COMMITMENT TO THE PROTECTION OF PERSONAL DATA

MACC (9 rue des frères Lumière - ZI du Sanital - CS 50427- 86104 Châtellerault France, intends to make control of your data and respect for your privacy a fundamental concern that is consistent with our cooperative values of trust and transparency.

This is why MACC intends to strictly comply with the General Data Protection Regulation (GDPR) (red. le Règlement Général sur la Protection des Données, RGPD) that came into force on 25 May 2018. 

The GDPR is the European framework for the processing and circulation of Personal Data, the information on which companies rely to offer services and products. This text covers all persons residing in the European Union.

This regulation is based on two main objectives: on the one hand, to strengthen the right of persons whose data are processed, and on the other hand, to strengthen the obligations of the structures that process such data.
On this occasion, we made sure to inform you of the rigorous steps taken by MACC to comply with these regulations.

This document is intended to help you better understand our privacy practices, including the Personal Data we collect, why we collect it, what we do with it, and how we protect it, as well as your individual rights. 

INTENT OF THE COMMITMENT

This Personal Data Protection commitment describes the conditions under which we undertake to comply with all French and European regulatory and legislative provisions regarding the protection of this data.

This document may be amended at any time, in particular to comply with any regulatory, jurisprudential, editorial or technical developments. On the Internet, the user must refer before any navigation to the latest version of this commitment.The Personal Data of the user will always be processed in accordance with the commitment valid at the time of their collection, unless a legal and imperative prescription were to provide otherwise.

The Personal Data Protection commitment is an integral part of our General Terms and Conditions of Sale. By using our sites or by submitting personal information to us, the user acknowledges having read, understood and agreed to be bound by this Personal Data Protection Commitment

We are committed to following the regulation (UE) 2016/679 from 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and the free flow of such data (GDPR, red. RGPD), as well as the law for «trust in the digital economy» n° 2004-575 from 21 June 2004 (article L. 33-4-1 Postal and Telecommunications Code et article L. 121-20-5 of the Consumer Code).

WHAT IS PERSONAL DATA?

Any Information that directly or indirectly identifies a natural person: name, mail address or electronic address, phone number, account number, client number, IP address, are for example personal data. 


WHO IS REPONSIBLE FOR THE PROCESSING?

MACC collects et treats Personal Data for her own account as controller, in accordance with the Regulation (UE) 2016/679.


WHO IS THE RECIPIENT OF YOUR PERSONAL DATA? 


Only persons involved in the processing of data for a specific purpose (final goal) that you are informed of on a case-by-case basis will be able to access your data and only for that purpose.

The Personal Data may be processed by subcontractors (service providers), in full compliance with the above principle, exclusively in order to achieve the purposes of this commitment.

The Personal Data are intended for use by MACC as well as subsidiaries of the MACC Group.
Personal Data are not transmitted to commercial or advertising actors.

If we sell or divide all or part of our business, transfer assets or otherwise participate in a change of control transaction, or in the undesirable case of bankruptcy, we may be required to transfer Personal Data covered by this commitment to one or more third parties as part of the transaction.

In addition, we may access, transfer, disclose and retain the Personal Data when necessary to:

• Comply with applicable law or follow a justified legal procedure, including from judicial authorities or other public authorities;
• Protect customers, for example, to prevent unsolicited emails or fraud attempts;
• Operate and maintain the security of our products and services, including to prevent or stop an attack on computer systems or networks; protect our rights or property, including the application of the conditions governing the use of the products or services.
• Within these limits, all information collected is kept confidential and as necessary anonymous, only information which is exclusively necessary is transmitted to the addressees concerned.
In the event of a proven breach of legal or regulatory provisions, this Personal Data may be the subject of a communication at the express and reasoned request of the judicial authorities.

Within the limits of their respective responsibilities and for the purposes mentioned above, the main persons likely to have access to our Customers' data are predominantly the staff of our customer service (Trade and Marketing, Sales Administration, Technical).

We also use the services provided by several specialized companies (mailing, audience analysis) whose list can be communicated to the data subjects on request addressed to the contact below.

HOW IS YOUR PERSONAL DATA COLLECTED?

We process the Personal Data about you that you may communicate to us, in particular during the following operations:
• When you subscribe to one of our services;
• When you browse our sites;
• When you provide products or services to us;
• When you participate in events or public relations occasions organized by us;
• When you agree to receive our newsletters and other commercial information from us;
In case you would like to contact us for questions or with complaints.

HOW PERSONAL DATA ARE PROCESSED IN THE EVENT OF COMMERCIAL PROSPECTING

MACC may be required to process your personal data for commercial prospecting purposes, with the aim of making the company and its products known to as many potential customers as possible.

MACC may be required to process your personal data for commercial prospecting purposes, with the aim of making the company and its products known to as many potential customers as possible.

The legal basis for such commercial processing is constituted by the legitimate interest of MACC to ensure the visibility of its business activity and its products in order to guarantee its economic sustainability.

In this context, the data can be collected directly by MACC, on the occasion of a new relationship via the web site, a meeting with a sales representative of the company, etc.

Data may also be collected indirectly from business partners who produce and maintain databases on professionals from information also collected directly or indirectly (business partnerships, institutional files …). In this regard, MACC ensures that it has entered into partnerships and has surrounded itself with the most rigorous professionals in the management of such databases.

In the context of such a request, you of course, have a right of opposition allowing you, in the first place, to unsubscribe from any list sending commercial messages, but also secondly, to exercise this right towards MACC under the Regulations (see paragraph “What Rights”, hereafter).

WHAT KIND OF PERSONAL DATA IS COLLECTED?

We collect data to provide products and services to customers and to conduct our business.

Some of this data is provided directly, for example when the user creates an account on our web site or contacts us to obtain advice or to perform other services.

We also receive data by recording how users interact with our products and services (web sites, cookies, etc.).

The data collected depends on the products, services and features used and may include the following elements:

 Name and contact details. Marital status, identity, identification data, contact details (address, phone numbers, e mails, fax numbers, etc.) and other contact information.

Verification of permissions. We collect information used for authentification and account access on a web site, among other things.

 The payment data. We collect on our behalf, or on behalf of the funding bodies, the data necessary to process the payments in more than one time, such as bank information, bank transfers and/or any other financial information associated with a payment.

 The usage data. We collect data on how users and how they interact with the products and services we offer. For example, we collect data on service usage, web site activity data, the data on performance, product/service preference information, and purchase history

 Cookies. The web sites may collect certain types of data, that may include personal information during visits, including through the use of cookies. Cookies are small text files sent from a site to a user’s device’s hard drive to store information about that particular user or device. Cookies might store information about the device and users, including IP addresses, browsing data, server information, data transfer times, the user preferences and passwords needed to access the special areas of the sites. We may use cookies to facilitate the down loading of documents from sites and for other commercial purposes such as website traffic analysis.

If the user chooses to create his personal space, we use cookies to store the personal information of his profile. His or her browser can be configured to block, reject, delete or disable cookies and other tracking technologies. However, if the user rejects or deletes cookies or any other tracking technology, he or she may not be able to access certain pages or use important functions or use important functions, including down loading documents and setting up a user profile.

❏ Cookies strictly necessary for the workability of the MACC.fr web site

These cookies are essential for browsing our web site (such as session identifiers) ,which allow you to use the main features of the web site and to secure your connection. They allow you, for example, to access directly to reserved and personal areas of our web site, thanks to identifiers or data that you may have previously entrusted to us.
Without these cookies you will not be able to use the web site normally and we therefore advise you not to prevent their use or to delete them.
These cookies are stored exclusively by MACC.
These are the most important cookies we use: 


- The name of the cookie 
- Purpose 
- Longevity 
- PHPSESSIONID Identifier of the session : to maintain the connection Session
- brsxds_* Identifier for the session: maintain the connection Session 
- BRS_PROFIL Identifier for the session : preferences et news Session

❏ The functionality cookies 

These cookies allow to improve the operation of the MACC website
They also allow you to adapt the presentation of the site to the display preferences of your terminal during your visits. These cookies allow you to have a smooth and customized navigation.
Placing cookies on your device is the simplest and fastest way to customize and improve your user experience.

These cookies are deposited by MACC. They have a very short lifespan, for the majority, the time of the session, and a maximum of 13 months.

Examples of functionality cookies:
Name of the cookie Function Longevity 

- profilInfos width OSD (red. on screen display) Session
- rememberme Identification on the connection page 30 days 
- Cistr* Validation of the connection 12 months 
- Ckln* Identification of the navigator 13 months 
- session Functions Session
If you have refused the implementation of cookies, you will not be able to benefit from the features described in the present paragraph

❏ The analytical cookies / performance cookies

These are cookies that allow us to know the use and performance of the web site, to establish statistics, the volumes of use and the use of various elements (content visited, path …) in order to improve the interest and ergonomics of our services (the pages or paragraphs that you have visited most often, the articles that you read most, ...).

The cookies also serve us to count visitors to a certain page.
These analytical cookies are implemented by Google Analytics and AT Internet. Every now and then, cookies from MACC may be deposited in certain advertising content, in order to measure the effectiveness of these campaigns, as well as in order to guard against computer fraud.

Cookies from MACC may also be deposited for the purpose of measuring the effectiveness of campaigns and the aggregate composition of users, deposited on the basis of aggregated and anonymous statistical data.
The confidentiality commitment of MACC is available at the following address: ZI du Sanital 9, rue des Frères Lumière ZI du Sanital 86104 CHATELLERAULT.
Because of the partners implementing these analytical cookies, transfers of personal data may be subject to have been made towards non-EU countries, whose personal data protection legislation differ from that of the European Union.

In that case, a precise and demanding framework, consistent with the models adopted by the European Commission, as well as appropriate security measures, ensure the protection of transferred personal data. The transfer of personal data made necessary, shall take place under the conditions and under the guarantees necessary to ensure the confidentiality and security of such data.

As such, we implement all appropriate technical and organisational measures to ensure the security of your personal data.

The fact of refusing the implementation of such cookies or of deleting them, does not affect your navigation on the web site, but is likely to prevent us from ensuring the best quality of services that we would wish to offer to our visitors.

❏ Shared cookies (social links)

We may well include on the web site, computer applications from third parties, which allow you to share content from our web site, with other persons or to make them aware of your consultation or your opinion regarding content on our web site.

Our web site may thus contain sharing links to Facebook, Twitter and other similar social networks, which allows you to share content from our Site with other persons. 
When you use these share buttons, a third-party cookie from the relevant social network is installed. If you are connected to the social network during your browsing on our web site, the share buttons allow you to link the content viewed to your user account.
If you have refused the implementation of cookies, you must sign in yourself during each sharing operation to the network(s) concerned.

The social network providing such an application button is likely to identify you through this button, even if you did not use this button when visiting our web site. As a matter of fact, this type of application button can allow the social network involved, to track your browsing on our web site, simply because your account on the social network concerned was activated on your terminal (open session) during your browsing on our web site

We invite you to please consult the privacy commitments of these social networks, in order to become familiar with the purposes of use, particularly with regard to advertising, of the browsing information they may collect through these application buttons. The cookie commitments of the social networks concerned are accessible down below:
• Facebook : https://fr-fr.facebook.com/policies/cookies/
• Twitter : https://twitter.com/privacy?lang=fr

These protection commitments must allow you to apply your choices with these social networks, in particular by setting up your accounts to use each of these networks.

❏ Browsing data and advertising cookies

As part of your browsing on all pages of our web site, MACC may process your browsing data and/or use advertising cookies in order to be able to offer you the most relevant advertising possible, adapted to your interests. Ces publicités peuvent être affichées sur notre site, aussi bien sur les pages accessibles au public, que sur celles sur lesquelles vous vous serez connecté en qualité de membre ou de client. They might also be displayed on other web sites you browse.

The relevance of the advertising content displayed on your device can also be realized, thanks to the technology of one of our partners, by the combination of the navigation information of your connection on our web site, with the data you have provided us when you register or access one of our services. 
The refusal of these advertising cookies has no impact on the use of our web site. 

However, denying them may result in the termination of advertising on our web site or on the Internet, which would then no longer be adapted to your special interests.
This will only have the effect of displaying an advertisement that will not take into account your interests or preferences.

These cookies are mainly third-party cookies and depend mainly on advertising company ruless. They come from companies such as Google Remarketing, Google Adwords Conversion Pixel, Google Analytics, etc.


 Other technologies. Sites also use IP addresses, log files and other technologies to identify problems and use of the site. We also use web beacons to perform standard traffic analysis on sites in the same way that we use cookies and to track the use of the website for statistical purposes. We reserve the right to introduce new tracking technologies and techniques related to the use of the web sites, although we do so in compliance with applicable data protection laws and regulations.

Consequences of failure to respond

In certain circumstances, the collection of Personal Data identified by an asterisk is mandatory. It is mandatory to transmit real and accurate information and it is necessary to contact us for any update of these. Failure to do so may result in the request not being processed or delayed.


Use of Personal Data
We only process data or a category of data if it is strictly necessary for the intended purpose. You can find information about these purposes below. 

We use, disclose, transfer and process data, including personal information, for different purposes
• Operate our business and provide and support the products and services offered (including enhancement and customization), and
• Purposes and legal bases of processing

We only process Personal Data for specific, explicit and legitimate purposes. We do undertake not to process any data in a manner incompatible with these purposes.
Your Personal Data is collected as part of the execution of a contract, in particular, in order to:
• • Allow you to join and allow us to manage your customer account;
• Send you commercial information about us;
In this context, the processing is based on our legitimate interest, more specifically our economic interest to communicate personalized offers to you, to better understand your needs and to offer you adapted services, in particular, using computer tools that allow us to analyze your interests according to your purchases, in particular according to criteria of recency/frequency/amount.

• Manage the contractual relationship with our customers, service providers and partners (contract management, orders, deliveries, invoices, public relations, etc.);
In this context, the legal basis for processing is the performance of the contract between us and you.
The data thus collected will not be processed or transmitted for other purposes.

We also carry out data processing for purposes other than the strict execution of contracts. In this case, we ensure that we have a legitimate interest in carrying out the processing.Furthermore, treatments may be the subject, as necessary, of the reception of your consent, which you may withdraw at any time.

• Analyze your browsing on our sites and improve their use;
In this context, the legal basis for processing is our legitimate interest, more specifically our economic interest to continuously improve our sites and services and to understand your needs to meet your expectations.
• Answers to your questions and complaints;

In this context, the legal basis for processing is either the performance of the contract, if the request is related to the contractual relationship between us and you, or our legitimate interest, more specifically our economic interest in communicating clearly with you and understanding your needs and expectations.

• Process your transactions and payments;
In this context, the legal basis for processing is either the performance of the contract between us and you when it comes to managing your transactions and payments, or compliance with legal obligations if we implement measures to combat fraud.

To this end, the following aims are pursued: 

• Your data is kept for the period necessary for the fulfilment of the aforementioned purposes.
• We also process your data to meet our legal or regulatory obligations. 


Your data may be retained for as long as necessary to enable us to meet its legal obligations.
We may also process your data for statistical purposes, including marketing the resulting statistics. In this case, all the data is previously made anonymous.
Personal Data on Social Networks

Our customers can click on the social media icons (Twitter, Facebook, LinkedIn and Google Plus...) on our websites.


The use of Personal Data Social networks makes it possible to improve the usability of the web site and help its promotion through sharing. Video sharing services enrich the web site with video content and increase its visibility.
When the user clicks on these buttons, we will be able to access the personal information that the User has indicated as public and accessible from his social network profiles. However, we do not create or use any database independent of these social networks based on the personal information that the user may publish there and we will not process any data relating to his privacy through this way.
If you do not want your personal information to be transmitted from the Site to the social networks, we advise you in this case: 

• Not to interact with these social networks by clicking on the plug-ins available on the site;
• To deactivate your account on the relevant social network before coming to browse our Site;
• Navigate in “Private” mode via your browser;

SECURITY OF PERSONAL DATA 

We maintain technical and administrative procedures in accordance with current regulations and state of the art to protect Personal Data against accidental or unlawful destruction, accidental loss, modification, or unauthorized disclosure.
Links to other websites
The elements set out in this Personal Data Protection Commitment, are for all web sites and all of our activities. Other web sites hosted by third parties may have different practices. If a user creates a link to or visits other web sites managed by third parties, they should consult the privacy policies published on these web sites. We have no control over these web sites and are not responsible for the commitments and practices followed by third parties.
Retention of Personal Data
The Personal Data are kept only for a necessary period and proportionate to the purpose for which they were collected. However, we may retain your Personal Data for a longer period to comply with legal obligations, including applicable limitation periods.
We undertake to erase the data from these databases or to make it anonymous at the end of a predetermined period by the interested parties (manufacturers, customers, suppliers, etc.), or by aligning with the regulations and referentials issued by the CNIL (red. the National Commission for Data Protection and Liberties)

In order to define an adequate data retention period, we use in particular the following criteria:
• The data relating to your membership, your payments and the use of our services are kept for the entire duration of the membership/contractual relationship and then in compliance with the applicable limitation periods;
• Data relating to the management of the commercial relationship with our service providers and partners are kept for the entire duration of the contractual relationship and then in compliance with the applicable limitation periods;
• Where you have consented to receive commercial prospecting, we will retain your Personal Data until you express your wish to no longer receive communications, otherwise in accordance with a period defined by the applicable legislation;
• When your data is collected in connection with queries/questions relating to IT services and applications, we retain this data for the duration necessary to process such queries;
Your personal data may be stored for the following periods:
• 1 year for connection logs from the last connection;
• 13 months for cookies from their deposit on your computer or terminal;
• 3 years for non-order customer identification data (name, first name, email address, telephone number, etc.);
• 6 years for tax documents;
• 10 years for accounting documents;
• If applicable, the entire duration of the proceedings and until the remedies have been exhausted.
At the end of the planned retention period, the Personal Data shall be deleted or anonymised.The data necessary to fulfil a legal or regulatory obligation may be archived for the time corresponding to the fulfilment of the obligation in question.
Archived data will be deleted when there is no longer a need to archive it.

Transfer of Personal Data

We remind you that your Personal Data are not transferred to third parties and in particular to business partners.
In particular, if the subcontractors and partners concerned are not members of the Privacy Shield Agreement in respect of transfers to the United States of America, or are not located in a country with legislation considered to provide adequate protection, they must have previously signed the European Commission’s "standard contractual clauses" or will be subject to binding internal rules approved by the authorities. 

WHAT RIGHTS CAN I EXERCISE OVER MY PERSONAL DATA? 

In accordance with the applicable legislation on the protection of Personal Data, you have a number of rights concerning the collection and processing of your Personal Data, namely:
• The right

WHAT RIGHTS CAN I EXERCISE OVER MY PERSONAL DATA? 

In accordance with the applicable legislation on the protection of Personal Data, you have a number of rights concerning the collection and processing of your Personal Data, namely:
• The right to be informed: You have the right to be informed in a concise, transparent, understandable and easily accessible way about how your Personal Data is processed.

• Right of access: You have the right to obtain (i) confirmation that Personal Data concerning you are or are not processed and, where they are processed, to obtain (ii) access to such data and a copy thereof.

• The right to rectification: You have the right to obtain rectification of Personal Data concerning you that are inaccurate. You also have the right to have incomplete Personal Data completed, including by providing a supplementary statement.

• The right to erasure: In some cases, you have the right to obtain the erasure of your Personal Data. However, this right is not an absolute right and we may have legal or legitimate reasons to keep the said data.

• The right to portability: You have the right to receive the Personal Data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without our interference. This right applies only when the processing of your Personal Data is based on your consent or on the performance of a contract and the processing is carried out using automated processes.

• The right to object: You have the right, for reasons relating to your particular situation, to object to the processing of Personal Data concerning you when such processing is based on our legitimate interest. However, there are legitimate and compelling reasons for further processing. When your Personal Data is processed for prospecting purposes, you have the right to object to the processing of this data at any time. You can benefit from this right by clicking on the "unsubscribe" link available at the bottom of the messages received.

• The right to limitation: If you object to the accuracy of the data used or if you object to the processing of your data, the law allows us to verify or examine your request for a certain period of time. During this period, you have the option to request to freeze the use of your data.Concretely, we do not use the data, but keep it.

• If conditions for collection are challenged

• The right to limitation: If you object to the accuracy of the data used or if you object to the processing of your data, the law allows us to verify or examine your request for a certain period of time. During this period, you have the option to request to freeze the use of your data.Concretely, we do not use the data, but keep it.

• In the event of a dispute concerning the conditions relating to the collection and processing of your Personal Data, you also have the right to lodge a complaint with a supervisory authority: You have the right to contact a supervisory authority (such as the CNIL) in order to lodge a complaint concerning our practices relating to the protection of Personal Data.

• The right to provide instructions on the use of data after death: You have the right to give us instructions on the use of your Personal Data after death.
These rights can be exercised by request at the following address: dpo-rgpd@macc.fr or by post at the following address: MACC – DPO-RGPD - 9 rue des frères Lumière - ZI du Sanital - CS 50427- 86104 Châtellerault. You must prove your identity and indicate the context in which you provided us with your Personal Data (date of complaint and/or reason).
If the conditions relating to the collection and processing of your Personal Data are challenged, you also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (www.cnil.fr).

If you access Personal Data during your visit to the site, you must refrain from any collection, unauthorized use and any act that may constitute an infringement of the privacy or reputation of individuals. We do not accept any responsibility in this regard. 


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