like the validity period of the User’s consent to the use of these cookies. The lifespan of cookies is not extended on each visit. The User’s consent must therefore be renewed after this period.

FPurpose of cookies
The cookies used by the Editor are strictly necessary for the proper functioning of the Site or for statistical analysis purposes in particular to optimize the services provided to the User, based on processing information concerning the frequency of accessing the Site, customizing pages as well as operations performed and information viewed.

User’s right to refuse cookies
The User acknowledges having been informed that the Editor may use cookies. If the User does not wish cookies to be used on their device, they are invited to use the functionality present in their browser to disable cookies in the settings options.

5. Security of collected Personal Data

Implementation
The Editor implements all appropriate technical and organizational measures to ensure a level of security adapted to the storage of Personal Data. However, the User acknowledges that no storage or transmission technology is completely foolproof.

Informing the User and the competent authority in the event of a security breach
In the event of unlawful or unauthorized access to stored Personal Data, the Editor undertakes to inform the User and the competent supervisory authority as soon as possible in accordance with the procedures provided for by the applicable regulations.

Limitation of the Editor’s liability
Under no circumstances can the commitments defined in the above point relating to notification in the event of proven breach of Personal Data be equated with any kind of acknowledgment of fault or liability regarding the occurrence of the incident in question.
The User must also take all necessary measures to prevent any unauthorized access to their Personal Data.

6. Hypertext links to Partner sites

The Site may contain hypertext links redirecting to certain sites in its partner network, each with its own GDPR privacy policy over which the Editor has no control.

It is up to the User to read the privacy policies of the third party sites regarding the protection and use of Personal Data before communicating it to them. The Editor therefore declines any responsibility for the processing of such data by third party sites.

7. User’s rights

Right to information
The Editor undertakes to communicate in the greatest transparency about the conditions under which the User’s Personal Data is processed, in particular through this privacy policy. The User has a right to information in this regard.

Right of access to Personal Data
The User has the right to access their Personal Data processed by the Editor concerning them. This data will be provided in an open and easily reusable format.

Right to rectify or erase Personal Data
The User has the right to rectify or erase their Personal Data. The Editor undertakes to respond to this on first request. However, the User is informed that some of it may be retained by the Editor pursuant to a law or by decision of a regulatory or judicial authority or in case of legitimate grounds.

Right to lodge a complaint with a competent authority
The User has the possibility to file a complaint with a competent authority (CNIL, etc.) if they believe that the Editor is not doing everything possible to preserve the confidentiality of their Personal Data.
The CNIL provides models of letters on its website www.cnil.fr for the User to exercise their rights.

8. Changes to the privacy policy

Commitment not to lower the level of confidentiality 

Depending on legislative and regulatory developments and in order to improve data protection processing, the User is informed that the Editor may need to amend this privacy policy. Nevertheless, the Editor undertakes not to lower the level of confidentiality of the collected Personal Data.
Therefore, it is recommended that the User refer regularly to this privacy policy in order to follow any amendments and check the date of the latest updated version.

9. Applicable law and jurisdiction

Any dispute relating to this privacy policy and the use of the Site is subject to French law.
Prior to referring the matter to any court, the User undertakes to contact the Editor in order to find an amicable solution to the dispute between them. In the absence of an amicable agreement, the dispute will fall under the jurisdiction of the Courts of the Aix-en-Provence Court of Appeal (13).

10. Contact

For any questions regarding this privacy policy, the User is asked to contact the Editor :