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Privacy Policy

Last updated: April 6, 2021

S GOBERT company places great importance on confidentiality and data protection. In the context of organizing contests, S GOBERT company collects personal data concerning you in a spirit of loyalty and transparency in accordance with the Data Protection Act of January 6, 1978 as amended in 2004, the Law for Confidence in the Digital Economy ("LCEN") of June 21, 2004 and the General Data Protection Regulation ("GDPR") 2016/679 of April 27, 2016.

The purpose of this Privacy Policy is to describe the types of personal information we collect, how it is used, and how the protection of this data and your rights are ensured.

By participating in contests, you declare that you have understood and accepted the practices described in this Privacy Policy.

A — Type of data collected and purposes of processing

A.0 — Preamble - Data Storage

Please note that our data storage services/units are located in the EU:

Amazon Web Services, Inc.
P.O. Box 81226
Seattle, WA 98108-1226
https://aws.amazon.com

Location of Datacenters: IRLANDE
EU-US Data Protection Shield:
https://www.privacyshield.gov

A.1 — Personal data

The concept of personal data refers to any information relating to an identified or identifiable natural person.

As part of your registration and participation in the game, you voluntarily provide us with data about yourself:

  • Your name, first name, age, title, date of birth, email address, postal address and telephone number (landline and/or mobile); and any other data that may appear on the registration form, provided that such data is in no way categorized as sensitive.

As part of your registration and participation in the game, you will never be asked to provide sensitive personal data. By sensitive personal data we mean, in accordance with the GDPR:

  • your racial or ethnic origin; your political opinions, religious or philosophical beliefs; your trade union membership; processing of genetic data; biometric data for the purpose of uniquely identifying a natural person; data concerning your health; data concerning your health; data concerning sexual life; your sexual orientation.

As part of your registration and participation in the game, we may ask qualifying questions about your preferences, interests, and user behavior:

  • data relating to your family situation and consumption habits such as marital status, number of people in the household, number and age of child(ren) in the household, socio-professional group, owner/tenant status, etc.

Please note that all fields in the contest entry form are mandatory in order to participate in the contest.

When browsing our website, we may collect certain information relating to your browsing:

  • navigation data such as IP address and communication information made available through the use of your computer are collected automatically. This data is used only for purposes related to dispute resolution. Furthermore, statistical data may be collected during your visit and used.

In the case of an online survey, all your answers are kept strictly confidential and no link is made between your survey responses and your personal data.

A.2 — Identity and contact details of the data controller

Les données à caractère personnel recueillies font l’objet d’un traitement informatique dont le responsable est la société S GOBERT, EURL au capital de 15 000 euros, dont le siège social est situé 16 rue Paul Bert, 92400 Courbevoie - FRANCE, immatriculée auprès du Registre du Commerce et des Sociétés de PARIS sous le numéro 794602201.

In accordance with the provisions of Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, our company has been the subject of a declaration to the CNIL (National Commission for Data Protection and Freedoms), registration number: 1560281.

In addition to our mailing address, you also have the option to contact us using this contact email: pkrstan@gmail.com

If you agree to transmit your personal data to receive offers from the partners identified on the page at the time of collection, the data controllers are each of the partners indicated at the time of the action.

In any event, S GOBERT cannot be held responsible for processing carried out by these partners. For this reason, we invite you to review their respective privacy policies.

A.3 — Processing purposes and legal basis

A.3.1) The personal data you voluntarily provide to us is collected and may be processed for the following purposes:

  • Management of the data subject's participation in the contest: the processing of this data is necessary to take your participation into account, to conduct the contest, to determine the winner and process the winnings, in particular to inform the winner and send the prize, to manage requests for the exercise of rights of the data subject, and for the purpose of complying with our legal and regulatory obligations.
  • Implementation of advertising campaigns by third-party companies, studies and surveys by S GOBERT company: for this purpose, the data of the persons concerned must be subject to normalization, deduplication, filtering and verification operations. Third-party advertising will be sent by S GOBERT company. You can stop our solicitations at any time by unsubscribing from our communications or by contacting us. This processing is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with applicable regulations, your participation in the game is not conditioned on accepting commercial offers.
  • Implementation of advertising campaigns by third-party companies, studies and surveys by our monetization partners on behalf of S GOBERT : for this purpose, the data of the persons concerned must be subject to normalization, deduplication, filtering and verification operations. Third-party advertising will be sent by our monetization partners on behalf of S GOBERT. These monetization partners cannot in any way freely use your data (They are not owners of your data). A contractual relationship requires them to use your data only on behalf of our company and to destroy it if we request it. You may at any time stop their solicitation by unsubscribing from their communications or by contacting us. This processing is optional and only applies if you expressly agree to receive commercial offers from S GOBERT. In accordance with applicable regulations, your participation in the game is not conditional on accepting commercial offers.
  • Transmission of data to game sponsors for the purpose of carrying out commercial solicitation operations in various business sectors : for this purpose, the data of the persons concerned will necessarily be subject to normalization, deduplication, filtering, verification operations and may be used for targeting and analysis functionalities. Advertising will be sent by third-party companies. This processing is optional and only applies if you expressly agree to receive offers from sponsors and for your data to be transmitted to them. In accordance with applicable regulations, your participation in the game is not conditional on accepting commercial offers.

Advertising campaigns sent by both S GOBERT and third-party companies may be carried out through the following channels: email, postal mail, telephone calls, SMS and/or MMS messages, Web Push or any similar means of communication.

  • Management of requests for access, rectification, erasure, objection, and data portability rights.
  • Justification in case of dispute and compliance with our legal and regulatory obligations.

A.3.2) The justification for processing your data regarding the purposes listed in Article A.3.1 is based on:

  • For managing the participation in the contest of the data subject: the performance of the contract for the distribution of prizes and gifts following the draws we organize.
  • For the implementation of advertising campaigns by third-party companies and studies and surveys by S GOBERT company: the consent of the person concerned.
  • For the transmission of data to third-party companies for the purpose of carrying out advertising actions: the consent of the person concerned.

By this Privacy Policy, you are informed of the terms and conditions for processing your personal data. You can express your prior and express consent to the collection and processing of your personal data by S GOBERT company on the Site, in compliance with the provisions of the GDPR.

B — Duration of data retention

All personal data collected is retained for a limited period depending on the purpose of processing and only for the duration provided by applicable legislation.

Personal data collected to participate in the game will be kept for the duration of the game and after the expiration of the game, for the time necessary for the designation of the winner, the management of prizes and any claims, for a maximum total period of three years. At the end of this period, the data is destroyed in accordance with the measures prescribed by applicable legislation.

The data of the persons concerned will be kept for the purposes of our commercial actions and prospecting for which the data was collected until your request for cancellation, limitation or deletion, and within the limit of three years from their collection by the data controller or from the last contact from the prospect. At the end of this period, the data is destroyed in accordance with the measures prescribed by applicable legislation.

C — Recipients of personal data

S GOBERT company takes care to protect and secure the personal data you have agreed to communicate to us in order to prevent it from being disclosed to unauthorized third parties. However, if we are legally required to do so or if a court decision requires it, we will communicate your data to the extent necessary to comply with that law or court decision.

The personal data collected may be communicated to authorized personnel of S GOBERT company, its business partners, if you have given your express consent, or its ancillary service providers, in the context of the performance of all or part of the services.

The data collected may, where applicable, be transmitted to subcontracting companies to which the data controller may call upon in the context of the performance of services. The data controller ensures compliance with data protection requirements for all its subcontracting companies.

D — Data Security and Confidentiality

We implement organizational and technical security measures designed to guarantee the confidentiality and integrity of your personal data. To this end, administrative, organizational, technical, and physical precautions are intended to protect your personal data from loss, theft, misuse, unauthorized access, unauthorized transmission, any undue modification, or destruction.

In all cases, the data controller will take security measures appropriate to the nature of the data collected.

The data collected is stored confidentially and protected at a very high level of security. The servers where this data is stored comply with current security standards. They are protected against digital and physical attacks.

However, despite all our efforts, we cannot guarantee the infallibility of this protection due to unavoidable risks that may occur during the transmission of personal data.

E — Rights of persons concerned

Under applicable law, you have the following rights concerning your personal data, where applicable:

  • Right of access, rectification, deletion of your personal data;
  • Right to data portability concerning you;
  • Right to object to processing justified by a legitimate interest, or to prospecting;
  • Right to limit the processing of data concerning you;
  • Right to unsubscribe from our company and/or our partners;
  • Right to communicate your directives regarding the fate of personal data concerning you in the event of death.
  • Right not to be subject to a decision based solely on automated processing, including profiling, producing legal effects concerning you or affecting you in a significant manner in a similar way.

Vous pouvez exercer vos différents droits en nous contactant : S GOBERT, EURL au capital de 15 000 euros, dont le siège social est situé 16 rue Paul Bert, 92400 Courbevoie - FRANCE. Veuillez noter que nous pouvons vous demander une preuve d’identité et que nous nous réservons le droit d’exiger le paiement de « frais raisonnables » liés aux coûts administratifs supportés pour fournir les informations si votre demande est manifestement infondée ou excessive. Nous nous efforcerons de répondre à vos demandes dans les délais requis. Parallèlement à notre adresse postale, vous avez également la possibilité de nous joindre en utilisant cet e-mail de contact : pkrstan@gmail.com

F — Transfer of data outside the European Union

Your personal data is stored by us within the European Union.

Some of S GOBERT's partners are located outside the European Union. In this case, however, it is possible to carry out a secure data transfer in accordance with European data protection regulations.

We ensure that your personal data is effectively protected. Thus, all transfers are made to recipients located:

  • to countries that present, according to the criteria established by the European Commission, an adequate level of personal data protection;
  • to countries that do not offer adequate protection but to which the transfer is governed by standard contractual clauses issued by the European Commission or by the adoption of binding corporate rules;
  • in the United States, provided that these recipients meet the conditions set by the Privacy Shield established by the U.S. Department of Commerce.

G — Cookies

On our web pages, we use what are called cookies. These are small text files placed on your hard drive by the website visited, allowing it to record and store certain information about your computer and about you.

By browsing the Site, you consent to cookies as described below being placed on your terminal, subject to any choices you have made in accordance with this Cookie Management Charter.

G.1 — Definition of cookies

Cookies are small text files, generally composed of letters and numbers, placed on the device you use (computer, tablet, smartphone, etc.) when you visit a website.

They allow the website thus consulted to control, store and retrieve information about your browsing habits as well as to obtain technical communications on the navigability of the site. In this way, cookies allow us to provide you with personalized services and to improve the functionality, user-friendliness and accessibility of the relevant web pages.

G.2 — Types and purposes of cookies

Depending on their status and purposes, there are different types of cookies listed below. These concern our contest sites as applicable and/or our email communications.

  • Technical cookies and functionality cookies: These cookies are necessary for the operation of our Site and essential to allow you to navigate and use the features of our Site, such as access to secure areas. These are mainly session cookies or login cookies.
  • Analytical or audience measurement cookies : These are mainly cookies related to visits to the Site, cookies that analyze the origin of the visit, Site performance cookies and statistical or analytical cookies. These cookies allow us to recognize and count the number of visitors and sources of traffic in order to measure and improve the performance of our Site. They help us understand why you may encounter difficulties or receive error messages on certain pages, if applicable; to determine which pages are most and least visited; to analyze visitor navigation on the Site; to adapt and improve our Site to make it more useful and intuitive; and overall, to improve the user experience.
  • Social media sharing cookies: These cookies are necessary to manage external social networks (examples: Facebook, Twitter, Pinterest, etc.). Their function is to control the interaction of internet users with social widgets within a web page. Indeed, our Site may contain buttons linked to social networks allowing you to share Site content or express your opinion (e.g., "like", "retweet", etc...). If you are logged into the social network while browsing our Site, your browser establishes a connection between the network and the Site. If you click on a social network button placed on the Site, plug-ins (small software programs) transmit the corresponding information to the social network, which publishes it on your account. If you want to avoid any connection between a social network and the Site, you must log out of the social network before browsing our Site. These cookies are placed directly by social networks. Thus, user choices regarding the placement of these cookies must also be made with the social networks. For this purpose, S GOBERT invites users to consult directly the websites of social networks and their personal data protection policy.
  • Behavioral advertising cookies : These cookies collect information about your browsing habits in order to identify your preferences and specific interests. They serve to identify the user profile in order to display targeted advertisements in real time based on your interests, via our email sending programs and those of our partners where applicable and on other websites you visit and on which our partner has placed the same cookies. These cookies thus allow you to personalize the content of advertising according to your preferences. They may come from our partners as well as third parties and may be placed either by browsing the Site or by consulting our emails. The objective is to present you with the most relevant possible advertisements, close to your interests. For this purpose, cookie technology makes it possible to determine which advertisement to display on a terminal, based on recent browsing on one or more websites.
  • Partner marketing cookies: Marketing cookies are held by partners and used to provide you with targeted advertisements and offers throughout your online experience (web, email, applications, etc.). These cookies can be placed either by browsing the Site or by viewing our emails. Cookies may be included in the advertising spaces on our Site. These advertising spaces display advertising content from advertisers on your device. These advertising spaces contribute to the financing of the content and services we provide to you. The issuance and use of cookies by third parties are subject to the privacy policies of these third parties. We inform you of the cookies we are aware of and the means available to you to make choices regarding cookies.

G.3 — Use of cookies on this Site

S GOBERT company uses its own cookies, as well as those issued by third parties, for the purposes of continuing and improving the Site's activity and, where applicable, its email sends. Cookie placement may occur when browsing our Site or following the opening of emails.

  • Google Analytics : S GOBERT uses Google Analytics (third-party cookies) on the Site. This is an analytics service provided by Google, Inc. Through Google Analytics, S GOBERT analyzes your interaction with the Site, tracks your activity on it, and collects data on your browsing habits to allow S GOBERT to measure the Site's performance. You can manage and block the processing of your personal data through Google Analytics by configuring the browser used to access the Site. For more information about Google Analytics, click here: https://support.google.com/analytics/answer/3455585?hl=en. Furthermore, you can disable Google Analytics. To do this, you must install an opt-out option. For more information about this opt-out option, click here: https://tools.google.com/dlpage/gaoptout.

G.4 — Cookie Settings on this Site

You can freely choose at any time to express and modify your preferences regarding cookies, by the means described in this Privacy Policy.

If you refuse the storage of cookies in your terminal or if you delete those stored there, you may no longer be able to benefit from a number of features that may nevertheless be necessary to navigate certain sections of our Site. This would be the case if you attempted to access our content or services that require you to identify yourself. This would also be the case when we and/or our service providers and/or partners could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the internet.

To manage cookie activity, block them, or delete them, you simply need to manage the settings of the browser used to access the Site. Otherwise, browsing the Site implies your acceptance of cookie use, in accordance with what is indicated in this Cookie Management Charter. Each browser's configuration is different. We indicate below how to configure the main browsers. For information purposes, and without being able to guarantee proper operation, you can find instructions for different browsers at the following (temporary or permanent) addresses:

PC Browsers:

Browsers on mobile devices:

You can also visit the Youronlinechoices website, offered by digital advertising professionals, grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France to modify the activity of your cookies, block them or delete them. This site offers you a cookie management platform shared by hundreds of professionals, allowing you to accept or refuse their cookies in their entirety or on a case-by-case basis. Youronlinechoices is accessible via the link: Youronlinechoices

G.5 — Duration of cookie retention

In any event, cookies stored in your terminal or any other element used to identify you for statistical or audience purposes will have a reasonable lifespan for the purpose of the intended processing, limited to a maximum of thirteen (13) months, this duration not being automatically extended upon your subsequent visits to the Site. Beyond that, raw traffic data associated with an identifier are either deleted or anonymized.

G.6 — Additional information about cookies

For more information about cookies and how they work, visit the following page: https://www.allaboutcookies.org/. You can also consult the page dedicated to cookies on the website of the CNIL (National Commission for Data Protection and Liberties) via the following link: https://www.cnil.fr/vos-droits/vos-traces/les-cookies/

H — Links to other websites and services

It is specified that certain links in the game allow access to third-party sites and give you access to third-party services (such as social networks).

We have no control over how third-party sites and services process your personal information. We do not verify third-party sites and services, and we are not responsible for these third-party sites and services or their privacy practices. We invite you to refer to the privacy policies or privacy statements of third-party sites or services that you access from our sites or services.

Our privacy policy only concerns information collected on our website. As such, S GOBERT company cannot be held responsible for the use of your data on these other websites.

I — Bloctel

When participating in the contest, if you authorize S GOBERT or its partners to call you by telephone, this means you accept receiving offers from them or their partners.

We inform you of the existence of the "Bloctel" telephone marketing opt-out list, on which you can register here: https://conso.bloctel.fr/

J — Modification of the privacy policy

This Privacy Policy may be updated at any time, in particular in application of changes to applicable laws and regulations. We therefore invite you to regularly review the updates.