Article 1: Scope
Mouratoglou International (MI), as data controller, is committed to protecting the privacy of Users in accordance with the applicable legal requirements and in particular Regulation no. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “General Data Protection Regulation” or “GDPR”) and Act no. 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties (hereinafter “Data Protection Act”) (together referred to as “Applicable Regulation”).
Thus, one of the objectives of the Policy is to inform Users as well as possible regarding the way MI processes and protects their personal data, collected by MI as part of the provision of the Website and Services to Users.
Article 3 – Data collected by MTA
3.1. The data provided by the Users to MI
MI processes the data provided by the User via the Website and/or via the contact form, in particular during the following operations:
- when the User contacts the customer service or any other MI contact point.
In this context, MI may in particular be required to collect and process the following categories of personal data concerning the User :
- identity: first name, last name,
- contact details: phone number, email address;
- the User’s credentials: username and password;
- any other information directly and voluntarily provided by the User and/or Participant and in particular the content of emails or messages sent.
3.2. Data collected through cookies
3.2.1. What is a cookie?
Cookies are small files that are stored on the User’s computer or on any communication device used by the User (phone, tablets) when browsing the Website. These files allow the exchange of status information between the Website and the User’s browser. This data is likely to reveal the type of browser used, the date and time of the visit, the IP address as well as the activities carried out on the Website. This data enables MI to remember the User throughout his successive uses of the Website and to record his browsing path:
(i) in order to improve the security, the quality of the Services and the Website navigation;
(iii) for audience measurement, analysis and statistical purposes;
(iv) in order to send and display targeted advertisements.
3.2.2. What kind of cookies are used on the Website?
MI uses the following categories of cookies on its Website:
- Strictly necessary cookies:
These cookies are essential in order to enable you to browse the Website and use its features. These cookies also remember the choices you made such as, for example, the country from which you visited our Website. They can thus be used in order to offer you an experience more adapted to your choices and to make your visits more pleasant and personalized (in particular regarding the display of Website pages adapted to your device).
For this type of cookies, your consent is not required.
- Audience measurement cookies
The Website also uses Google Analytics to monitor the performance of the Website and enable MI to optimize your online experience. These cookies collect information on how Users use the Website in order to gather information such as the frequency of Users’ visits on the Website, the pages they consult and the other websites they visited before coming on the Website. The information obtained through Google Analytics is used for the sole purpose of improving the Website and Services offered. If you do not want Google Analytics to track your activities on all websites, please visit the following website: http://tools.google.com/dlpage/gaoptout.
3.2.3. How do I set up the cookie deposit?
The prior consent of the User is required before any reading or deposit of cookies that are not strictly necessary for the operation of the Website, namely on this Website to cookies for audience measurement.
In accordance with the recommendation of the CNIL on the subject, MI collects the User’s consent by means of a platform accessible during his first browsing on the Website and at any time thanks to a blue button entitled “Confidentiality” appearing at the bottom right of all the pages of the Website.
This platform allows the user to:
- accept directly the deposit of all kind of cookies; or
- directly refuse the deposit of all kind of cookies requiring consent; or
- choose in a granular manner the purposes of the cookies for which the User wishes to give or refuse consent; and/or
Article 4 – Use of User and Participant data
As data controller, MI collects the personal data of Users in a lawful and fair manner and with respect for their rights.
The information collected by MI, including personal data, shall be used for the following purposes:
- To manage the Website and its operational features (including logistics), solve any technical problem, improve and develop new features according to the use and/or the feedbacks and requests of the Users;
- To carry out statistical analysis;
- To answer the requests from Users and communicate with them;
- To enforce applicable laws, regulations and Terms.
MI may also use the User’s personal data in order to send the User commercial prospecting messages (in particular sending information related to the launch of new services, the organization of promotional events and marketing activities of any kind). The User may explicitly and freely consent or not to the collection and processing of his personal data for marketing purposes by means of a checkbox.
Finally, the User benefits from the possibility of having his phone details recorded on the Bloctel opposition list managed by Opposetel. Bloctel is the phone canvassing opposition list on which any consumer can register free of charge in order to no longer be canvassed over the phone by a professional with whom he has no current contractual relationship.
You can find all information regarding the steps to be taken to register on this list via the following link: https://conso.bloctel.fr/
Article 6 – Users’ rights regarding their personal data
In accordance with the Applicable Regulation, the User and Participant have the following rights regarding their personal data:
right to be informed: you have the right to obtain clear, transparent, understandable and easily accessible information on how we use your personal data and on your rights. That is why we are providing you with the information contained in this Policy.
right of access: you have the right to access and obtain a copy of the personal data we have about you (provided that the request is not manifestly unfounded or excessive, in particular due to its repetitive nature). If you wish to access the data we hold concerning you, please contact us at the contact details below.
right to rectification: you have the right to obtain the rectification of your personal data when inaccurate or out of date and/or that they be completed if they are incomplete (provided that the request is not manifestly unfounded or excessive, in particular because of its repetitive nature). If you wish to modify your personal data, please contact us at the contact details below.
right to erasure: in certain cases, you shall have the right to obtain the erasure of your personal data. This is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons. If you want us to erase your data, please contact us at the contact details below.
right to restriction of processing: This right means that the processing of your data by us is limited, so that we can store this data, but we cannot use or process it. This right applies in special circumstances, as follows:
- In cases where the accuracy of personal data is contested by the data subject (i.e. you). The processing is then limited for a period of time allowing MI to verify the accuracy of the personal data;
- In cases where the processing is unlawful and the data subject (i.e. you) opposes the erasure of the personal data and requests the restriction of their use instead;
- In cases where MI no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
- In cases where the data subject (i.e. you) has objected to processing based on the legitimate interests pursued by MI pending the verification whether the legitimate grounds pursued by MI override those of the data subject.
If you wish to obtain the restriction of processing, please contact us at the contact details indicated in point 9 below
right to object to commercial prospecting: you may, at any time, unsubscribe or object to receiving commercial prospecting messages from MI. Simply click on the link in the footer of the communications you receive from MI or send a message to the contact details below. However, it is specified that MI will continue to send certain electronic communications, in particular communications transmitting invoices.
right to send us special instructions concerning the fate of your personal data after your death.
right to lodge a complaint with a supervisory authority: you have the right to seize and lodge a complaint with the data protection authority of your country (in France it is the Commission Nationale de l’Information et des Libertés) to challenge MI’s practices with regard to the protection of personal data and privacy. We nevertheless encourage you to contact us at the contact details below before lodging any complaint with the competent data protection authority.
To exercise all of these rights, you may send a request to the following address email@example.com.
Article 7 – Update of personal data
The User undertakes to:
- provide accurate, complete and unambiguous personal data;
- ensure, as far as necessary, the update of personal data concerning him and the Participant;
- provide accurate, complete and unambiguous personal data concerning the User after having obtained the consent of the User for the transmission of the data to MI;
Article 8 – Communication of Users’ personal data
MI undertakes to store all personal data collected and to share it only under certain circumstances and in accordance with the provisions of the Applicable Regulation.
- The communication of personal data of the Users and Participants to MTA employees:
Some of the personal data of Users and Participants are accessible to MI’s employees if these persons need to have access to this data in order to carry out the mentioned purposes, i.e. to provide the Users with the Services in an appropriate manner. MI’s internal departments that may have access to the personal data of the Users are in particular the IT department, the technical support service, the marketing/commercial service and the coaches.
- The communication of the personal data of the Users to third party service providers:
In particular, MTA may grant access to the personal data of the Users to third party service providers, acting as subcontractors, for the performance of services relating to the Website and in particular hosting, storage, analysis, marketing, communication, data processing, database management or computer maintenance services. These service providers shall only act upon the instructions of MI and shall only have access to the personal data of the Users in order to perform these services and shall be bound by the same obligations of security and confidentiality as MI.
In addition, the personal data of the User and Participant may be shared with third parties for the following reasons:
- in the context of a merger, acquisition or sale of all or part of the company’s assets, of which the User acknowledges having been informed;
- following judicial or administrative proceedings of any kind or law enforcement measures requested by the competent authorities;
- to comply with legal obligations, to protect the rights and/or safety of an individual, to protect the rights and property of MI, including the need for these Terms and Conditions to be complied with and to prevent fraud, security or technical problems.
- as part of a joint operation with third parties. Where appropriate, the sharing of information with these partners as well as the name of the partner(s) will be explicitly mentioned.
Article 9 – Storage of the Users’ personal data
The personal data collected by MI is stored on the servers of a service provider located in the European Economic Area.
MI requires this provider to take, in accordance with the Applicable Regulation, all organizational and technical measures to ensure an adequate level of protection of the Users’ personal data.
MTA stores personal data for a different period of time depending on the situation:
- if you are not a client of MI on the Website: for a duration of 3 years from your last contact with MI
Article 10 – Security and protection of the personal data of the Users and Participants
The security of personal data is one of the priorities of MI. MI undertakes to take all reasonable organizational and technical measures to prevent any disclosure, use, alteration, accidental loss or destruction of the personal data of a User.
MI may update this Policy at any time to reflect new practices and Service offerings. In this case, the date of the Policy will be updated to indicate the day on which the changes were made. It is the responsibility of the Users to check for any updates made to this Policy that are posted on the Website. If MI makes significant changes, the Users will be notified by means of an email.
Article 12 – Links to third party mobile applications and/or websites
Article 13 – Contact MI
In general, if the User and/or Participant have any questions or comments regarding this Policy, or about MI’s use of their data, they can contact MTA at the following address: firstname.lastname@example.org.
As data protection is an important issue these days, MI has chosen to voluntarily appoint a Data Protection Officer. The latter can be reached at the following address: