PRIVACY AND COOKIES POLICY

praxinos.coop

Effective 01/08/2023

Pursuant to Regulation (EU) No. 2016/679 of April 27, 2016, known as the "RGPD", which came into force on May 25, 2018, and the French Data Protection Act (Loi Informatique et Libertés), amended several times, PRAXINOS, a limited liability cooperative company with variable capital (minimum €7,000), located at 7 Avenue de Blida in METZ (57000) France, registered in the METZ Trade and Companies Register under number 843 876 764 (hereinafter referred to as "the data controller" or "we"), acting in its capacity as data controller, ensures the protection of personal data collected from individuals, users of the praxinos.coop website (hereinafter referred to as the "Site") in accordance with the General Terms and Conditions of Use available on the Site (hereinafter referred to as "You").

ARTICLE 1. PURPOSE OF THE POLICY

In order to ensure respect for your privacy and the protection of your personal data (hereinafter referred to as the "Data"), this privacy policy informs you about the processing and destination of your Data in the context of the use of the Site (hereinafter referred to as the "Privacy Policy").

This Privacy Policy informs you of the origin and use of the information collected, as well as the rights and options available to you in application of the applicable legislation on the protection of personal data. The Privacy Policy is therefore important to You and We invite You to read it carefully.

To find out how we use cookies on our Site, please consult article 9 of this Privacy Policy.

This Privacy Policy applies in addition to the provisions of the General Terms and Conditions of Use of the Site, as well as the General Terms and Conditions of Sale accessible directly from the bottom banner of our Site. All terms written with a capital letter as the first letter have the meaning given to them in the General Conditions of Use of the Site and/or in the General Conditions of Sale.

ARTICLE 2. MODIFICATION OF THE PRIVACY POLICY

We may modify the Privacy Policy in accordance with the legal and regulatory context, as well as to keep you informed of changes in our practices with regard to the processing of personal data and cookies. We therefore advise you to ensure that you are always aware of the most recent version of the Privacy Policy whenever you interact with Us by consulting this section or by clicking on the "Privacy Policy" link in the bottom banner of our Site. In particular, when ordering paid Content and/or Services, we invite you to read the most recent version of this Privacy Policy.

ARTICLE 3. OUR ROLE AND RESPONSIBILITY

Unless otherwise indicated in separate information notes / notices relating to certain specific personal data processing operations, the personal data processing operations described in this Privacy Policy are implemented by our company, above named, publishing the Site; thus having the quality of "Data Controller" within the meaning of Article 4 of the RGPD and applicable national legislation on the protection of personal data.

ARTICLE 4. CONTACT

If you have any questions and/or difficulties about the Privacy Policy and our personal data protection practices, please do not hesitate to contact us:

• by post: PRAXINOS company - 7 Avenue de Blida - METZ (57000)
• by e-mail at the following address: contact@praxinos.coop

In the event of a dispute concerning the way in which We collect and process your Data, you may lodge a complaint with the CNIL via the following link: https://www.cnil.fr/fr/plaintes/ or either, via postal mail to the following address: 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 - www.cnil.fr or, if you reside in another European Union country, with the supervisory authority in your place of habitual residence.

ARTICLE 5. CATEGORIES OF DATA WE PROCESS AND THEIR PURPOSE

This section aims to provide you with more information regarding the Data we collect, the purposes for which we process this Data, and the legal basis upon which each specific processing relies. We only process Data that we gather about you if there is a valid reason to do so, and we have a relevant legal basis.

It is specified that for all purposes based on our legitimate interests, we ensure in such cases to consider any potential impact that this processing may have on you. If we believe that your interests or fundamental rights and freedoms outweigh our legitimate interests, then we will not use your Data on this legal basis and may request your specific consent.

• Account Creation : We collect and process Data to allow you to create and access your Account on the Site. To manage your Account from its creation until its closure, you must provide certain information about yourself (particularly your first name, last name, country of residence, phone number, profile (and, depending on the profile, additional information such as school name or employer name and department), email, password, and password confirmation).

  • The legal basis for this processing is contractual. We need this Data to create and maintain your Account, enforce the Terms of Use, as well as any other applicable contractual terms (including the Terms of Sale).

• Online Purchases : We collect and process your Data to enable you to purchase Content and/or Services online and utilize the various services on our Site (including online payment service).

  • Payment Processing : We utilize third-party services for payment processing. We do not retain or collect data related to your payment card. This information is directly provided to our third-party payment processor, Stripe, whose use of your personal data is governed by its own Privacy Policy accessible here: https://stripe.com/privacy
  • Order Fulfillment : We process your contact and identification information, namely: name, first name, postal address, email(s), phone number(s).
  • Customer Transactions / Billing : We process the following Data: transaction number, purchase details, license activation code(s), date and amount of the order and invoice, terms and delivery address (if applicable).
  • Complaints / Customer Relations : We process the following Data: purchase history, requests for exercising legal or contractual guarantees, correspondence with the customer, and after-sales service.

  The legal basis for these processes is contractual. We need this Data to enforce the Terms of Sale. The legal basis for processes related to Customer Transactions / Billing is a legal obligation. We need this Data to comply with our accounting and tax obligations.

• Customer Reviews / Studies : We process the content of your reviews (as well as your potential pseudonym) spontaneously provided by you regarding Content and/or Services, as well as those provided in response to our solicitation as part of a study or satisfaction survey regarding the quality of our Content and/or Services.

  • The legal basis for these processes is our legitimate interest.

• Commercial Prospecting Actions towards Customers : We process Data such as your email address to send you commercial solicitations.

  • The legal basis is our legitimate interest for solicitations related to Content and/or Services similar to those you already benefit from.
  • The legal basis is your consent for all other solicitations.

• Commercial Prospecting Actions towards Prospects : We process Data such as your email address to send you commercial solicitations.

  • The legal basis is your consent for all solicitations.

• Connecting with Recruiters : We process Data such as your email address and specialties to connect you with recruiters.

  • The legal basis is your consent for this type of solicitation.

• Complaint Management and Exercise of Rights in this Privacy Policy : We collect and process Data such as your contact details and the content of your message (to the extent that it may contain Data about you or a third party), your identification document (for exercising rights in this Privacy Policy) when managing and tracking the questions and/or requests you submit to us.

  • The legal basis for these processes is our legitimate interest in responding to your requests and keeping a record of them.

• Site Management, Analysis of Site Usage, and Purposes outlined in the "Cookie Policy" : In this regard, we process and collect Data related to your connection device and browser, particularly your IP address (from which information about your country/state of location can be inferred), the type of device used, and browsing information.

  • More information in Article 9 of this Privacy Policy.

Some personal data that are essential for fulfilling the purposes described above may be indicated on different pages of our Site, typically with an asterisk. If you do not provide these mandatory fields, we may not be able to fully respond to your requests. Other information is optional and allows us to better understand you and improve our communications and services to you.

Outside of any interaction with the Site, certain Data are essential for fulfilling the purposes described above, and we reserve the right not to proceed with your requests if they are not provided.

During events we organize, we may process additional Data under conditions and for purposes specifically notified to you on that occasion.

ARTICLE 6. CONSERVATION DE VOS DONNEES

Purpose	Lifespan
Account Creation	Until your Account is closed. However, where required by applicable law, if we are required to retain any of your data beyond the date of closure of your Account, then the applicable maximum retention period will apply in accordance with the applicable statutory limitation periods (art. L.34-1 of the French Post and Electronic Communications Code).
Online shopping: Order payment	We use the services of third parties to process payments. We do not store or collect your payment card details. This information is provided directly to our payment service provider, Stripe, whose use of your personal data is governed by its own Privacy Policy, which can be accessed here: https://stripe.com/privacy
Online shopping: Order processing	Duration of the contractual relationship.
Online purchasing: customer transaction management and invoicing	15 months from the date of the activity concerned, plus any periods required to comply with our legal retention obligations (accounting obligations: 10 years; tax obligations: 6 years).
Online shopping: Complaints and Customer Relations	5 years from the last contact initiated by you.
Customer Opinion and Surveys: Spontaneous customer opinions	Period during which the Content / Service subject to a notice is still marketed or until the right of objection is exercised.
Customer Opinion and Surveys: Studies and satisfaction surveys	Duration necessary to achieve the objective of the study or satisfaction survey or until the right to object is exercised.
Commercial prospecting for customers: For solicitations relating to Content and Services similar to those you already enjoy.	3 years from the last contact initiated by us
Commercial prospecting for customers: For solicitations relating to Content and Services that are not similar to those you already enjoy.	Until consent is withdrawn or 3 years after the last contact initiated by us.
Sales prospecting for prospective customers	Until consent is withdrawn or 3 years after the last contact initiated by us.
Putting you in touch with ‍recruiters	Until consent is withdrawn or 3 years from last use of Account.
Handling complaints and exercising the rights provided for in this Policy: Handling complaints	3 years from the last contact initiated by you.
Handling claims and exercising rights under this Policy: Exercising rights under this Policy.	1 year from exercise of the rights concerned
Site management, analysis of Site usage and purposes set out in the "Cookies Policy" article: Analysis of Site usage	See article 9
Site management, analysis of Site usage and purposes set out in the "Cookies Policy" article: Cookies	See article 9

ARTICLE 7. RECIPIENTS OF YOUR DATA

Your Data is shared with third-party partners only when necessary for the purposes outlined in this Privacy Policy.

We engage trusted third-party partners and provide them with only the information they require. We ensure they do not use this information for other purposes. We take all measures to ensure that all these third-party partners maintain the confidentiality and security of your Data.

Sharing your Data with third-party partners serves the following purposes:

7.1. Site and Related Services Management

Data will only be transferred or made accessible to third parties under the following conditions:

• Our subcontractors and service providers, namely the hosting and maintenance provider of the Site (Network SA), email service providers, CRM tools;
• And in the event of any legal organizational restructuring, including total or partial asset transfer, merger, acquisition, split, and more generally any reorganization operation to ensure service continuity.

Whether integrated directly into the Site or not, these service providers and third-party partners collect and process your Data independently in accordance with their own relevant privacy policies and under their sole responsibility.

7.2. Complaint Management / Exercise of Your Rights under this Policy

Your Data is accessible to authorized individuals acting on our behalf who are in contact with you, as well as our customer relations teams.

7.3. Personalized Customer Management / Prospecting

Your Data is accessible to authorized individuals acting on our behalf for the management of the Site you are in contact with, as well as our customer relations teams. Through them, you may receive information about our offers, training, news, and events, as specified in Article 5.

7.4. Banking Transaction Management

Banking data processed for the purposes mentioned above must be shared with the payment service provider present on the Site to facilitate the transaction process. For more information, please refer to the information provided by Stripe, accessible here: https://stripe.com/privacy

7.5. Protection and Defense of Our Rights

We may disclose your Data to third parties when such disclosure is required by law, regulatory provision, or a court decision, or if such disclosure is necessary to protect and defend our rights (for example, to our external representatives and advisors in the case of debt collection).

7.6. Recruitment

We may share your Data with third-party recruiters (studios and educational institutions). Through them, you may receive job offers, as specified in Article 5. For more information about the processing of your Data by recruiters, please review their own privacy policy.

7.7. Outbound Links to Third-Party Websites

The Site may contain outbound links to third-party websites. We have no control over the content, privacy policy, or actions of these websites.

The use of information you may provide to third parties on other websites, or that these third parties may collect on other websites, is not governed by this Privacy Policy.

You should carefully review the privacy and personal data protection policy of third-party websites and contact the publishers of these sites if you have any questions about how they use information about you.

We cannot be held responsible for any third party that does not use information about you in accordance with the privacy policy of that third party or in accordance with any contractual or legal obligations to which that third party is subject.

ARTICLE 8. TRANSFER OF YOUR DATA OUTSIDE THE EUROPEAN UNION

Your personal data may be transferred outside the European Union. In such cases, we take necessary measures with our service providers/partners to ensure an adequate level of data protection, in accordance with the applicable regulations (Chapter V of the GDPR).

In this context, we ensure that your data receives a degree of protection similar to that applicable within the European Union, by implementing at least one of the following protective measures:

1. Your Data may be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (e.g., Switzerland, the United Kingdom, Japan...);
2. We may use the Standard Contractual Clauses approved by the European Commission.

If the provider and/or partner no longer meets these conditions, we commit not to transfer your Data to them.

ARTICLE 9. COOKIE POLICY

Our Site uses cookies and/or other tracking technologies as specified below.

9.1. Definitions of Cookies and Other Tracking Technologies

The term "cookies" refers to a small file stored by a server on your device (computer, phone, tablet...) and associated with a web domain (meaning, in most cases, all pages of the same website). This file is automatically sent back during subsequent interactions with the same domain.

It can, for example, include:

• HTTP cookies
• "Flash" cookies

Other tracking technologies may also be used. These may include:

• The result of calculating a unique fingerprint of your device in the case of "fingerprinting" (calculating a unique identifier of the device based on elements of its configuration for tracking purposes).
• Invisible pixels or "web bugs",
• Access to device information through APIs (LocalStorage, IndexedDB, advertising identifiers such as IDFA or Android ID, GPS access...),
• Any other identifier generated by software or an operating system (serial number, MAC address, unique device identifier (IDFV), or any set of data used to calculate a unique device fingerprint (for example, via a "fingerprinting" method).

In the context of this Privacy Policy, we will use the term "Cookies" to refer collectively to cookies and any other tracking technology deposited and/or read during the consultation of our Site, regardless of the type of device you are using: computer, smartphone, internet-connected digital tablet.

These Cookies have various uses, including:

• Tracking your navigation for statistical or advertising purposes;
• Enabling user interface personalization (language choice or service presentation);
• Enabling authentication for a service, including those aimed at securing the authentication mechanism, such as limiting attempts at robotized or unexpected access.

9.2. Prior consent

Your prior consent is required for the use of certain Cookies.

When you visit our Site for the first time and we intend to place a Cookie on your terminal:

1. You are informed by means of an information banner at the bottom of the page that is displayed; and
2. You are invited to accept, refuse or configure your choices regarding the use of these Cookies.

Insofar as your consent must be unambiguous, any action other than explicit acceptance (for example, closing the consent form) is considered as a refusal.

Some of these Cookies are exempt from consent when they meet the criteria set out in the guidelines on cookies and other identifiers, chapter 3.

However, we would like to inform you of their use and remind you that your browser settings may allow you to block them, with potentially negative effects for the operation of our Site.

9.3. Types of Cookies Used and Their Purposes

We may use the following types of cookies:  

• Functional Cookies : These enable us to enhance the functionality of our Site and make it more user-friendly for visitors. For example, we store your login data.

• Audience Measurement Cookies : These ensure that an anonymous cookie is generated each time you visit our Site. They help determine whether you have visited our Site before or not. A cookie is created only during the first visit, and subsequent visits automatically use the existing cookie. This cookie is used solely for statistical purposes. The following data can be collected:

  • Number of unique visitors
  • Frequency of user visits to our website
  • Pages visited by visitors
  • Duration of time users spend on a specific page
  • Page from which visitors exit our Site.

• Tracking Cookies :These analyze your browsing behavior, viewing habits, or consumption patterns on our Site in order to provide targeted advertisements or personalized services. The profile established based on this data is not linked to your name, address, email, etc., but is solely used to match advertisements to your profile for maximum relevance.

We obtain your consent for these cookies. They will not be installed without your consent.

• Third-Party Cookies : These allow tracking of the pages you visit on the internet to create your personal profile. This profile is not linked to your name, address, email, etc., as mentioned above, but is solely used to identify you as a unique visitor and tailor advertising content to your profile for maximum relevance.

We obtain your consent for these cookies. They will not be installed without your consent.

• Social Media Cookies : These enable social media platforms to record articles and pages you share using their share buttons. They may also include tracking cookies that monitor your internet browsing behavior.

We obtain your consent for these cookies. They will not be installed without your consent.

• Site Improvement Cookies : These allow testing of different versions of a web page to determine which version is better utilized. 

• Session Trackers : These store information about the ongoing session.

9.4. List of trackers used

Functional cookies:

PHPSESSID: Mandatory unique session identifier enabling the Site to store information relating to your session (referrer, referring page, etc). Retention: session.

Tarteaucitron: Manager of mandatory and optional services and service-related cookies. Memorises the User's choice as to whether or not to activate cookies. Retention period: 13 months.

Third-party cookies:

YouTube: cookies deposited directly by YouTube via Tarteaucitron when the User wishes to view videos hosted on this platform. Uses cookies GEUP (Contains information necessary for the operation of YouTube), PREF (Keeps the YouTube User's preferences), VISITOR_INFO1_LIVE (Contains information about the User but does not allow authentication) and YSC (Contains data to target advertising to Users). Retention period: 13 months.

9.5. Your rights with regard to personal data collected by Cookies

You have the right to access, rectify, limit and delete your Data in accordance with this Privacy Policy. In addition, you have the right to object to the processing of Data and the right to the portability of your Data.

In order to prevent abuse, we may ask you to identify yourself when exercising your rights.

When it comes to accessing Data linked to a Cookie, we may ask you to send us a copy of the Cookie in question, according to instructions that will be communicated to you by our technical teams.

ARTICLE 10. SECURITY

We have put in place the appropriate technical, organisational, software and physical measures to guarantee the confidentiality and security of your personal data against any loss, destruction, alteration, unauthorised access or disclosure. In particular:

• Our IT systems are subject to state-of-the-art physical and software protection. Physical and electronic backup procedures for data collected on the Site are implemented, in accordance with current French legislation and European regulations relating to the protection of personal data;

• Our employees who, by virtue of their position, have access to your Data are subject to confidentiality obligations;

• Our service providers and subcontractors are bound by written undertakings to implement sufficient security measures to ensure the protection of your Data in accordance with applicable legislation;

• We remind you that the Internet is not a completely secure environment and that, as such, we cannot guarantee the security of the transmission or storage of information on the Internet.

Article 11. YOUR RIGHTS

In accordance with the laws and regulations applicable to personal data, you have the following rights:

11.1. Access and Rectification

You have the right to access your Data and to request the rectification or deletion of Data that is found to be inaccurate.

11.2. Erasure

You can also request the erasure of Data concerning you when its retention is no longer necessary.

11.3. Objection

You can object to the processing of your Data or request its limitation, except when the processing is necessary for the performance of services.

11.4. Withdrawal of Consent

When the processing of your Data is based on your consent (and is the sole legal basis for the processing), you can withdraw this consent at any time.

11.5. Restriction

You have the right to obtain restriction of the processing of your Data in certain cases defined in Article 18 of the GDPR.

11.6. Data Portability

When permitted by law, you have the right to request the return of your Data (in a structured, machine-readable format) or, where technically feasible, to transfer it to a third party.

11.7. Post-mortem Directives

You can also communicate your instructions regarding the preservation, erasure, and disclosure of your personal data after your death by providing us with the name of one or more authorized individuals on a durable medium. You can modify these instructions at any time.

ARTICLE 12. EXERCISING YOUR RIGHTS AND COMPLAINTS

The rights outlined in Article 11 of this Privacy Policy can be exercised directly with us according to the procedures mentioned in Article 4 of this Privacy Policy.

To enable us to respond to you promptly, it is recommended that you provide your name, first name, and email address.

Some requests to exercise rights (right of access) may need to be accompanied by a photocopy of an identity document bearing the signature of the person concerned in order to verify their identity and specify the address to which the response should be sent. A response will then be sent within one (1) month following the receipt of the request.

It is specified that data related to identity documents necessary for the exercise of the right of access, modification, or rectification will be retained for a period of one (1) year in accordance with Article 9 of the Code of Criminal Procedure.

However, we reserve the right not to respond to clearly unfounded or excessive requests.