Preamble
Aleteia, a news and information website (hereinafter “the Services”).
Aleteia is committed to the protection of personal data. In this respect, Aleteia is committed to complying with the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”) and French Law no. 78-17 of 6 January 1978 on information technology, data files and civil liberties (the “Informatique et Libertés” law) (together, “the Data Protection Regulations”).
This Personal Data Protection Policy (hereinafter “the Policy”) forms part of our commitment to transparency and fair dealing towards you.
The purpose of the Policy is therefore to provide you with all the information you need in order to understand how Aleteia collects, processes and protects your personal data in connection with your use of the Services, and what options are available to you in this regard.
Aleteia may amend the Policy at any time, in line with any changes or additions made, in particular in order to comply with regulatory, case-law, editorial and/or technical developments. You are advised to refer to the latest version of the Policy before browsing.
ARTICLE 1. In what context and for what reasons is your personal data processed?
Personal data means any information that makes it possible to identify you as a natural person, directly or indirectly. This includes, for example: surname, first name, date of birth, gender, postal address, email address, a computer’s IP address, browsing history, purchase history, telephone number, payment card number, photographs, videos, comments containing your contact details, personal and confidential username and password, etc.
When you access the Services, you may be required to provide personal data, for example if you:
- create a user account on the Site;
- subscribe to one of our newsletters;
- take out a subscription to one of our Services;
- take part in a prize competition organised by us;
- answer a survey;
- forward a link or content from our Services to one of your contacts.
Providing this data may be mandatory in order to use some of our Services.
Your personal data is collected and processed for the following purposes:
- to create and manage your account;
- to enable you to benefit from our Services;
- to contact you to inform you of any prizes you may have won in connection with prize competitions;
- to respond to your requests;
- to inform you about news relating to our Services and our offers;
- to compile statistics on traffic to the various parts of our Services;
- to comply with applicable legislation should you take part in contribution areas moderated after publication (forums, reviews, uploading of any digital item, etc.);
- to identify abusive uses of our Services.
ARTICLE 2. Who may use your personal data?
Your personal data is collected when you subscribe to our Services. It is intended for Aleteia, and may be disclosed to third parties under certain conditions.
–Aleteia
Your personal data is processed by Aleteia for the purposes described above.
Your personal data may be:
- disclosed by Aleteia to its subsidiaries or to the subsidiaries of the Média Participations Group;
- transferred to any third-party company that Aleteia has appointed as a processor to carry out on its behalf any of the activities described above, it being specified that your personal data will remain under the control and direction of Aleteia.
–Our partners, if you agree
Third parties may use your personal data only if you have agreed to this.
If you tick a box offering you the opportunity to receive offers from our partners, or if you actively respond to any form of proposal expressing your explicit wish to receive such offers, your data will be transferred to the partner(s) concerned, so as to enable them to send you their offers of products or services, by email or by SMS, as applicable.
Any partner previously accepted by you may send you such offers until you inform them, under the conditions described by that partner, of your wish to stop receiving offers from them by email or by SMS, as applicable.
These partners are fully responsible for the processing of your personal data once it has been disclosed to them with your consent. It is their responsibility to comply with applicable law and to take account of your rights and any requests you may make.
–Third parties authorised by law:
In certain cases provided for by law, your personal data may be transferred to third parties legally entitled to access it upon specific request: judicial authorities, administrative authorities, your internet service provider, or a third party placing a cookie stored on your device (an external advertising network, another publisher, etc.).
We may also be required to disclose your personal data to third parties where such a measure is necessary to protect and/or defend the rights of the Data Controller, to enforce these provisions, or to protect your rights and/or interests or those of the public, provided that such disclosure is authorised by law.
In the event that all or part of the Data Controller is sold to a third party, we reserve the right to transfer your information as an asset sold or assigned.
ARTICLE 3. How can you access, modify and/or delete your personal data?
–Your rights
You have rights over your personal data.
In accordance with the Data Protection Regulations, and within the limits set in particular by Articles 12 to 22 of the GDPR, you:
- have the right to ask us for access to the personal data concerning you, as well as its rectification or erasure – you can access and rectify certain of your personal data directly from your Account;
- also have the right to object to the processing of your personal data, to request its restriction, and the right to the portability of the personal data provided.
In addition, within the limits set by Article 22 of the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Finally, we remind you that you have, in any event, the right to lay down general or specific directives concerning what is to become of your personal data after your death.
–Exercising your rights
The simplest way is to send us your request online. You can exercise these rights by:
– using the tools provided for this purpose and made available to you within our Services;
– writing to us at the following address: [email protected]
In addition, at any time and where applicable, you may withdraw your consent to the processing of your personal data by clicking on a dedicated hyperlink in the messages we send you.
Withdrawing consent does not affect the lawfulness of processing based on consent carried out before that withdrawal.
If you are unable to access, modify or delete your information online, you may submit your request by post to the following address: Aleteia, 57 rue Gaston Tessier, 75019 Paris, France, or by email to [email protected].
In order to prevent any unauthorised access, modification or deletion, and to prevent identity theft, please, as far as possible, enclose proof of your identity with your request. If there is any doubt as to your identity, we will ask you to send us – in addition – a copy of an identity document.
–A few points to note
Any abusive, manifestly unfounded or excessive request may be rejected.
The request must also state the address to which the reply is to be sent; failing this, the reply will be sent to any address known to us, as applicable. A reply will then be sent to you within 1 month of receipt of the request. This period may be extended by 2 months, taking into account the complexity and the number of requests.
We remind you that our partners are responsible for the use they make of your personal data and for taking your rights into account, including the right to stop receiving offers from them.
If your personal data is deleted, you acknowledge that you will no longer be able to access and/or order products on the Site.
You may, however, change your choices at any time within your user account, in the section dedicated to your choices regarding the sending of offers by third parties. If you change this choice after having accepted third-party offers, your personal data will no longer be transferred to our partners as from the processing of your request. Your request will not, however, have retroactive effect on data transfers carried out before your request. In that case, you will need to contact the third parties concerned directly.
ARTICLE 4. How long is your personal data processed by Aleteia?
Your personal data is stored by Aleteia and/or any service provider for the strict performance of the Services offered, and is retained for the period strictly necessary to achieve the purposes for which it is collected, in accordance with the applicable regulations.
Thus, for example, the data collected when you subscribe to one of our newsletters is retained in order to send you such newsletters for as long as you have not unsubscribed.
Beyond that, the data will be:
- either deleted or securely destroyed;
- or strictly anonymised, for statistical purposes only, and will not give rise to any other use of any kind whatsoever.
ARTICLE 5. Where is your personal data stored and processed?
As a matter of principle, Aleteia attaches great importance to protecting the personal data of its customers and subscribers, as well as to complying with the framework set by the Regulations on the protection of personal data.
Accordingly, your personal data is processed by us or by our service providers in France and in Italy and is not, as far as possible, transferred to third countries.
ARTICLE 6. Who should you contact regarding your data?
For any questions relating to your personal data, you may contact the Data Protection Officer appointed by the Média Participations Group, who is authorised to deal with all matters relating to the protection of personal data. You may contact them using the following details: [email protected]
We remind you that, in the absence of a satisfactory reply to your request, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés, the supervisory authority responsible for enforcing the Regulations on the protection of personal data in France, directly on the website https://www.cnil.fr/fr/agir or by post to the following address: Commission Nationale de l’Informatique et des Libertés, 3 Place de Fontenoy – TSA 80715, 75334 PARIS CEDEX 07, France.