Privacy policy
1. Preamble
The General Data Protection Regulation (hereinafter the “GDPR”) of May 25, 2018 on the protection of individuals with regard to the processing of personal data and on the free movement of such data sets out the legal framework applicable to the processing of personal data.
The RGPD strengthens the rights and obligations of data controllers, processors, data subjects and data recipients. In the interests of transparency, DayParGolf has defined this policy to enable you to find out more about: the origin and purpose of information processed when you browse the DayParGolf website (hereinafter referred to as the “Site”) and any other possible exchange of information.
Your rights regarding cookies and other tracking devices used by DayParGolf
Within the framework of its activity, DayParGolf implements a processing of personal data gathering the data of its customers and contacts. For a better understanding of the present policy, it is specified that :
- “customer(s)” refers to any individual or legal entity who is a customer of DayParGolf.
- “contact(s)”: refers to any individual or legal entity who has a relationship with DayParGolf but is not a customer (prospects, relations, partners, etc.);
- “Data controller” means the natural or legal person who determines the purposes and means of processing personal data. For the purposes of this policy, the data controller is DayParGolf.
- “processor”: refers to any natural or legal person who processes personal data on behalf of the controller. In practice, this means the service providers with whom DayParGolf works and who handle the personal data it processes;
- “Data subjects”: refers to persons who can be identified, directly or indirectly. They are referred to herein as “customer” or “contact”;
- “recipients” refers to the natural or legal persons who receive personal data. Data recipients may therefore be both internal recipients and external bodies (support service providers, the Judicial Administration and its auxiliaries, professional bodies, etc.).
The RGPD requires that data subjects be informed of their rights in a concise, transparent, comprehensible and easily accessible manner.
2. Object
In order to meet its needs, DayParGolf implements and operates the processing of personal data relating to its customers and contacts.
The purpose of this policy is to meet DayParGolf’s obligation to provide information and to formalize the rights and obligations of its customers and contacts with regard to the processing of their personal data.
3. Scope
The present personal data protection policy applies to the processing of personal data of DayParGolf’s customers and contacts. This policy applies only to data processing for which DayParGolf is responsible and to data described as “structured”. Similarly, the policy does not cover processing carried out by DayParGolf employees in the treatment of their personal customers. The processing of personal data may be managed directly by DayParGolf or through a subcontractor specifically appointed by DayParGolf. This policy is independent of any other document that may apply within the contractual relationship between DayParGolf and its customers and contacts, in particular our general terms of business or our cookies policy.
4. General principles and commitment
No processing is carried out by DayParGolf concerning customer and contact data if it does not relate to personal data collected by or for our services or processed in connection with our services and if it does not comply with the general principles of the GDPR. Any new processing, modification or deletion of existing processing will be brought to the attention of customers and contacts by means of an amendment to this policy.
5. Types of data collected
NON-TECHNICAL DATA (DEPENDING ON USE)
Identification: surname, first name, title, job title, pseudonym, social network pseudonym
Contact details: telephone, e-mail address, postal address, fax, etc.
Photo and video when you grant us this right
Professional life
Personal life (family or property) when necessary for the processing of a file
Bank details if required
NON-TECHNICAL DATA (DEPENDING ON USE) IN THE FORM OF COOKIES OR OTHER TRACERS
Identification data (IP)
Connection data (logs in particular)
Consent (click) data, mainly for online subscriptions (newsletter)
WHAT ARE COOKIES?
During their period of validity (367 days maximum), cookies enable us to store status information when a browser accesses different pages on a website, or when the browser returns to the site at a later date. Only the sender of a cookie can read or modify the information it contains. There are different types of cookies:
- session cookies, which disappear as soon as you leave the browser or site
- permanent cookies, which remain on your terminal until their lifetime expires, or until you delete them using your browser’s functions.
The installation of certain cookies is subject to your consent. When you first visit the DayParGolf website, an information banner appears at the bottom of the screen inviting you to give your consent to the use of cookies or other similar tracers. If you consent to this in accordance with the General Data Protection Regulation (GDPR), however, you may revoke your choice at any time.
HOW TO DEACTIVATE COOKIES?
You have several options for deleting cookies and other trackers.
BROWSER SETTINGS
The recording of a cookie in your terminal is essentially subject to your wishes, which you can express and modify at any time and free of charge through the choices offered to you by your browser software. While most browsers are set to accept cookies by default, you can choose to accept all cookies or reject them systematically, or choose which cookies you accept depending on who is sending them. You can also set your browser to accept or reject cookies on a case-by-case basis, prior to their installation.
You can also regularly delete cookies from your terminal via your browser. Don’t forget to configure all the browsers on your various terminals (tablets, smartphones, computers, etc.). To manage cookies and your choices, the configuration of each browser is different. It is described in your browser’s help menu, which will tell you how to modify your cookie preferences. By way of example:
To take full advantage of the Site’s functionalities, the activation of cookies is required. If your browser is configured to refuse all cookies, this may prevent the use of some of our services, for which DayParGolf cannot be held responsible. In order to manage cookies in the way that best suits your needs, we invite you to configure your browser according to the purpose of the cookies.
PUBLISHER OPT-OUT MODULES
You can choose to deactivate Google Analytics cookies directly by going to the following page. For more practical information on cookie management, we recommend that you consult the website of the Commission Nationale Informatique et Libertés, and in particular the page “Maitriser mes données”. DayParGolf does not process sensitive data, apart from data necessary “for the establishment, exercise or defense of legal claims or whenever courts act in their judicial capacity” [Article 9 of the RGPD].
6. Data sources
DayParGolf collects customer and contact data from :
- data supplied by the customer as part of a file entrusted to DayParGolf (customer file);
- business cards ;
- electronic forms filled in by the customer (attendance sheet, post-conference satisfaction form);
- registration or subscription to our online services (website, social networks, etc.);
- registration for events organized by DayParGolf;
- lists provided by the organizers of events or conferences in which we participate;
- Visitor statistics via Google Analytics;
Exceptionally, we may rent databases.
7. Purpose of processing
Depending on the case, DayParGolf processes your data for the following purposes:
- processing of files entrusted to DayParGolf ;
- customer relationship management (CRM);
- management of events organized by DayParGolf (conferences, breakfasts, etc.);
- sending out our newsletters;
- answering questions put to us (by telephone or online);
- responding to public or private invitations to tender;
- sending out our greetings and other events;
- improving our services;
- fulfilling our administrative obligations;
- compiling statistics.
8. Legal basis
The purposes of processing presented above are based on the following conditions of lawfulness: Customers : Pre-contractual or contractual performance Contacts: Legitimate interest and, where required by law, consent.
9. Recipients of data
DayParGolf ensures that data is only accessible to internal recipients.
10. Shelf life
The duration of data retention is defined by DayParGolf with regard to legal and contractual constraints. It is set out in our retention policy. Once the time limits set out in the aforementioned policy have elapsed, data is either deleted or kept after being anonymized, notably for statistical purposes. Customers and contacts are reminded that deletion or anonymization are irreversible operations and that DayParGolf is no longer able to restore them.
11. Right of access (right to copy)
Customers and contacts traditionally have the right to request confirmation from DayParGolf as to whether or not data relating to them is being processed. Customers and contacts also have a right of access. Requests must be made in writing to the following address:
C2A INNOV – 106 Route de Roanne – 42460 VILLERS
or via the contact form on our website. Customers and contacts have the right to request a copy of their personal data being processed from DayParGolf. If customers and contacts submit their request for a copy of the data electronically, the information requested will be provided in a commonly used electronic form, unless otherwise requested. The right of access must not be exercised in an abusive manner, i.e. on a regular basis with the sole aim of destabilizing DayParGolf.
12. Update and correction
This right may be exercised by contacting your usual contact, or by contacting DayParGolf’s Communications Department. In order to regularly update the personal data collected by DayParGolf, DayParGolf may contact customers and contacts who are able to satisfy its requests. DayParGolf. will not be held responsible if the customer or contact does not update their data.
13. Right to erasure
Customers’ and contacts’ right to erasure will not apply in cases where processing is carried out to meet a legal obligation. Apart from this situation, customers and contacts may request the deletion of their data in the following limited cases:
- when personal data is no longer required for the purposes for which it was collected or otherwise processed;
- when the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
- when the data subject objects to processing that is necessary for the purposes of the legitimate interests pursued by DayParGolf and there is no compelling legitimate reason for the processing;
- if the data subject objects to processing of his or her personal data for marketing purposes, including profiling;
- when personal data has been processed unlawfully.
14. Right to limitation
Customers and contacts are informed that this right is not intended to apply insofar as the processing carried out by DayParGolf is lawful and all personal data collected is necessary for the performance of the commercial contract.
15. Justification
With regard to all the above-mentioned rights of the customer or contact, and in accordance with the legislation on the protection of personal data, you are informed that these are rights of an individual nature which can only be exercised by the person concerned in relation to his/her own information. To fulfill this obligation, we will verify the identity of the person concerned.
16. Optional or compulsory answers
Customers and contacts are informed on each personal data collection form of the compulsory or optional nature of the answers by the presence of an asterisk. Where answers are mandatory, DayParGolf explains to customers and contacts the consequences of not answering.
17. Right of use
Customers and contacts grant DayParGolf the right to use and process their personal data for the purposes described above. However, enriched data resulting from DayParGolf’s processing and analysis work, otherwise known as enriched data, remains DayParGolf’s exclusive property (usage analysis, statistics, etc.).
18. Subcontracting
DayParGolf informs its customers and contacts that it may involve any subcontractor of its choice in the processing of their personal data (e.g. Google Analytics). In this case, DayParGolf ensures that the subcontractor complies with its obligations under the RGPD.
19. Data breach
In the event of a personal data breach, DayParGolf undertakes to notify the Cnil under the conditions prescribed by the RGPD. If said breach poses a high risk to customers and contacts and the data has not been protected, DayParGolf:
- will notify the customers and contacts concerned;
- will provide the customers and contacts concerned with the necessary information and recommendations.
