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General Policy for the protection of personal data

Updated on 08.03.2024

Preamble

The Publisher attaches great importance to the protection of its Internet users' personal data.

It is for this reason that the Publisher undertakes, in the interests of transparency and information, to communicate this Policy to Internet users so that they are aware of the conditions under which their Personal Data is processed, used and protected.

This Policy may be modified, supplemented or updated in order to comply with any legal, regulatory, jurisprudential or technical developments. However, the Publisher guarantees that your Personal Data will always be processed in accordance with the Policy in force at the time of collection, unless a mandatory legal requirement stipulates otherwise and applies retroactively.

This Policy forms an integral part of the GCU. All capitalized terms, whether singular or plural, have the meaning given to them in the GCU.

1 – Appointment of a Data Protection Officer

The Publisher Group declares that it has appointed a Data Protection Officer (the "DPO") and has registered his appointment with the CNIL.
The DPO can be contacted for any questions, or for the exercise of their rights by Internet users at the following address: cnil@lpcr.fr.

2 – Origin of data collected by the Publisher

The Personal Data collected by the Publisher from Internet users is that which they enter on the Site when they:
• Pre-register online by filling in the form published on the Site.
• Fill in the contact form on the Site.
• Fill in the application form on the Site.
• Fill in the information requested in the company contact form or company parenting guide form.
Whatever the purpose for which the Internet user provides his or her Personal Data, the latter is asked for his or her consent to process said Personal Data. The Publisher therefore systematically obtains the Internet User's consent prior to any processing. Lastly, the Publisher specifies that the Site is intended for adults capable of entering into obligations, in accordance with the legislation of the country in which the Internet User is located. Thus, Internet users under 16 years of age, or who are otherwise incapable, must obtain the prior consent of their legal guardians before entering their Personal Data on the Site.

3- Purpose of processing

The Personal Data collected is used by the Publisher for the proper performance of its duties, in particular the contractual relationship to be established with the Internet User, and to ensure compliance with its legal and regulatory obligations.
The Personal Data collected may also be used for the purposes of commercial and marketing communications, provided that prior consent has been given by the Internet User when communicating his/her Personal Data on the Site. The Internet User may, at any time, withdraw his/her consent by unsubscribing from the aforementioned communications.
The Publisher will not sell or rent Personal Data to third parties without the Internet User's prior consent.
The Publisher undertakes to ensure that the purpose of processing is always necessary, proportionate and appropriate.

4 – Categories of Personal Data collected

The Publisher undertakes to collect only Personal Data that is relevant and limited to what is necessary for the purposes for which it is processed.
Accordingly, the Publisher only collects declarative Personal Data, which is entered by the Internet user on the Site.
The Personal Data processed is the Internet user's identification and contact data, such as surname, first name, postal address, e-mail address and telephone number. When pre-registering for a crèche on the Site, the Internet user's family and financial situation are also processed, as well as the surname, first name and date of birth of the child for whom pre-registration is requested. In the context of an application on the Site, Personal Data relating to the Internet User's qualifications, level of study and professional experience are processed.
The Publisher hereby informs Internet users that no "sensitive" Personal Data is collected via the Site.

5 – Recipients of Personal Data

The Personal Data collected is intended for the Publisher. Within the company, and depending on the purposes of the processing, it may be communicated to the various support departments, as well as to the nursery managers.
The Personal Data of Beneficiaries may also be communicated to service providers commissioned by the Publisher for the sole purpose of ensuring the proper execution of its mission.
In addition, the Internet user will be informed if any of his Personal Data is transferred within or outside the European Union, and all necessary measures will be taken by the Publisher to ensure that this transfer complies with current regulations.

6 – Securing Personal Data

The Publisher undertakes to protect Internet users' Personal Data by implementing all technical and organizational measures to ensure the security and confidentiality of Personal Data processing.
In particular, the Publisher takes all necessary precautions to prevent Personal Data from being distorted, damaged or accessed by unauthorized third parties.

7 – Retention period for Personal Data

The Publisher retains the Internet User's Personal Data for a period that does not exceed the time required for the purposes for which it is collected and processed, or the time required by applicable legal or regulatory requirements.

8 - Users' rights regarding the processing of their personal data

In accordance with current regulations, Internet users have the following rights with regard to the processing of their personal data:
• Right of access to processed Personal Data,
• Right to delete processed Personal Data,
• Right to object to the processing of Personal Data,
• Right to rectification of Personal Data,
• Right to portability of processed Personal Data.
To exercise their rights, Internet users may send an e-mail to cnil@lpcr.fr or a letter to the following address: THE GRANDIR GROUP - Direction Juridique & Conformité - Immeuble Stories - 7, rue Touzet Gaillard - 93400 Saint-Ouen-sur-Seine.
The Publisher will have one (1) month to respond to requests from Internet users. This period may be extended to two (2) months in the case of a complex request or in view of the large number of requests.
The Editor may refuse a request for deletion of Personal Data made by the Internet user concerned by the processing, if such data must be retained in order to meet the legal, fiscal and accounting obligations of the Data Controller.
Finally, you also have the right to lodge a complaint with the French Data Protection Authority, the Commission Nationale de l'Informatique et des Libertés (CNIL), if you consider that your rights have not been respected.

9 - Links to other websites

The Editor may provide links to other websites. Most of these websites are part of the Publisher's group, and some of them operate independently of the Publisher's Site and are not under its control. These sites operated by third parties may have their own privacy policies or conditions of use, which the Publisher recommends the Internet user to examine. The Publisher declines all responsibility for the content of these sites, for the products and services that may be offered there, or for any other use.

10 – Updating of this Policy

The Publisher may update or modify this Policy from time to time. Any such modifications will only be applicable after a period of 30 working days has elapsed since the modification was made.

11 – Contacting the Publisher in the event of a problem

In the event of a problem, or for any question relating to the Policy, the Publisher can be contacted:

- By post at the following address
THE GRANDIR GROUP - Direction Juridique & Conformité - Immeuble Stories - 7, rue Touzet Gaillard - 93400 Saint-Ouen-sur-Seine - France

- By e-mail to the following address: cnil@lpcr.fr