Privacy policy – Vinispi

Version DANTES – n°1 of May 12, 2020, at 2:25 p.m.

Concerned about respecting the privacy of Internet users, the DANTES Company, (hereinafter “the Company” or “we”), undertakes that the collection and processing of personal information will be carried out in accordance with EU Regulation No. 2016/679 of the European Parliament and of the Council of April 27, 2016 on the Protection of Individuals with regard to the processing of personal data and on the free movement of such data hereinafter “RGPD” and with all the provisions of the French regulations applicable in this matter.

1. DATA CONTROLLER

DANTES whose registered office is located at 31 rue Nollet – 75017 PARIS, registered in the PARIS Trade and Companies Register under number 803 694 918, which operates the following website (hereinafter referred to as “the Site”):
https://vinispi.com

2. COLLECTED DATA

Your personal data is collected and processed on the following legal bases:

in the performance of a contract ;
for legitimate interests;
on the basis of your consent via a personal data collection form;
to ensure compliance with our legal and regulatory obligations.

2.1
Your personal data

In general, your data is therefore collected directly from you in the course of :

your subscription to one of the Company’s newsletters and/or communications;
your consultation of our newsletters, communications (statistics of openings, clicks…) ;
your inquiries via a contact form;
your browsing on the Site ;
certain partnerships offering services from the Site;
exercising your rights regarding your personal data.

We collect and process the following personal data:

identification data (e.g. surname, first name, e-mail address, proof of identity if you wish to exercise your rights);
connection data (e.g. IP address, terminal type, browser type and version, operating system, date and time of access, connection logs);
data relating to your communications (e.g. e-mail, consultation and usage statistics);
preferences, editorial and/or advertising interests declared by Site users or deduced from your browsing.

Cookies or similar technologies (hereinafter “cookies”) may be installed and/or read in your browser when you visit the Site. Click here to find out more.

If your personal data is collected by means of a form, you will be informed of the compulsory nature of the information by an asterisk (*) next to the fields concerned. The absence of an asterisk means that the information requested is not mandatory.
Only personal data that is strictly necessary for the purposes described below, and in particular for subscribing to our newsletters and for compiling statistics on Site traffic, is collected.

2.2 Data concerning minors

In principle, our products and services are intended for people of legal age who are capable of entering into contractual obligations.
Users who are minors must obtain the consent of their legal guardians prior to the communication of personal data concerning them.
The age of 16 is accepted for registration on our Site and for some of our online services (e.g. newsletter).
Internet users under the age of 18 at the time of publication or creation of an online account have a specific right to have their personal data deleted.

3. PURPOSES OF PROCESSING

We use the data referred to in the previous article for the following main purposes:

3.1 Operations required to supply products or services

managing subscriptions to our newsletters and/or e-mail alerts ;
updating your personal information in a dedicated database;
a service available by post, telephone or e-mail for any questions or complaints;
statistics on our existing services or as part of the development of new services;
continuous improvement of our services, in particular through the use of advanced data analysis technologies;
audience statistics ;
sending information about changes or developments in our services;
automatically collects information about your editorial and advertising interests, browsing patterns, visitor numbers and interaction data when you visit the Site, by means of tracers (cookies);
managing the exercise of your personal data rights ;
verification of compliance with applicable legislation, our contracts and general terms and conditions.

3.2 Marketing and sales prospecting operations relating to publications, products and services

sending marketing, advertising and promotional offers relating to our products and services by e-mail or any other medium.

3.3 Business partnership transactions

Display targeted ads from partners ;
Display targeted editorial content proposed by partners.

4. DATA RETENTION PERIOD

Your personal data is kept for a period of time that complies with legal provisions or is proportionate to the purposes for which it was collected. However, your personal data may be kept for a longer period when required by legal and regulatory obligations.

User data

Data categories	Goals	Shelf life
Identification and contact data	a service available by post, telephone or e-mail for any questions or complaints;	13 months from the last contact1 from the user*.
Identification and contact data - Newsletter subscribers	Sending newsletters, information on the evolution of our publications and offers	3 years from unsubscription or last contactError: source of reference not found from user
Data relating to the exercise of personal rights Personal identification data provided in response to a request to exercise a right	Managing the exercise of your personal data rights	6 years from request to exercise a right
Data generated by cookies
Data related to your browsing on our online services	Service operation and optimization Visitor measurements Personalized content and advertising	13 months maximum

* Last contact: Positive action on the part of the user: for example, clicking on a newsletter, requesting information, etc.

5. RECIPIENTS OF YOUR PERSONAL DATA

Your personal data will be communicated to the following persons:

5.1 Internal to the Company

Your data is communicated to employees of the Company’s internal departments.

In accordance with regulations, access to your data is based on individual, limited and supervised access authorizations.

5.2 To our subcontractors

They provide services on our behalf, in particular:

customer relationship management ;
management of marketing campaigns and sales prospecting;
handling telephone calls, sending postal or digital mail;
the personalization of the Site’s advertising content;
maintenance operations and technical developments;
the supply of analytical solutions or audience measurement statistics;
digital reading solutions (including video).

5.3 A Our business partners

They promote products or services on their own behalf or on behalf of advertisers.

6. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

We store your personal data in the European Union. However, some data is transferred to our subcontractors outside the European Union, in the United States. We have ensured that the processing is governed by the privacy shield (

https://www.privacyshield.gov/participant?id=a2zt0000000GnH6AAK

) , which guarantees an adequate level of protection for the privacy and fundamental rights of individuals.

We undertake to verify the renewal of our subcontractor’s certification to the “Privacy Shield” and to sign the European Union’s Standard Contractual Clauses with the subcontractor in the event of non-renewal of the certificate.

7. YOUR RIGHTS

In accordance with the aforementioned legal and regulatory provisions, you have :

a right of inquiry;
a right of access to your data;
a right of rectification ;
a right to erasure;
a right to limit the processing of your data
a right to portability of your data to a certain extent, i.e. the right to receive the personal data you have provided us with in a structured, commonly used format and the right to transmit this data to another data controller;
the right to object to the processing of your personal data;
a right to object to your data being used for prospecting purposes, in particular commercial prospecting (see 9.);
a right to object to marketing profiling, which means that you will continue to receive commercial solicitations but they will be less relevant and will no longer be targeted according to your centers of interest;
the right to define general and/or specific directives concerning the fate of your personal data and the manner in which you wish your rights to be exercised after your death. In this respect, in the event of your death, your data will be deleted, unless it needs to be kept for a specific period of time for reasons relating to our legal and regulatory obligations and/or legal limitation periods, and after having been communicated to a third party designated by you.

You may exercise your rights by contacting the Company:

by sending a letter to the following postal address:
DANTES
31 rue Nollet – 75017 Paris

by sending an e-mail to the following address
contact@twil.fr

In the interests of confidentiality and the protection of your personal data, the company must verify your identity before responding to such a request. Any request to exercise these rights must be accompanied by a copy of a signed identity document.

In the event of an unsatisfactory response, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL): https: //www.cnil.fr/fr/plaintes.